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Third party submission of information on alternatives for

Applications for Authorisation

NON-CONFIDENTIAL

Legal name of submitter(s): BASF SE

0013-01 and 0013-02 - benzene, ethenyl-, polymer with 1,3-butadiene, brominated - July 4, 2014

SUBMISSION OF INFORMATION ON ALTERNATIVES (NON CONFIDENTIAL)

TABLE OF CONTENTS

1. ALTERNATIVE ID AND PROPERTIES .................................................................................................. 3

2. TECHNICAL FEASIBILITY ...................................................................................................................... 4

3. ECONOMIC FEASIBILITY ...................................................................................................................... 6

4. HAZARDS AND RISKS OF THE ALTERNATIVE ................................................................................... 11

5. AVAILABILITY ......................................................................................................................................... 12

6. CONCLUSION ON SUITABILITY AND AVAILABILITY OF THE ALTERNATIVE .................................. 20

7. OTHER COMMENTS .............................................................................................................................. 21

REFERENCES ............................................................................................................................................. 22

APPENDIXES ............................................................................................................................................... 22

0013-01 and 0013-02 - benzene, ethenyl-, polymer with 1,3-butadiene, brominated - July 4, 2014 2


1. ALTERNATIVE ID AND PROPERTIES

Substance name: Benzene, ethenyl-, polymer with 1,3-butadiene, brominated Synonym: Polymeric FR, pFR or PolyFR CAS number: 1195978-93-8 Commercial name: ‘Emerald 3000’; ‘FR-122P’; ‘GreenCrest’; Brominated co-polymer of styrene and butadiene Representative structure:

Molecular weight: 60,000-160,000; <0.1% <1,000; <0.1% <500 Molecular formula: (C8H9)x(C4H6Br2)y(C4H6Br2)z Physical forms: Solid Use: Flame retardant Polymeric: Yes Oligomers: The average MW of this polymer ranges from 60,000 to 160,000 daltons with oligomers below 500 or 1,000 expected in negligible amounts as it has a very narrow molecular weight distribution (polydispersity close to 1.1). Appearance: White powder BASF agrees with the identification information provided in the applicants’ dossier.


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2. TECHNICAL FEASIBILITY

Current status BASF completely agrees with the applicants that PolyFR meets the technical and functional requirements for use in EPS. PolyFR is a block copolymer of polystyrene and brominated polybutadiene. It ensures excellent fire performance in expanded polystyrene (EPS) and extruded polystyrene (XPS) for thermal insulation applications. Experience from the market to date confirms that the performance of EPS with PolyFR is equal or even better than EPS with HBCD1 and that the processing of the new EPS grades does not present any difficulties for converters. BASF also understands that other EPS producers do not have technical difficulties switching their production from HBCD to PolyFR as the same technology and the same plants without any modifications can be used for the production of EPS with PolyFR. Furthermore, switching to this alternative will improve the industry’s environmental footprint by not using a SVHC (substance of very high concern) and a POP listed substance when it is no longer necessary. Industry has taken all required steps to ensure meeting the REACH timeline with a sustainable alternative to HBCD that has been developed, tested and approved for use in EPS beads and foams. Concerted efforts of the entire value chain, from the licensee Dow to thermal insulation producers, have led to the successful and timely development of a sustainable and economically viable alternative to HBCD. The result of a development and testing process that lasted for more than 10 years is a polymeric flame retardant (PolyFR) that has been endorsed by regulatory authorities and scientists for its superior environmental and fire safety profile. According to Dow, the PolyFR is a stable, high molecular weight, non-PBT (persistent, bioaccumulative or toxic) substance with an improved Environment, Health & Safety (EH&S) testing profile. It provides a fire safety solution for EPS (as well as XPS) foams which enables thermal insulation materials to continue to meet the increasing demands of energy efficiency regulations as well as the evolving fire safety building codes and standards (reference: Dow, 2011). Efforts to identify a viable alternative Already in 2003 BASF started to investigate alternatives to HBCD proposed by flame retardant producers. In October 2008, BASF received information on the PolyFR (based on technology licensed by Dow) and a few months later, in February 2009, the PolyFR had already been tested. EPS polymerisation (emulsion and suspension stability, bead size, molecular weight being higher than HBCD) and performance in B2 flammability test2 results were considered to be equally as good as with HBCD. This investigation into alternatives was not an exclusive BASF project, but a project of the whole European EPS industry, which is organised in PlasticsEurope, as referred to at the UNEP POPRC discussion on ‘Alternatives to HBCD – state of play’ in October 2013 (reference: Synthos, 2013). Hence, by April 2010 a viable alternative to HBCD in EPS had already been identified and developed and BASF was in a position to commit to introduce the alternative to the market within 4-6 years. In March 2011, Dow Global Technologies LLC announced that it had signed a license agreement with Chemtura Corporation for the production of PolyFR and that it was planning to finalise agreements with other licensees by the end of 2011 to ensure sufficient volumes for the global market (reference: Dow, 2011). BASF publically endorsed this announcement and stated that “extensive test series with the new flame retardant on a small to medium scale have yielded very promising results” (reference: BASF, 2011). In 2013,

1 Please note that HBCD and HBCDD refers to the same substance and can be used interchangeably

2 B2 is a German flammability test, very similar to the European Class E flammability test.



Dow issued a press release announcing that the PolyFR was licensed to the three largest producers: Chemtura, ICL Industrial Products and Albemarle (reference: Dow, 2013). Testing and Certification of PolyFR Pilot tests conducted by the industry on the viable alternative, PolyFR, confirmed that PolyFR delivers the required level of fire safety to its products and that it has essentially the same flame retardant efficiency to HBCD when used at equivalent bromine content. Tests also prove the good thermal stability and compatibility of PolyFR with polystyrene. An exhaustive testing programme was commissioned by the German Association of EPS converters for thermal insulation, IVH3 and carried out by the Institute for Insulation Research FIW Munich4 with the participation of five major European EPS producers. As all major EPS producers except two (BASF and Knauf) are included in the HBCDD Consortium, presumably at least three Consortium members were among the companies that participated in the testing programme (maybe even four, if Knauf did not participate in the programme). The testing programme lasted for over 1.5 years, from summer 2012 until the end of 2013, and compared EPS with HBCD to EPS with PolyFR. At the beginning of the programme, five different EPS producers supplied EPS with HBCD and EPS with PolyFR to different EPS converters. It is important to note here that this is an indication that already at that time the largest EPS producers were able to provide several tons of sample EPS material that was converted into foam for the tests. Therefore, these companies have already had two years of experience with PolyFR. The programme has proven that PolyFR is a suitable alternative to HBCD for EPS insulation foams as it has confirmed that a number of critical physical properties, including foam properties and fire resistance, of EPS containing PolyFR are at least on the same level as EPS with HBCD. The testing programme has allowed a fast track certification of insulating boards containing PolyFR for building applications. Its results were endorsed in September 2012 by the European Committee for Standardization (CEN) Sector Group 19 (SG19) of Notified Bodies for the Construction Products Directive (89/106/EEC), which is responsible for the conformity of thermal insulation products with harmonised European standards for EPS insulation materials. SG19 decided that for the substitution of HBCD with PolyFR in EPS the involvement of an external certification body for upfront approvals is not necessary. This is true for all EPS which is labelled according to EN 131635 (reference: GNB-CPD, 2012). Therefore, all testing, except for Class E flammability tests, can be done internally with EPS converters solely responsible for testing and documentation. Thanks to this endorsement by SG19, there are no hurdles for the marketing of EPS with PolyFR. BASF’s experience in the marketplace selling EPS with PolyFR shows that both producers and their customers (converters of EPS) are already able to successfully manufacture and commercialise these products and thus all necessary certificates and approvals are available or can be obtained in a timely fashion. EPS Production process Finally, it should be noted that the same technology and the same plants without any modifications can be used for the production of EPS with PolyFR. Some modification in the product recipe is needed, as is normal practice when introducing a new additive.

