Illegal imports

Illegal imports of fluorinated refrigerants into the EU

As part of the EFCTC (European Fluorocarbons Technical Committee), Arkema is strongly commited to fighting the issues surrounding the smuggling of illegal HFCs in the European Union.


Why we are fighting illegal HFC trade

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Some reported uses of illegal refrigerants led to:

  • Freeze-up of expansion valves and evaporator tubes
  • Corrosion and acid formation
  • Overall system performance issue

This illegal product can be created with methyl chloride of hydrocarbons which are highly flammable and can be extremely hazardous to contractors during maintenance operations as well as end-users during the use of the installations.


The phase down of the HFCs is a major factor of the F-Gas regulation whose goal is to lower the impact of HFCs by gradually reducing the quantity that can be placed on the EU market through a quota system. The F-gas regulation is anticipated to allow the EU to meet its commitments under the Kigali amendment to the Montreal Protocol, avoiding a temperature increase of almost 0.5 degree Celsius by the end of the century. The smuggling of illegal HFCs into the EU jeopardizes this effort.

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The black market of illegal refrigerants is harmful to the local economy due to lost VAT and taxes. It is often a key source of revenue for organised criminal organisations. Allowing this black market to thrive further complicates and undermines national law-enforcement efforts to tackle organised crime.

Help us fight

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We encourage our customers to report any suspicious activity using the EFCTC's dedicated plateform.


We invite you to commit with us to help stop the illegal trade and sign the pledge.


To learn more about illegal imports

Illegal R-22 imports into the United States

Arkema Inc., along with other major industry manufacturers, supports the efforts of the federal Environmental Protection Agency (EPA) and other governmental agencies to curtail the unauthorized import and purchase of R-22 refrigerant, a regulated ozone-depleting refrigerant that is also known as HCFC-22. This program, code-named Operation Catch-22, includes a new industry-sponsored web site (Catch-22 Compliance Line) that enables users to report suspected illegal import and/or purchase of the refrigerant.

The Clean Air Act, and its implementing regulations, established a schedule to phase out the production and importation of ozone-depleting substances beginning in 2002, with a complete ban starting in 2030. Proper authorization by the EPA is needed to legally import HCFC-22. The EPA is actively investigating smuggling and distribution of HCFC-22 through the multi-agency Operation Catch-22 initiative.


Anyone importing HCFCs without legal allowances is in violation of federal law, and purchasers of illegal refrigerant are at risk as well. It is important that you protect yourself by knowing your refrigerant source! Those who illegally deal in R-22 in the U.S. are subject to seizure of the product, large fines, and even imprisonment. The full extent of the law was shown in one case involving a smuggling operation where a Florida man was sentenced to 30 months imprisonment, followed by three years of supervised release, and a Florida corporation was sentenced to five years of probation for the illegal smuggling of 418,654 kilograms of HCFC-22 in 29,000 cylinders (estimated market value of over $3.9 million) over several shipments.


For reporting suspected violations, you may call 866-506-6134. Direct reports to the EPA can be made here. End users are encouraged to use any of these resources for the identification of illegal R-22 activity.


Arkema Inc. is dedicated to providing our customers with legal R-22 refrigerants, using allocated allowances, ongoing investments in reclaim services, and alternative refrigerants developed by Arkema at competitive prices throughout the HCFC-22 phase out.

Enforcement Actions under Title VI of the Clean Air Act