EU F-Gas regulations – Foam Insulation Products

Foam Insulation Products

This guidance is for organisations affected by the 2014 EU F-Gas Regulations (517/2014). The F-Gas
Regulations create controls on the use and emissions of fluorinated greenhouse gases (F-Gases)
including HFCs, PFCs and SF6.

In the foam insulation sector, the F-Gas Regulations affects the use of HFCs as foam blowing agents.
The 2014 EU F-Gas Regulation replaces the 2006 Regulation, reinforcing all of the 2006 requirements
and introducing a number of important new measures.

The F-Gas Regulation is an important piece of legislation that will result in significant reductions in the
emissions of F-Gases. These are very powerful greenhouse gases, with global warming impacts that can be more than a thousand times higher than CO2 (per kg of gas emitted). All EU Member States agree that it is important to reduce emissions of these gases.

This Information Sheet describes the requirements that apply to foam insulation products.

Sector description

EU F-Gas regulations – Foam Insulation Products

The manufacture of many types of foam insulation requires the use of a blowing agent to create the
desired cell structure and product density. The blowing agent remains trapped within closed cells and,
owing to its low thermal conductivity, creates a significant proportion of the insulating properties of
the foam. Since the phase out of CFCs and HCFCs for foam blowing, a proportion of foam products
have been manufactured using HFC blowing agents. These blowing agents have favourable properties
including low thermal conductivity and being non-flammable.

The choice of blowing agent depends on the foam type and the application. Most insulation foam is
manufactured in a factory environment where safety issues such as flammability can be controlled.

This allows for a range of blowing agents to be used, including hydrocarbons, where this choice does
not compromise product performance. However, some foams are created “in-situ” (e.g. spray foam
used for external roof insulation and one component foam aerosols) where the impact of flammability
could be a more significant issue.

There are 2 main categories of foam referred to in the F-Gas Regulation. Extruded polystyrene foam
(XPS) is used in the form of insulating boards or panels and is often manufactured using HFC 134a
blowing agent. The Regulation also refers to “other foams”, which includes polyurethane,
polyisocyanurate and phenolic foam types.

These are sometimes manufactured using HFC 245fa or HFC 365mfc/227ea blends. These other foams can be used in a wide range of applications including domestic appliances, steel faced or laminated panels, pipe and vessel insulation and as spray foam.

Manufacture and purchase of new foam insulation products

EU F-Gas regulations – Foam Insulation Products


The main impact of the 2014 F-Gas Regulation on the manufacture of foam insulation is a series of
bans applied to placing new foam products on the market.

NEW: Impact of the HFC Phase Down on the manufacture of foam insulation

When selecting a foam blowing agent you should also consider the HFC phase down2
that is a key feature of the 2014 F-Gas Regulation. This will reduce the quantity of HFCs that can be sold in the EU – by 2030 there will be an 80% cut in HFC supply.

If the blowing agent is part of a mixture (e.g. an HFC blended with a hydrocarbon), the GWP threshold is for the mixture. Annex IV of the Regulation specifies how to calculate the GWP of a mixture.

Irrespective of the bans described above, it makes sense to always use foam blowing agents with the lowest practical GWP to minimise the future impact of the phase down

New: Product Labelling

EU F-Gas regulations – Foam Insulation Products

From January 1st 2015 all foam products and pre-blended polyols that contain F-Gases (including HFCs) shall not be placed on the market unless the F-Gases are identified with a label. The label should
indicate the F-Gas used as a blowing agent, with the accepted industry designation or, if no such
designation is available, the chemical name.

The label shall clearly indicate that the foam or pre-blended polyol contains F-Gases.
In the case of foam boards, this information shall be clearly and indelibly stated on the boards.

Use of existing foam products

EU F-Gas regulations – Foam Insulation Products


There are no restrictions in the 2014 F-Gas Regulation that affect the use of existing insulating foam.

End-of-life requirements

EU F-Gas regulations – Foam Insulation Products


The 2014 F-Gas Regulation requires operators of products and equipment that contain F-Gases to
arrange for the recovery of the gases, “to the extent that it is technically feasible and does not entail
disproportionate cost”.

Recovery of blowing agent from foam may involve crushing the foam in a special plant and capturing
the released gases. Specialised recovery facilities are available in the UK for domestic appliances
(mainly refrigerators and freezers). Recovery of blowing agents from domestic appliances is
mandatory and should be available via all UK local authorities. Commercial refrigeration appliances
(e.g. display cases used for food retail) are also subject to mandatory blowing agent recovery at endof-life.
Block foam used for insulating pipes and vessels can also be sent for processing in the facilities
dealing with domestic appliances.

Steel faced insulation panels may be cut up and processed in domestic appliance facilities. The steel
facings can be recovered in addition to any F-Gases in the insulating foam.

For some foam products end-of-life recovery is not considered feasible or cost effective. For example
laminated panels used as building insulation foam needs to be segregated from demolition waste and
then sent to a specialised recovery facility. Currently this might not be cost effective in terms of the
F-Gas Regulation requirements.

It is important to note that end-of-life foam insulation products could contain a range of different
blowing agents:
• Foam manufactured before 1995 probably used CFCs
• Foam manufactured between 1995 and 2004 may have used HCFCs
• Foam manufactured after 2004 may have used HFCs
• Since the phase out of CFCs, various other blowing agents have been used.

In particular, for polyurethane and phenolic insulation, hydrocarbons (HCs) are often used. This must be taken into consideration at recovery facilities as the blowing agent could be highly flammable.
Organisations disposing of building insulation foam should be aware that the foam should be treated
as a hazardous waste under UK waste regulations if it contains ozone depleting blowing agents
CFCs or HCFCs), or if a particular HFC is classified as dangerous to human health or the environment
under the EU Classification Regulation (1272/2008). Building insulation waste containing HFCs or their
mixtures that are not classified as dangerous is not defined as hazardous waste.

All recovered F-Gases can either be:

a) Sent for destruction by incineration at a licenced waste facility
b) Sent to a hazardous waste landfill
c) Sent to a specialist plant that can re-process old HFC blowing agent into a gas with properties
identical to virgin fluid, to create “reclaimed blowing agent”.

In the foam sector this is a theoretical possibility, although in practice it is unlikely to be worthwhile. The specialist foam crushing plants receive a mixture of different foam types, hence the recovered blowing agent could be a mixture of CFCs, HCFCs, HFCs and HCs. Only a small proportion of the recovered blowing agent will be HFCs, so segregation and reclaim may not be cost effective.

Reporting of imports

EU F-Gas regulations – Foam Insulation Products

NEW: Any foam products containing HFCs and HFOs4 imported from outside the EU need to be reported to the Commission on an annual basis. The first report covers the calendar year 2014 and must be submitted to the Commission by March 31st 2015. Reports for future calendar years must be made by March 31st of the following year.

The SRAC industry and the world as a whole, now understand that fluorinated gases have a potentially devastating global warming effect when released into the atmosphere.

F Gas regulations have been implemented in order to contain, prevent and thereby reduce emissions of fluorinated greenhouse gases.

On 2nd April 2008, the Commission Regulation 303/2008 set out the requirements for a company certification scheme.

This scheme is specifically for businesses working with F Gas refrigeration, air-conditioning and heat pump equipment containing or designed to contain fluorinated greenhouse gases.

These F Gas Certification requirements are in accordance with Article 5.1 of EC Regulations 842/2006 on certain fluorinated greenhouse gases (the EC F Gas Regulation).