3 Industrieverband Hartschaum 4 Forschungsinstitut für Wärmedämmung 5 EN 13163 determines the properties of EPS insulation materials for buildings and procedures for testing


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3. ECONOMIC FEASIBILITY

Today, more than a year before the EU sunset date (21 August 2015), a seamless market introduction of EPS with PolyFR is well underway. BASF and a growing number of EPS producers are already in the process of producing and commercialising EPS with PolyFR in the European market (see market gathered information in the confidential submission by BASF). BASF is already using PolyFR in the majority of its range of EPS products. Our first EPS with PolyFR product was marketed in 2013. In the course of the first half of 2014, BASF has managed to switch most of its EPS material production (more than 80%) from HBCD to PolyFR. The switch of all EPS grades in Europe will be completed by the end of 2014, significantly earlier than required by EU law (reference: BASF Press Release, 2014). Please see the confidential submission for BASF data in support of this. Today, BASF is selling EPS with PolyFR in 30 European markets, including 26 EU member states (Austria, Belgium, Bosnia and Herzegovina, Bulgaria, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Great Britain, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Macedonia, Netherlands, Norway, Poland, Portugal, Romania, Serbia, Slovakia, Slovenia, Spain, Sweden, and Switzerland). Table 3 in our confidential submission demonstrates that the commercialisation of EPS with PolyFR is taking place throughout Europe. Furthermore, BASF has gathered evidence that a substantial number of HBCDD Consortium applicants are already in a position to offer EPS with PolyFR to the marketplace. The BASF confidential submission refers to this evidence in more detail. This successful commercialisation indicates the economic feasibility of transitioning from HBCD to PolyFR. Furthermore, the empiric evidence shows that EPS customers (converters) are able to manufacture and sell foam products made of EPS with PolyFR successfully, which proves that certification and approvals are already available across Europe. The experience from the market to date confirms that the performance of EPS with PolyFR is equal to or even better than EPS with HBCD and that the processing of the new EPS grades does not present any difficulty for converters.



BASF assessment of cost to industry if Authorisation is granted (see Appendix 1 for detailed explanation) BASF expects that a granted Authorisation will impose a large economic burden to the EPS and building insulating industries. Moreover, BASF predicts that an Authorisation of HBCD will have negative consequences on the overall insulation levels within the EU. This would endanger the achievement of the targets of the European Union to reduce energy consumption and greenhouse gas emissions6. There is no need to take these risks given that the EPS industry is already in the process of switching to PolyFR; can complete the process successfully by the sunset date of August 2015, and given that enough quantities of the alternative are available to cover the EU and global market demand. Should an Authorisation be granted, harsh criticism is to be expected from environmental associations and alternative insulation materials to the unnecessary use of HBCD in EPS, a substance classified as SVHC (substance of very high concern) and POP (persistent organic pollutant). Hence, the perception of EPS in the eyes of the value chain and end consumers will be severely damaged. This negative perception will be reinforced by the labelling requirements imposed by the Stockholm Convention (please refer to section 7). The consequence will be a reduction on the EPS demand and, due to its key role in the building insulating industry, a potential decrease of the overall building insulation sales, as some consumers would avoid insulating altogether7. The longer it takes to complete the switch, the more significant will be the harm to the sector’s image and the more negative the impact on EPS and building insulation sales. An Authorisation, independently of its length and restrictions, would thus encourage a long lasting switch8 away from EPS either to alternative insulation materials or away from insulation entirely. BASF has assessed the cost of a granted Authorisation in terms of lost value added to EPS producers and EPS converters caused by a long lasting reduction of EPS sales as a result of the building insulating industry switching away from EPS, but has not assessed its impact on previous steps of the value chain. Since it is not possible to estimate precisely the negative impact of a granted Authorisation on EPS sales, a scenario analysis is proposed. For the sake of simplicity, the proposed model neither describes the negative effects of an Authorisation in the packaging and recycling industries (please refer to section 7 comments on recycling), nor the consequences on employment, nor the impact on the environment of increased greenhouse gas emissions caused by reduced building insulation. Due to the long lasting impact of a reputational damage on EPS, these effects are expected to be significant. Our assessment estimates the loss of sales value added for EPS producers and converters in net present value terms (with base year 2014) from three scenarios: a highly conservative one of a 5% reduction of EPS sales value, a more probable one of a 10% reduction of EPS sales value and a more pessimistic one of a 15% reduction of EPS sales value, over the next 10, 15 and 20 years (Table 4).

6 It is important to note that building insulation is one of the most important instruments (if not the most) to reduce energy consumption and thus achieve the EU goals to comply with its commitments under the Kyoto Protocol to the United Nations Framework Convention on Climate Change (UNFCCC): its long term commitment to maintain the global temperature rise below 2°C, and its commitment to reduce, by 2020, overall greenhouse gas emissions by at least 20% below 1990 levels, or by 30% in the event of an international agreement being reached. Furthermore, building insulation also has an important part to play in encouraging security of energy supply, technological developments and in creating opportunities for employment and regional development, in particular in rural areas. Any reputational damage to EPS could thus put at risk the achievement of these goals. 7 This reduction in overall sales can be expected in light of existing attacks on the benefits of insulation. The additional pressure from a negative perception of EPS might create insecurity and drive consumers away from insulation altogether, especially on those applications where EPS is the material of choice (for example: external thermal insulation composite systems or Etics, which accounts for most of the flame retardant EPS sales in building and construction applications in Europe). 8 The explanation for the assumption that any switch away from EPS as an insulation material will be long lasting is linked to the conservative nature of the construction market. Each insulation material requires investment in employee training for applicators and explaining to architects and other decision makers, a costly and time intensive process. For this reason, once a firm changes insulation material, they are highly unlikely to switch back. This is reflected in the stability of the relative shares of materials in the insulation market.


