The Alliance for Responsible Atmospheric Policy’s Refrigerant Imports Committee hosted a virtual side event during the joint 12th Meeting of the Conference of the Parties to the Vienna Convention and 32nd Meeting of the Parties to the Montreal Protocol entitled, “Tracking, Training, Tracing: Trade Enforcement on Illegal HFC Imports.” The Side event featured representatives from the US Environmental Protection Agency (EPA), the European Fluorocarbons Technical Committee (EFCTC), and King and Spalding LLP. The focus of the side event was to evaluate the impact of illegal imports on global trade and outline the current role of secretariat in facilitating import compliance accordance with the Montreal Protocol. The panel of trade and enforcement experts discussed cooperative efforts to eliminate illegal imports and the key elements of effective programs. The panel assessed which enforcement measures must be undertaken by parties to ensure the integrity and success of the transition under the Protocol.

Panelists outlined import data transparency as a key element of an effective enforcement programs. The immediacy and transparency of information sharing between relevant agencies has proven an integral component in differentiating between open smuggling and traditional smuggling. This empowers programs to adequately punish and flag illegitimate perpetrators while protecting the interests of legitimate imports and their licenses/quotas. Data transparency working tandem with heightened resources for customs administrations can ensure identification of suspect containers before its crosses borders and pose risks to human health and equipment of legitimate consumers. Consistent interception of illegally imported HFC material at border stations will result in better origin tracing and halt the growth of illegal imports across the global market.

The recording of the session can be downloaded here and the slides that were used for the event can be found in the Refrigerant Imports Committee Resources tab.

The Alliance for Responsible Atmospheric Policy’s Refrigerant Imports Committee hosted a virtual side event for the 42nd Meeting of Open-Ended Working Group entitled, “Curtailing Illegal HFC Imports: The Role of Effective Trade Enforcement.” The Side event featured representatives from the Cooling Post, European Commission, UN Environment Program (UNEP), Environmental Investigation Agency (EIA), and European Anti-Fraud Office (OLAF). The focus of the side event was to evaluate the best practices from F-Gas Regulations counter-active measures against the growth of HFC Imports. As much as 33 million tons of illegal material has come into the EU since the prices for these compounds skyrocketed in 2018 from starting the EU HFC phasedown.

Three primary areas of action that the panelists agreed would incentivize more robust management of the European Market lessen the saturation from illegal imports:

  1. Making collaboration between custom administration easier and mandate mandatory reporting and data sharing from import stations.
  2. Generate more detailed and translatable licensing codes to allow custom agents to more readily identify illegitimate packaging to confiscate the fraudulent material within.
  3. Develop punitive measures, especially in EU border states where a majority of illegal material is stored before being transported into the EU.

The recorded session can be dowloaded here.