Document 6b1EN5O642grGj2QVXKzkaLzm

From: Sent: To: Subject: (SPF Sant Publique - FOD Volksgezondheid) sgezondheid); Potential for end-use ban on the use of HFOs and HCFOs in insulation foams in the EU Dear On behalf of various elements of the European insulaon foam manufacturers, we have been tracking the trialogue discussions that are on-going within the EU on the revision of the F-Gas Regulaon (EC 517/2014). Although it is not absolutely clear what the current status is, we have picked up that there are proposals, led by the European Parliament and supported by the European Council and the Presidency to see a ban on all F-Gas use in insulaon foams from 1st January 2030 onwards, as outlined in the square-bracketed text in blue below: The insulaon foam industry has consistently argued that such a ban would be counter-producve to the objecves of the European Green Deal, and parcularly to the Renovaon Wave, and has outlined these arguments regularly at various gatherings over recent months (see below): 1 Use of Fluorinated Gases as blowing agents for highefficiency Product ban 19 4 The current F-Gas Regulation already requires insulation foams to use blowing agents with <150 GW 4 Fluorinated gases are preferred because of their low flammability and excel lent thermal insulating p HFOs and HCFOs maintain that high thermal performance which del ivers energy and resource efficiel 4 In certain appl ications PU Spray Foams), process safety would be compromised limiting building 4 Industry welcomes the proposal of the Swedish Presidency not to adopt the universal 2030 ban (19b; Impact assessment : Although insulation values for new buildings are set at a statutoryminimum, irrespective of insulation type, leaving design flexibility to the architect, the thicker building elements required to accommodate less efficient insulation materials can have a significant effect on the embodied energy arising from the building products used. In renovation & refurbishment projects, the geometry of the building is already defined and available space becomes a key driver in respect of the additional energy that can be saved Therefore, highly efficient insulation provides greater energy saving prospects. Since 80% of the buildings that will be standing in 2050 have already been constructed and are in use, the impact of losing high eff iciencyinsulation will be substantial Timber Frarne WM Construction - Bnct Outer Leaf wiles a Cost Wei Disbkips 1 S. 10 ... 20/ftiom. =... 1.1 . boot NNW I II da. Mal SIM 111110111 I IN411111111 OPIUM girami PIP IIPI s swim s. W CORIP *MA.sost L2V ittesse 111A14..Wk MOO ma Silli4eamot 1212,11,04si NMI 610. opoo NOM ISM IOW SON ors UNPIN , purr s The industry therefore appeals to Belgium to consider these arguments closely as it seeks to take a position on the proposal to see the use of F-Gases in high performance thermal insulation foam restricted, primarily because such a ban would substantially inhibit building renovation at a time when improving the thermal performance of the built environment is of paramount importance -- noting that 80% of the buildings that will be standing in 2050 have already been built. We think that, to a large degree, the call for a complete ban confuses the objectives of F-Gas Regulation and the proposed PFAS Restriction, which is something that we had understood the Spanish Presidency wanted to avoid. Please let us know if you have any specific questions arising on this issue, since we would be glad to address them. Best regards -- Regulatory & Sustainability Advisor j ;LArti rOaM ASSoCratiOn European Phenolic Foam Association, Unit 34 BASE Bordon Innovation Centre, Broxhead House, 60 Barbados Road, Bordon, Hampshire, GU35 OFX, UK T: I www.epfa.org 2 A Company Limited by Guarantee in England No 4146502 | VAT registration No 572 7251 33 This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please notify the system manager. Please note that any views or opinions presented in this email are solely those of the author and do not necessarily represent those of the company, unless specifically stated. Finally, the recipient should check this email and any attachments for the presence of viruses. The company accepts no liability for any damage caused by any virus transmitted by this email. Anthesis (UK) Limited shall not be held liable to any person resulting from the use of any information contained in this email and shall not be liable to any persons who acts or omits to do anything in reliance upon it. Anthesis (UK) Limited, part of the Anthesis Consulting Group a company incorporated in England and Wales (registered number 3409491) Registered office is: Fitzroy House, 355 Euston Road, London, England, NW1 3AL 3