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Table 4: Loss of a granted Authorisation (in m Euros; net present value with base year 2014)

Scenarios

Loss of a granted authorisation (in m Euros; net present value with base year 2014)

10 years 15 years 20 years

Long lasting loss of 5% of EPS sales

Lost sales EPS producers 523 717 877 Lost value added EPS producers 65 90 109 Lost value added EPS converters 47 64 79 Total lost value added 112 154 188 Long lasting loss of 10% of EPS sales

Lost sales EPS producers 1,046 1,434 1,753 Lost value added EPS producers 131 179 219 Lost value added EPS converters 94 129 158 Total lost value added 225 308 377 Long lasting loss of 15% of EPS sales

Lost sales EPS producers 1,569 2,151 2,630 Lost value added EPS producers 196 269 329 Lost value added EPS converters 141 194 237 Total lost value added 337 463 565 To make comparison with the applicants’ model possible, this model is based on:

• data provided by the applicants (market size, value added generated by EPS converters); • the extremely conservative assumption of no growth of the EPS market from 2007 onwards; • the conservative assumption of a value added generated by EPS producers of 12.5% of the EPS

sales value. For additional information on this model, please see Appendix 1. It should also be noted that the costs in the BASF model do not take into account the costs of idle production plants for the PolyFR producers, or the costs already incurred by BASF and other EPS producers who are not members of the consortium for serving the market with a product (PolyFR) that is more expensive than HBCD. It also does not take into account employment effects or additional costs to consumers. In all these aspects, our model is highly conservative. BASF considers that an Authorisation is unnecessary as the EPS industry is already in the process of switching to PolyFR, can complete the process successfully by the sunset date of August 2015 and enough quantities of the alternative are available to cover the EU and global market demand. Thus, an Authorisation of HBCD would yield no benefits while the costs to the industry are expected to be very high, as the proposed model (Table 4) shows. Pricing The current experience indicates that the switch to the alternative (PolyFR) increases the cost of the final foam product by only 1 - 3% (under the assumption that all other costs, including manufacturing of foam products, stay the same) and thus the switch to the alternative is not expected to result in a switch to different insulation materials or reduce overall insulation demand. However, due to the commodity nature of EPS, its high degree of interchangeability and its low value added, the difference in cost for EPS producers (both because of the higher price per unit and the higher need of input to replace HBCD by PolyFR) between the two flame retardant systems would have a large impact on their bottom line if both products were simultaneously allowed in Europe. A granted Authorisation would thus penalise and slow down the introduction of the sustainable alternative, PolyFR. By allowing the applicants to continue using HBCD, an Authorisation would give a competitive and economic advantage to the applicants as converters would choose to stay with the cheapest product



available (EPS with HBCD) as long as possible. As we have explained earlier, this will damage the EPS share of the insulation market and is expected to reduce demand for insulation materials altogether. Applicants’ assessment of cost to industry if Authorisation application is rejected BASF has identified and would like to bring to ECHA’s attention a number of inconsistencies in the HBCDD Consortium’s argumentation regarding the estimated loss resulting from a refused Authorisation. According to the applicants, the historical annual value of flame retarded EPS pellet sales for the consortium is estimated to be approximately €0.8-1.3 billion per year. The application also estimates that lost sales value to EPS formulation over the period 2016-2019 would be €1,175m in Present Value (PV) if Authorisation for use 1 (production of EPS beads) was refused (reference: Socio-economic Analysis, p.69). These numbers are based on the volume of EPS that could not be produced given the asserted shortage in supply of the only viable alternative flame retardant system, PolyFR. Firstly, BASF is in a position to demonstrate that no shortage in supply of PolyFR is expected if the Authorisation is refused (please refer to section 5). As a result, the total lost sales value (and lost sales value added) of a refused Authorisation is expected to be zero. Secondly, the model presented by the applicants to estimate the supply / demand balance of PolyFR seems to have been wrongly calculated: the applicants estimate –based on their own assumptions- that 57% of the global HBCD demand from 2015 to 2018 will be replaced by an alternative flame retardant. The rate of HBCD replacement in the world is not evenly distributed: Europe (with a global HBCD demand share of 40%) is assumed to have a HBCD replacement rate of 100%, whereas Non-EU (which accounts for 60% of the global HBCD demand) is only assumed to switch partially (for example, China, which represents 65% of the Non-EU HBCD demand is expected to have a HBCD replacement rate of 0% from 2015 to 2018); in fact, when using the applicants’ own assumptions, the obtained Non-EU HBCD replacement rate is 28% However, in order to calculate the demand of HBCD that will be replaced by an alternative flame retardant in Non-EU, the applicants use the global replacement rate of 57% and not the Non-EU replacement rate of 28% which leads to a large overestimation. For more details, please refer to section 5 and appendix 3. Using the applicants’ own assumptions and correctly calculating the resulting model, the availability situation of PolyFR looks much different (Table 5). If we use all the applicants’ own assumptions and correctly calculate the resulting model to estimate the cost of a refused Authorisation, the resulting loss of EPS sales value expected by the applicants in net present value (base year 2015) should not be 1,175m Euros but only 57m Euros (only in 2015 and 2019 a small deficit of PolyFR should be expected by the applicants, and thus a much lower reduction of EPS production and sales than the one claimed in their Socio-economic analysis)


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Table 5: Comparative summary of applicants’ model by correcting miscalculation (see Appendix 3 for detailed explanation) 2015 2016 2017 2018 2019 TOTAL PolyFR Deficit/Surplus (wrongly calculated applicants’ model) tonnes

-7,489 -1,802 -753 1,046 -4,500 -13,498

Lost sales to consortium EPS formulators (wrongly calculated applicants’ model) million Euros

270 260 109 0 649 1,288

Lost sales to consortium EPS formulators (wrongly calculated applicants’ model) million Euros NPV (base 2015)

270 250 101 0 555 1,175

Lost sales value added to EPS converters (wrongly calculated applicants’ model) million Euros (base 2015)

26 24 9 0 53 112

PolyFR Deficit/Surplus (correctly calculated applicants’ model) tonnes

-921 4,766 5,739 7,160 -193 16,551

Lost sales to consortium EPS formulators (correctly calculated applicants’ model) million Euros

33 0 0 0 28 61

Lost sales to consortium EPS formulators (correctly calculated applicants’ model) million Euros NPV (base 2015)

33 0 0 0 24 57

Lost sales value added to EPS converters (correctly calculated applicants’ model) million Euros (base 2015)

