Last year was the first year that the European Union’s phase down under the F-gas regulations came into force, allocating registered companies a quota from the total 182.5 million tonnes of F-gas allowed to be placed on the market.
Honeywell maintains that this amount has been exceeded by what it describes as illegal imports. If true, the illegal amount is equivalent to more than 5% of the total allocation and based on CO2 equivalents would represent, for example, well over 2,500 tonnes of R404A or 7,700 tonnes of R134a.
The concerns are also backed by another leading refrigerant supplier Chemours who said that they, too, had seen market indications of illegal imports.
Honeywell says it has based its estimated calculations on publicly available sources, such as export data from China, and compared these with EFCTC (Cefic) data. Honeywell has also heard of instances of companies without quota bringing in material and offering it for sale.
“As Honeywell is a significant market player, we also used our own estimations of imports of the biggest market players,” Dr Patrick Amrhein, Honeywell’s fluorine products marketing director for EMEA, told the Cooling Post. “This resulted in a figure showing material which cannot be assigned to any market player – and therefore has to come to the market outside of the quota.”
However, the real scale of the trade in illegal material could be far higher and does not include any refrigerant shipments that may have been smuggled into Europe or mis-declared.
“The amount of material coming into Europe far exceeds what should be coming in,” said Dr Amrhein. “I think 10 million tonnes is a conservative figure. Our estimation is that it is larger.”
A total of 413 companies were assigned quotas in 2015, 334 of them were new entrants. Each quota holder’s figures are audited at the end of March each year. The consequences for producers and importers exceeding their allocated quota is a deduction of double the excess from the company’s quota the following year.
Earlier this year, the Cooling Post revealed that imports of HFC refrigerants doubled in 2014, suggesting huge stockpiling in the run-up 2015 to the introduction of F-gas quotas.
Lack of control
Honeywell has also raised concerns at what it perceives as a lack of control or implementation at customs points.
“We see a disconnect between the legislation and its implementation at a national level,” said Dr Amrhein. “I don’t think there is currently a system in place which allows the national customs authorities to really check if an importer has quota or if the importer who does have quota has exceeded the amount of imports they can bring in.”
The concerns over the potential for illegal imports are shared by Chemours. “We have seen market indications of illegal imports as mentioned by Honeywell,” said Lene Stosic, Chemours’ senior communications manager, EMEA. “We share the commitment to supporting the F-gas industry in the successful implementation of the cap and phase down.”
Authorised dealer programme
To reassure the market, Honeywell has implemented an Authorised Dealers programme to help purchasers ensure they are buying refrigerants that comply with the European F-gas regulations.
“This programme is part of Honeywell’s ongoing efforts to help customers ensure they are using refrigerants and other materials that comply with this new regulation,” said Dr Patrick Amrhein. “By buying from a Honeywell Authorised Dealer, customers can avoid putting their businesses at legal risk of violating the regulation by using an illegal refrigerant. Honeywell is continuing to build awareness of the risks and legal consequences of using illegally imported refrigerants, and is working closely with EU authorities to actively prevent illegal imports to the EU market.
“We are not the policemen of the industry, we are just responding to requests from our customers who want to buy genuine high quality material that is fully compliant with the F-gas regulations,” Dr Amrhein maintained.
Honeywell’s list of country by country authorised dealers can be found here.