The Environmental Investigation Agency (EIA) has published a bulletin detailing a recent case of illegal refrigerant trade involving cross-border smuggling and unauthorized online sales, in violation of U.S. environmental laws.
On February 3, 2025, Michael Hart of San Diego was sentenced to time served, one year of supervised release, and a $1,500 restitution fee for conspiring to illegally import and sell hydrofluorocarbons (HFCs) and hydrochlorofluorocarbons (HCFCs). Hart pleaded guilty to charges under the American Innovation and Manufacturing (AIM) Act and the Clean Air Act.
Court documents state that between July and October 2022, Hart smuggled refrigerants from Mexico into the U.S. using his personal vehicle. He then sold them via informal online platforms including OfferUp and Facebook Marketplace. Hart claimed to have purchased canisters in Mexico for approximately $130–140 USD each and resold them in the U.S. for around $275 per unit.
Records show that Hart offered at least 94 cylinders of refrigerant to 22 individuals. The products included R-22 (51 cylinders), R-410A (10), R-404A (31), and R-134A (2), with an estimated total of 2,840 metric tons CO₂e—comparable to the annual emissions of 663 gasoline-powered vehicles if released, according to EPA data.
A U.S. Customs and Border Protection (CBP) officer intercepted Hart’s vehicle on October 18, 2022, discovering ten 24-pound canisters labeled as Freon 404A imported from China. These contained HFC-143a, HFC-125, and HFC-134a, all of which require an EPA import allowance.
The EIA emphasized that this case exemplifies how illegal refrigerant trade can bypass environmental controls through online peer-to-peer sales without proper certification or documentation. The agency urged stakeholders to remain vigilant and outlined key red flags, including suspicious pricing, lack of certification, and improper labeling or packaging.
The bulletin concludes that increased awareness and due diligence across the HVACR supply chain are essential to help prevent illegal refrigerant trade and uphold environmental regulations.