3 0 0 0 2 5

Note: to calculate the lost sales to consortium EPS formulators in 2015 the original figure of 270m Euros has been reduced in the same proportion of the reduction of PolyFR expected deficit: 270 x (-921 / -7,489) = 33 Thirdly, BASF believes that using lost sales value instead of lost sales value added is not the appropriate way to estimate the costs from a refused Authorisation application for use 1. The main argument of the applicants to use lost sales value is that it allows them to estimate the impact of the reduced EPS production on previous steps of the value chain. However, a theoretically assumed reduction of the EPS production volumes will not change the value added generated in previous steps of the value chain, especially not in Europe. Moreover, a large share of the EPS sales value is due to raw material costs and not to the value added generated previously. The EPS value generation only starts after natural gas or petroleum is converted into Naphtha and used in crackers to produce benzene and ethylene, which are then combined to produce styrene, the main raw material of EPS. Both natural gas and petroleum to produce styrene and most of the additives (including HBCD) used to produce EPS are imported to the EU. Styrene as monomer is not only used for the production of EPS, but also for the production of other styrene derivatives including polystyrene, acrylonitrile butadiene styrene (ABS), styrene-butadiene (SBR) rubber, styrene-butadiene latex, styrene-acrylonitrile resin (SAN), and unsaturated polyesters resins. According to BASF estimates from 2013, the styrene monomer production capacity in Europe is around 5.2 million tons p.a. The styrene consumption share of EPS in Europe is below 30%. The actual production volume in Europe was around 4.8 million tons in 2013, around 0.7 million tons were imported -mostly from US but also from Middle East- and around 0.3 million tons were exported from Europe to other regions. A reduction of the EPS production volume in Europe as stipulated by the applicants’ would not lead to a reduction of the styrene monomer production volume: For example, the applicants’ claim (Table 4.1 of their Socio-economic analysis) that a granted Authorisation would result in a loss of 270m Euros of EPS sales value in 2015, which translates into approximately 180,000 t of EPS sales (assuming an EPS price of 1,500 €/t) and roughly 170,000 t of styrene monomer (assuming a styrene monomer content of 95% in EPS) In such scenario the styrene monomer imports could easily be reduced and styrene monomer exports could be increased which would allow the styrene producers to compensate the reduced EPS volumes assumed by the applicants, therefore no value added would be lost in Europe.


http://en.wikipedia.org/wiki/Polystyrene

http://en.wikipedia.org/wiki/Acrylonitrile_butadiene_styrene

http://en.wikipedia.org/wiki/Styrene-butadiene

http://en.wikipedia.org/wiki/Rubber

http://en.wikipedia.org/wiki/Styrene-acrylonitrile_resin

http://en.wikipedia.org/wiki/Polyester_resin


The EPS industry has a very low value added. BASF’s own experience shows this value added to vary between 10% and 15% of the EPS price depending on the year. Given the commodity nature of EPS9 and given the situation of overcapacities in Europe10, it is a fair assumption to use BASF experience to estimate the industry’s average specific value added. The lost sales value added would therefore be a much lower figure than the lost sales value stated in the application. Using the HBCDD Consortium’s estimates for EPS sales this lost sales value added would be around €7m in 5 years (by multiplying €57m by a value added of 12.5% of sales value). In addition, the HBCDD Consortium estimates that up to 500 jobs across the EU may be lost if the Authorisation for use 1 is refused. BASF believes that no shortage of PolyFR can be reasonably expected (please see section 5 on availability), and thus that no jobs are endangered. Even using the applicants’ model, after correcting for the wrong calculation, the expected reduction of EPS sales to formulators and converters only represents between 2% and 4% of the historical annual value of sales of the consortium (as described in page 69 of their Socio-economic Analysis) in 2015 and 2019, therefore no reduction of the total employment level within the EPS value chain should be expected in case of a refused Authorisation even accepting the applicants’ assumptions and resulting model. BASF also notes that while the applicants use lost sales value when calculating the cost of a refused Authorisation for use 1, lost sales value added is used for use 2 (production of EPS boards). Moreover, BASF notes that the applicants estimate present value with base year 2015. Thus, the combined value added loss in terms of net present value for uses 1 and 2 based on the applicants’ model with base year 2014 would be 7m Euros. This figure of 7m Euros is comparable to the scenario model presented by BASF (Table 4). In all scenarios presented by BASF the loss of a granted Authorisation is significantly greater than the loss of a refused Authorisation as predicted by the applicants. BASF firmly believes that sales value added is the correct method, and has applied it using the applicants’ model in order to make comparison possible. To allow the alternative direct comparison with the application, in Table 4 we have also provided the lost sales value figures for EPS producers as a result of a granted Authorisation. For example, according to BASF’s model, the loss of sales value to EPS producers in net present value terms (base year 2014) in case of a 10% long lasting reduction of EPS sales caused by a granted Authorisation over the next 15 years (from 2015 to 2029) would be 1,434 m Euros. Most importantly, BASF is in a position to demonstrate that no shortage in supply is expected if the Authorisation is refused (please refer to section 5). As a result, the total lost sales value (and lost sales value added) of a refused Authorisation is expected to be zero.

4. HAZARDS AND RISKS OF THE ALTERNATIVE

Scientists and regulatory authorities have endorsed PolyFR for its superior environmental profile compared to HBCD.

BASF fully supports the applicants’ statement that the PolyFR is not a hazardous substance or mixture according to Regulation (EC) No. 1272/2008 on classification, labelling and packaging of substances and mixtures or according to Directives 67/548/EEC and 1999/45/EC.

This was recently endorsed by the US regulatory body, the US Environmental Protection Agency (EPA), in its report on alternatives to HBCD, as part of its Design for Environment (DfE) Programme. The report, which considers three alternatives to HBCD, identifies PolyFR as the safest alternative for use in polystyrene building insulation (US EPA, 2014).

9 EPS is a product that is highly interchangeable, has an extreme low degree of differentiation and thus a very high price sensitivity. 10 as shown by the shutdown of two EPS facilities in 2013: INEOS Marl (reference: INEOS, 2013) and Polidux Monzon (reference: Heraldo.es, 2013)


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Consequently, the switch from HBCD to PolyFR would result in reduced overall risks to human health, safety and the environment.

5. AVAILABILITY

Using a consistent PolyFR demand model and based on publically available information by PolyFR producers, it can be concluded that by the EU sunset date in 2015, the availability of PolyFR will be more than sufficient to cover European, and indeed global, demand. Already since 2011, when Dow Global Technologies LLC announced its first license agreement for the Polymeric flame retardant, the industry was expecting significant commercial volumes to be available by 2013-2015 in line with market demand, allowing the global polystyrene foam insulation industry to prepare for a smooth transition from HBCD to the alternative in line with national regulations (Dow, 2011; Dow, 2014). Global Supply of PolyFR Producers of PolyFR have announced their plans to expand their capacities. As a result, as of the third quarter of 2014, the companies will have enough capacity to adequately cover European and global demand (Table 6). In April 2014, ICL IP announced that it was planning to increase its production capacity for PolyFR in order to be able to replace HBCD by August 2015. ICL IP already produces commercial quantities of PolyFR at its plant in the Netherlands which, according to the applicants, has a capacity of 3,000 t. In the third quarter of 2014 ICL IP will launch its commercial production plant in Israel with a capacity of 10,000 t. The plant of ICL IP in Israel, which BASF has visited, is a bigger version of their plant in the Netherlands which is already on stream; therefore, all processes have been already tested and adjusted and a smooth and quick scale up is foreseen. ICL IP’s investment is hence linked to an expected increase in commercial sales during the second half of 2014. In its communications, the company confirms that it will be able to achieve a smooth transition from HBCD before the EU sunset date (references: ICL IP, 2014; ICL IP, 2013). In addition, Chemtura’s plant in the US, which is already operating since 2012, has a capacity of 10,000 t (reference: Great Lakes Solutions, 2013a). Finally, on 21 October 2013, Albemarle also announced that it was expecting to commercialise the PolyFR before the REACH sunset date in 2015 (reference: Albemarle, 2013). Table 6: Availability of PolyFR according to producers Producer Product name Capacity (t/a) Start of production Press Release Great Lakes Solutions (Chemtura)

