The Environmental Investigation Agency (EIA) has published the fourth issue of its Illegal Trade Bulletin, detailing recent enforcement actions and safety warnings related to the global trade of illegal refrigerants. The bulletin underscores how counterfeit and smuggled refrigerants pose dual threats to climate and public safety, and highlights the importance of regulatory enforcement and industry vigilance.
In the United States, a technician holding a Universal EPA certification was convicted on September 12, 2025, for illegally importing ozone-depleting HCFC R-22 in violation of the Clean Air Act. The refrigerant was intercepted at the San Ysidro port of entry by Customs and Border Protection officers. Although R-22 can still be legally sold in the US if recycled or reclaimed, new production and importation are banned due to its ozone-depleting potential.
In Canada, Environment and Climate Change Canada (ECCC) issued a December 2025 warning about counterfeit refrigerants mislabelled as R-410A. These products were found to contain a mixture including R-40, a substance known to be flammable and reactive in HVAC systems. The ECCC emphasized that R-40 contamination poses serious safety risks, including equipment damage, toxic chemical reactions, and potential explosions.
Authorities in Hong Kong seized approximately 1,300 cylinders of refrigerant on November 20, 2025, during a joint operation by Customs and the Environmental Protection Department. The shipment, falsely declared as laminate flooring, included R-410A, R-454B, and R-22, and had an estimated market value of HK$6.4 million (US$822,000). The seizure was made under Hong Kong's Import and Export Ordinance and Ozone Layer Protection Ordinance.
In Spain, enforcement agencies dismantled a criminal group allegedly involved in the illicit marketing of fluorinated gases. In December 2025, joint operations by the Spanish Tax Agency and National Police led to the seizure of 48.5 tonnes of illegal F-gases stored in 4,781 cylinders, with a market value of about €3 million (US$3.5 million). Five individuals were arrested, and authorities reported financial transactions exceeding €10 million (US$11.5 million) potentially linked to money laundering and tax evasion.
The bulletin also covers capacity-building efforts in the Philippines, where the Environmental Management Bureau and UNEP OzonAction organized a training workshop in November 2025 for Bureau of Customs officers. The training aimed to strengthen enforcement of the Montreal Protocol and the Kigali Amendment by addressing techniques for detecting illegal imports and misdeclared refrigerants.
According to the EIA, these cases demonstrate the increasing sophistication of illegal refrigerant trade and the need for coordinated enforcement, technician awareness, and strengthened supply chain verification.
