Changes to the processing obligations of old insulation

From the beginning of 2025, old insulation boards and elements containing F gases must be treated in such a way that the gases in them are either recovered or disposed of.

The new obligation is based on the updated EU F-gas and ozone regulations.

Does it apply to your project?

Identify whether the new obligation applies to your project, i.e. whether insulation containing F gases will be removed in connection with the repair or demolition project. The building owner and contractors are responsible. 

What about insulation

Fluorinated gases (F-gases) have been used before 1996 polyurethane, phenolic and XPS insulations in manufacturing. There are no F gases in wool or EPS insulation.    

The obligations concern insulation boards, sandwich elements and products where insulation boards have been used (e.g. insulated doors). On the other hand, foams used for sealing, insulating or fixing, such as window or door installation foams, are not covered by the obligations.

INCLUDES buildings built before 1996

  • polyurethane sheets and elements
  • phenolic sheets and elements
  • XPS boards and elements

DOESN'T BELONG

  • wool insulation
  • EPS insulation
  • sealing/insulating foams

Who can recover or dispose of F-gases

A facility that processes F gases or burns insulation boards must have an environmental permit. 

Get the waste management plan in order

Define in the waste management plan and agree with your waste management operator how insulation containing f-gases will be collected at the site (collection separately and as intact as possible) and how the waste management operator will handle the collected insulation and where it will deliver it.

If it is not technically feasible to remove insulation boards from the structures, the owner or contractor must prepare a document that proves that removal is not possible. This document must be kept for five years and made available to the authority upon request. We recommend attaching such a document as part of the waste management plan. Note the settings do not recognize a similar possibility for sandwich elements. 

Reuse is not limited

The regulations do not limit the re-use of insulation boards and products containing insulation (e.g. doors) containing F-gases. Note that reuse may be impossible for some other reason. In this case, insulation boards and elements containing F gases must be treated in accordance with the requirements of the regulations. 

More information

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