Emerald 3000 10,000 Q4 2012 22 April 2014

ICL Industrial Products FR-122P 3,000 10,000

Q2 2013 Q3 2014

5 March 2013 22 April 2014

Albemarle GreenCrest 10,000 (tbc) On standby in case of need

21 October 2013

Therefore, in the third quarter of 2014, there will be an existing global capacity of approximately 23,000 t for the production of PolyFR. Global Demand of PolyFR for EPS and XPS In 2011, the estimated global demand of HBCD was 31,000 tonnes according to the presentation by Chemtura at the UNEP POPRC meeting in October 2013 (reference: Great Lakes Solutions, 2013b). The demand for PolyFR can be calculated by using the demand for HBCD and applying a conversion rate to ensure equivalent bromine content as required for fire safety performance. Global demand of PolyFR should also take into account the availability of different alternatives to HBCD, as well as decisions taken by different regions on when they intend to switch out of HBCD: For example, China is not expected to ban the use of HBCD until at least 2019 and it is expected that it will grant a 5 year exemption for the use of HBCD. Other countries are likely to follow China’s example and also allow a few years before they phase out HBCD. For instance, it is expected that South Korea will not ban HBCD until at least 2019.


http://news.greatlakes.com/press-release/great-lakes-solutions-sees-continued-success-new-flame-retardant-technology

http://www.prnewswire.com/news-releases/icl-ip-accelerates-commercial-availability-of-sustainable-polymeric-flame-retardant-195210461.html

http://www.prnewswire.co.uk/news-releases/icl-ip-completing-second-production-facility-for-polymeric-flame-retardant-256176891.html

http://finance.yahoo.com/news/albemarle-samples-greencrest-polymeric-flame-200400682.html


BASF global PolyFR demand model in case of a refused Authorisation (see Appendix 2 for detailed explanation) Table 7 looks at global PolyFR demand evolution using realistic to moderately optimistic assumptions about the uptake of PolyFR. Namely:

• using demand of 12,400 t of HBCD in EMEA in 2011; • assuming a complete switch to PolyFR in Japan and EMEA already in 2015 (please note that EMEA

–Europe, Middle East and Africa- includes large EPS markets such as Russia and Turkey that are not expected to ban the use of HBCD shortly);

• considering no switch out of HBCD in China before 2019; • assuming a progressive switch out of HBCD in Korea (from 75% HBCD in 2015 to 50% in 2019); • using a conversion rate between HBCD and PolyFR on EPS and XPS of 1:1.2; and • considering that 90% of the HBCD alternative will be PolyFR in EMEA, 75% in Japan, 80% in

Americas and 75% in Korea (other alternatives to HBCD are already used in the XPS industry and in other regions such as Japan).

Table 7: Global PolyFR demand model of BASF (t) 2013 2014 2015 2016 2017 2018 2019 EMEA 1,488 6,696 13,794 14,414 15,207 16,196 17,248 Japan 2,232 2,232 2,232 2,232 2,232 2,232 2,232 Americas 0 670 1,190 1,190 1,190 1,190 1,190 PRC 0 0 0 0 0 0 0 Korea 0 0 349 698 698 698 698 TOTAL 3,720 9,598 17,565 18,534 19,327 20,316 21,368 With existing capacities, Chemtura and ICL IP (with a total global capacity of approximately 23,000 t) are already in a position to cover global demand of PolyFR for the whole estimated period. Furthermore, it should be noted that Albemarle has announced that additional 10,000 t will be available to the market as of 2015. Table 8: Global PolyFR demand / supply model BASF 2015 2016 2017 2018 2019 Global demand of PolyFR 17,565 18,534 19,327 20,316 21,368 Global supply of PolyFR: Available capacities 2nd half of 2014 23,000 23,000 23,000 23,000 23,000

Expected surplus 5,435 4,466 3,673 2,684 1,632 Global supply of PolyFR: Announced capacities as of 2nd half of 2015 33,000 33,000 33,000 33,000

Expected surplus 14,466 13,673 12,684 11,632

Alternative scenarios BASF has also compared this BASF global model (Table 7), which we can call case 0, with what happens if other regions move away from HBCD at different speeds:

• Case 1 explores a slow switch to PolyFR: • Japan and EMEA switch completely out of HBCD to PolyFR already in 2015 • Korea switch progressively out of HBCD (from 80% HBCD in 2015 to 50% in 2019) • Americas switch by 50% out of HBCD from 2015 to 2019 • China keeps using HBCD • In order to be conservative, in this scenario we assume only 75% of HBCD is substituted by

PolyFR, while other alternatives to HBCD are used for the other 25% (mainly in Asia and for XPS)

• Case 2 explores a fast switch to PolyFR:


13


• All regions but China switch completely out of HBCD in 2015 • China switches out of HBCD by 50% already in 2019 • All HBCD is substituted by PolyFR

The analysis shows that the results do not vary significantly between the two extremes (Graph 3, Table 9). Graph 3: BASF comparative analysis of global PolyFR demand

Note: Capacity prior to mid-2014 was 13,000 t. Existing capacity as of mid-2014 is 23,000 t. Announced capacity is estimated at 33,000 t based on announced capacity by ICL IP (3,000 t + 10,000 t), Chemtura (10,000 t) and Albemarle (10,000 t), as explained in Table 6. The graph above is highly conservative as it assumes no growth in capacity. Table 9: Comparative analysis of global PolyFR demand (t) 2013 2014 2015 2016 2017 2018 2019 EMEA Case 1 (slow) 1,488 6,696 13,794 13,614 13,518 13,496 14,374 EMEA Case 0 (current expectation)

1,488 6,696 13,794 14,414 15,207 16,196 17,248

EMEA Case 2 (fast)

1,488 7,440 15,326 16,016 16,897 17,995 19,165

Non-EMEA Case 1 (slow) 2,232 2,902 3,701 3,841 3,980 4,120 4,120 Non-EMEA Case 0 (current expectation)

2,232 2,902 3,771 4,120 4,120 4,120 4,120

Non-EMEA Case 2 (fast) 2,976 4,464 7,812 7,812 7,812 7,812 15,066 Total Case 1 (slow switch)

3,720 9,598 17,495 17,455 17,498 17,616 18,494

Total Case 0 (current expectation)

3,720 9,598 17,565 18,534 19,327 20,316 21,368

Total Case 2 (fast switch)

4,464 11,904 23,138 23,828 24,709 25,807 34,231

In conclusion, even with improbable assumptions regarding other regions implementing a HBCD ban in the short term, existing capacities are still more than enough to cover demand. The only case where further capacities additional to the already available in 2014 would be needed is if China decides to switch a significant share of its HBCD consumption to PolyFR. However, BASF does not expect a Chinese ban on HBCD to happen before 2019 and it is expected that it will grant a 5 year exemption to the use of HBCD.

Existing capacity (as of 2nd half 2014)

Announced capacity (as of 2015)

Existing capacity



Furthermore, should market demand of PolyFR increase beyond available capacity from 2017 onwards, the global supply of PolyFR can be reasonably expected to further increase beyond the projected 33,000 t in response to the market demand, as producers of PolyFR are able to adapt their capacities accordingly. If the Authorisation is not granted, the industry will receive a clear signal and the required confidence to invest in increasing its capacity and rate of transition. Finally, it should be noted that the European XPS industry (the largest consumer of HBCD in the EU in 2007 according to the applicants table 2.4 in Socio-economic analysis) is also confident about sufficient availability of alternatives to HBCD, as demonstrated by the absence of an application for Authorisation. Miscalculations in applicants’ model (see Appendix 3 for detailed explanation) BASF would like to point out that the HBCD Consortium’s estimation of PolyFR demand in Non-EU (Table 2.9 from the applicants’ Socio-economic analysis) seems to have been wrongly calculated, leading to extremely high demand figures, which cannot be reproduced when using the applicants’ demand model assumptions. Images from the applicants’ Socio-economic analysis:


15


In fact, when using the applicants’ assumptions and correctly calculating the resulting model, a small deficit of PolyFR in 2015 and a large surplus is expected in 2016, 2017 and 2018 (Table 10). Table 10: Estimated global demand and supply of PolyFR using the applicants’ assumptions and correctly calculating the resulting model (in t) 2015 2016 2017 2018 2019 Demand PolyFR EU 17,747 18,560 19,145 18,014 18,456 Demand PolyFR non-EU

6,524 6,524 6,466 6,176 13,087

Total Demand PolyFR

24,271 25,084 25,611 24,190 31,543

Total Supply PolyFR

23,350 29,850 31,350 31,350 31,350

Deficit/Surplus -921 4,766 5,739 7,160 -193 Example: Error in the calculation of PolyFR demand in 2015 in Non-EU in the applicants’ model: If, as stated in the applicant’s dossier: (From Table 2.6 of the Socio-economic analysis of the applicants):

• China decides not to switch out of HBCD between 2015 and 2018, • the Americas switch out of HBCD by 50% from 2015 to 2019 • Europe, Korea and Japan switch completely out of HBCD from 2015 to 2019;

and



(From Table 2.8 of the Socio-economic analysis of the applicants)

• we assume that there is no demand growth for EPS and XPS outside Europe

then the demand of HBCD alternative in Non-EU in 2015 would be equal to:

• the demand of HBCD in 2011 in Japan (2,480 t), • the demand of HBCD in 2011 in Korea (1,550 t), and • 50% of the demand in 2011 in Americas (2,480 t x 50% = 1,240 t),

then 5,270 t of HBCD would have to be replaced in Non-EU in 2015. To convert this demand into PolyFR demand, the conversion rate has to be used. (From Table 2.7 of the Socio-economic analysis of the applicants)

Thus,

• 80% of Non-EU sales of HBCD come from the EPS industry and 20% from XPS • Conversion rate of HBCD to PolyFR in EPS 1:1.3 and in XPS 1:1.1


17


• In 2015, 100% of the HBCD to be replaced in EPS will be substituted by PolyFR and 90% of the HBCD to be replaced in XPS will be substituted by PolyFR.

Therefore, the PolyFR demand in Non-EU in 2015 will be 5,270 x 80% x 1.3 x 100% + 5,270 x 20% x 1.1 x 90% = 6,524 t. Please note that the applicants incorrectly state that the demand of PolyFR in Non-EU in 2015 will be 13,091 t (Table 2.9 and Table 2.10 from the applicants’ Socio-economic analysis). As described above, this figure cannot be replicated by using the applicants’ model assumptions. When correcting this error, the claimed deficit of PolyFR in 2015 by the applicants of -7,489 t turns into a much smaller figure of – 921 t. For further details, please see Appendix 3. BASF disagreement with the assumptions in the applicants’ demand model Furthermore, BASF believes that there are a number of inconsistencies in the applicants’ model. Some of the assumptions used in the applicants’ model are not realistic, and lead thus to further overestimations. By correcting these unrealistic assumptions, it can be seen that a large surplus of PolyFR in 2015 should be expected. Firstly, the HBCDD Consortium suggests that the conversion rate between HBCD and PolyFR is 1.3 for EPS. Our own experience, as well as the recommendation from the PolyFR producers, shows that a substitution rate of 1.2 is the right figure. By correcting this assumption, the demand of PolyFR in Non-EU in 2015 is reduced by further 421t. Production data from BASF is attached in the confidential section to support this argument. Secondly, according to the presentation by Chemtura at the UNEP POPRC meeting in October 2013 (Great Lakes Solutions, 2013b), the proportion of demand of HBCD in the Europe, Middle East and Africa (EMEA) Region is 40% of global demand. This means that EMEA demand is thus 12,400 t (31,000 t x 40%). This figure is roughly 2,000 t lower than the 14,483 t used by the HBCDD Consortium which is an extrapolation of 2007 figures using a number of optimistic assumptions (for example, growth of demand of flame retardants in Europe despite economic crisis in 2009). Please note that EMEA (Europe, Middle East and Africa) includes large EPS markets such as Russia and Turkey that are not expected to ban the use of HBCD shortly. By correcting this assumption, the demand of PolyFR in Europe in 2015 is reduced by roughly 2,400 t (2,000 t x 1.2).



Great Lakes Solution slide:

The 12,400 t HBCD sales figure in EMEA used by BASF is validated by the industry VECAP programme which shows data on HBCD sales from 2008 until 2013 (reference: VECAP, 2014). Image from the VECAP report (European Annual Progress Report 2013):

Furthermore, both BASF and the applicants have used the favourable assumption for PolyFR that the complete switch in Europe in case of a refused Authorisation will happen already as of January 1s, when the


19


sunset date is set on August 21st, thus reducing even more the expected demand of PolyFR in Europe in 2015. Table 11: 2011 Global HBCD Demand Estimation of the Applicants and BASF Region GLOBAL HBCD DEMAND ESTIMATION OF THE

APPLICANTS (t) GLOBAL HBCD DEMAND ESTIMATION

OF BASF (t) 2011 2011 EMEA 14,483 12,400 Japan 2,480 2,480 Americas 2,480 2,480 PRC 12,090 12,090 Korea 1,550 1,550 TOTAL 33,083 31,000 Thirdly, it should be noted here that in its application, the HBCDD Consortium claims that South Korea is expected to fully switch away from HBCD by 2015 (Socio-economic analysis, p. 27) based on a comment made by BASF at UNEP POPRC9. The Consortium claims that this is because “it is assumed that [BASF] represent a large proportion of HBCDD demand for South Korea”. In fact, the BASF market share for flame retardant EPS for building and construction applications in 2013 in South Korea was 11%. Therefore, a decision by BASF to switch to PolyFR will hardly make an impact on the Korean market. Furthermore, BASF ongoing contacts with Korean authorities confirm that they do not have the intention to phase out HBCD before 2019. By assuming that Korea will not switch out of HBCD in 2015, the demand of PolyFR in 2015 is reduced by 1,919 t. Thus, by correcting these three unrealistic assumptions, the global demand of PolyFR in 2015 is reduced by 4,740 t (421 t + 2,400 t + 1,919 t). Therefore, even assuming that the complete switch out of HBCD in Europe will happen as of January 1st 2015, a large surplus of PolyFR in 2015 should be expected. Finally, China is expected to allow the use of HBCD beyond 2018. Therefore, a 50% switch in 2019 is considered highly improbable.

6. CONCLUSION ON SUITABILITY AND AVAILABILITY OF THE ALTERNATIVE

Adhering to the principle of responsible care, the industry has succeeded in developing the polymeric flame retardant (PolyFR) as a safe, sustainable and economically viable alternative to HBCD which ensures the possibility of a smooth substitution within the REACH mandated timeframe. Science and authorities worldwide endorse the superior environmental profile and the fire safety properties of PolyFR. Concerted efforts of the entire value chain (from licensee Dow to thermal insulation providers) have led to the successful and timely completion of a more than ten year long development process. As a result, the European industry is already in a position to completely switch its flame retardant polystyrene foam portfolio to PolyFR. As this submission shows, the availability of PolyFR is sufficient to fulfil European and global demand. Furthermore, a seamless market introduction of EPS with PolyFR is already well underway. For this reason, BASF believes that a complete substitution of HBCD by mid of 2015 is only a matter of will and should be actively encouraged. BASF is convinced that a rapid substitution of HBCD in EPS would avoid negative effects on the EPS industry and society as a whole. It is evident by the data presented in this document that an Authorisation is unnecessary given that the EPS industry is already in the process of switching to PolyFR, can complete the process successfully by the sunset date of August 2015 and enough quantities of the alternative are available to cover the EU and global market demand. In fact, BASF is convinced that granting an Authorisation would have a negative impact on the environmental footprint, image and long term profitability of the European EPS industry. A decision to refuse an Authorisation for HBCD, and thus the confirmation of the legal requirement to complete the substitution process by August 2015, would prevent penalising the first movers in the industry.



Those actors, for example the developer of PolyFR, the producers of PolyFR and the producers of EPS who have not applied for an Authorisation, have invested heavily in complying with the initial requirements of REACH in a timely way and have succeeded both in supplying the European market with enough quantities to cover its needs and in successfully introducing EPS with PolyFR in the European market. In addition, it would avoid additional complexity in terms of labelling and recycling impediments along the value chain (please refer to section 7). Last but not least, it would safeguard the image of EPS as a safe and sustainable material and would therefore minimise the potential risk of reducing overall demand for the European insulation industry, which is key to achieve the targets of the European Union to reduce energy consumption and greenhouse gas emissions.

7. OTHER COMMENTS

Additional challenges for the industry if an Authorisation is granted If an Authorisation under REACH were to be granted for HBCD a number of unnecessary costs and challenges would arise for the entire European EPS industry. These are linked to the implementation of the listing of HBCD as a POP under the Stockholm Convention. We understand that this would be implemented in the EU as of August 2015 (reference: RoHS Annex Dossier for HBCD: Umweltbundesamt, 2013). Labelling For an Authorisation to comply with the POP listing, EPS with HBCD would only be allowed in Europe for use in buildings and under the strict requirement that HBCD can be easily identified by labelling or other means throughout its lifecycle. In addition to the technical difficulties, the identification requirement entails high costs for the industry and would contribute to creating a negative perception of EPS in the final market. Recycling Furthermore, as soon as the POP listing is implemented into EU law, recycling of EPS with HBCD will no longer be permitted, regardless of whether the Authorisation is granted. Having EPS boards with HBCD on the market at this time will create further challenges for the industry by unnecessarily increasing the end of life cost of EPS boards and damaging the EPS sustainability profile. Such a problem will only arise during the Authorisation period, given that the implementation of the POP listing is aligned with the sunset date of August 2015. Before the implementation of the POP listing by the EU, the recycling of EPS containing HBCD is allowed. In addition, during an Authorisation period there would be severe problems to the recycling loop of EPS packaging. This is because when EPS boards are installed in buildings they are cut into smaller pieces to fit to the dimensions of the building. The cut-offs that do not make it to the building are usually then given to local collection stations the main function of which is to collect used EPS packaging. However, if part of these cut-offs contains HBCD, the whole collection may be contaminated to such an extent that recycling will no longer be possible for EPS. While we are aware that this depends on the low POP content and the Technical Guidelines for the Environmentally Sound Management of HBCD waste that are currently under development by the Basel Convention, we may expect a situation whereby the regular recycling of EPS packaging will no longer be possible due to the high contamination risk from EPS boards with HBCD. As a result, the EPS packaging industry could fall victim to the Authorisation of HBCD, even though they do not use this material at all. In order to avoid contamination, EPS boards containing HBCD would have to be kept separate throughout the value chain to avoid the possibility of contamination, leading to high handling costs for the industry. Without an Authorisation, there will be no risk to packaging recycling as EPS with HBCD will not be present at construction sites after August 2015, therefore there will be no need for costly labelling or separation.


21


REFERENCES

• Albemarle Press Release (2013) ‘Albemarle samples its new GreenCrest polymeric flame retardant product to consumers’. 21 October 2013. Available at: http://finance.yahoo.com/news/albemarle-samples-greencrest-polymeric-flame-200400682.html

• FIW & IVH presentation ‘Research project: EPS-Insulating Material Exchange of Flame Retardant’

FIW project comparison HBCD and

• BASF Press Release (2011) ‘BASF supports new polymeric flame retardant’ 5 April 2011. Available at: http://www.basf.com/group/corporate/en/function/conversions:/publish/content/news-and-med

• BASF Press Release (2014) ‘First Styrodur® plant completely switched to new flame retardant’ 19 May 2014. Available at: http://www.basf.com/group/pressrelease/P-14-240

• Dow Press Release (2011) ‘Dow announces development of a new polymeric flame retardant technology for polystyrene foam building insulation products’ (29 March 2011). Available at: http://www.dow.com/licensing/news/2011/20110329a.htm

• Dow Press Release (2013) ‘Dow Chemical licenses polymeric flame retardant technology’. Plastics News. 22 July 2013. Available at: http://www.plasticsnews.com/article/20130722/NEWS/130729992/dow-chemical-licenses-polymeric-flame-retardant-technology#

• Great Lakes Solutions (2013a) ‘Great Lakes Solutions sees continued success with new flame retardant technology’ 22 April 2013. Available at: http://news.greatlakes.com/press-release/great-lakes-solutions-sees-continued-success-new-flame-retardant-technology

• Great Lakes Solutions (2013b) ‘Polymeric flame retardant for polystyrene foams’. Presentation at UNEP POPRC9 side event 14 October 2013. Available at: http://chm.pops.int/Implementation/TechnicalAssistance/Webinars/tabid/1529/Default.aspx?overlayId=ArtId-11407

• Group of Notified Bodies for the Construction Products Directive (2012) ‘SG-19 Guidance from the Group of Notified Bodies for the Construction Products Directive: Questions and Answers for EN 13162 through EN 13171, EN 14064-1, and EN 1403 through EN 14314’

Sector Group 19 - Questions and answer

• Heraldo.es (2009) ‘Cierra la planta química de Polidux en Monzón’. 28 September 2009. Available at: http://www.heraldo.es/noticias/economia/2013/09/27/cierra_planta_quimica_polidux_monzon_250837_309.html

• ICL IP Press Release (2013) ‘ICL IP accelerates commercial availability of sustainable polymeric flame retardant’. 5 March 2013. Available at: http://www.prnewswire.com/news-releases/icl-ip-accelerates-commercial-availability-of-sustainable-polymeric-flame-retardant-195210461.html

• ICL IP Press Release (2014) ‘ICL IP completing second production facility for polymeric flame retardant’. 22 April 2014. Available at: http://www.prnewswire.co.uk/news-releases/icl-ip-completing-second-production-facility-for-polymeric-flame-retardant-256176891.html

• INEOS Press Release (2013) ‘INEOS Styrenics is to close Expandable Polystyrene plant at its Marl facility at the end of 2013’. 10 June 2013. Available at: http://www.ineos.com/news/shared-news/ineos-styrenics-is-to-close-expandable-polystyrene-plant-at-its-marl-facility-at-the-end-of-2013/

• Synthos (2013) ‘Transitioning from HBCD to Alternative FR for PS Building and Construction Products’ Presentation at UNEP POPRC9 side event. 14 October 2013. Available at: http://chm.pops.int/Implementation/TechnicalAssistance/Webinars/tabid/1529/Default.aspx?overlayId=ArtId-11407

• UNEP (2012) ‘Report of the Persistent Organic Pollutants Review Committee on the work of its eighth meeting: Addendum to the risk management evaluation on hexabromocyclododecane’. Geneva, United Nations Environment Programme.

• US EPA (2014) ‘Flame Retardant Alternatives for Hexabromocyclododecane (HBCD). Final Report’. Design for the Environment. Available at: http://www.epa.gov/dfe/pubs/projects/hbcd/about.htm




http://www.basf.com/group/corporate/en/function/conversions:/publish/content/news-and-med

http://www.basf.com/group/pressrelease/P-14-240

http://www.dow.com/licensing/news/2011/20110329a.htm

http://www.plasticsnews.com/article/20130722/NEWS/130729992/dow-chemical-licenses-polymeric-flame-retardant-technology

http://www.plasticsnews.com/article/20130722/NEWS/130729992/dow-chemical-licenses-polymeric-flame-retardant-technology



http://chm.pops.int/Implementation/TechnicalAssistance/Webinars/tabid/1529/Default.aspx?overlayId=ArtId-11407


http://www.heraldo.es/noticias/economia/2013/09/27/cierra_planta_quimica_polidux_monzon_250837_309.html

http://www.heraldo.es/noticias/economia/2013/09/27/cierra_planta_quimica_polidux_monzon_250837_309.html





http://www.ineos.com/news/shared-news/ineos-styrenics-is-to-close-expandable-polystyrene-plant-at-its-marl-facility-at-the-end-of-2013/

http://www.ineos.com/news/shared-news/ineos-styrenics-is-to-close-expandable-polystyrene-plant-at-its-marl-facility-at-the-end-of-2013/



http://www.epa.gov/dfe/pubs/projects/hbcd/about.htm


• Umweltbundesamt (2013) ‘ROHS Annex II Dossier for HBCDD, Restriction proposal for hazardous substance in electrical and electronic equipment regulated under RoHS’. Available at: http://www.umweltbundesamt.at/fileadmin/site/umweltthemen/abfall/ROHS/HBCDD_ROHS_Dossier_10_13.pdf

• VECAP (2014) ‘Sound results from a proactive industry: European Annual Progress Report 2013’. Available at: http://www.vecap.info/uploads/VECAP%20report%202013.pdf


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http://www.umweltbundesamt.at/fileadmin/site/umweltthemen/abfall/ROHS/HBCDD_ROHS_Dossier_10_13.pdf



http://www.vecap.info/uploads/VECAP%20report%202013.pdf


APPENDIXES

Appendix 1 – Explanation of model to estimate loss resulting from a granted Authorisation

Assumptions: • Discount rate: 4% (as advised by ECHA) • Flame retardant EPS demand in the construction sector in 2007: 860,000 t (figure mentioned on

page 32 of the applicants’ SEAC) • Growth rate of flame retardant EPS demand after 2007: 0% (conservative assumption, especially

after 2015) • EPS price: 1,500 €/t (assumption based on current market conditions) • Price increase over time: 0% (conservative assumption) • EPS value added: 12.5 % (midpoint of assumed values of industry low point of 10% and high point of

15%) • Value added per tonne of flame retardant EPS transformed by converters: 135 €/t (figure mentioned

on page 102 of the applicants’ SEAC)

Case 1: Loss of 5% of EPS sales in case of a granted Authorisation, due to damage to reputation of EPS in the final insulation materials market

2015 2016 2017 2018 2019 2020 2021 2022 2023 2024 Loss of sales to EPS producers (t) 43,000 43,000 43,000 43,000 43,000 43,000 43,000 43,000 43,000 43,000

Loss of sales value to EPS producers (1,000 €)

64,500 64,500 64,500 64,500 64,500 64,500 64,500 64,500 64,500 64,500

NPV loss of sales value to EPS producers (1,000 €)

62,019 59,634 57,340 55,135 53,014 50,975 49,015 47,130 45,317 43,574

Loss of sales value added to EPS producers (1,000 €)

8,063 8,063 8,063 8,063 8,063 8,063 8,063 8,063 8,063 8,063

NPV loss of sales value added to EPS producers (1,000 €)

7,752 7,454 7,168 6,892 6,627 6,372 6,127 5,891 5,665 5,447

Loss of sales value added to EPS converters (1,000 €)

5,805 5,805 5,805 5,805 5,805 5,805 5,805 5,805 5,805 5,805

NPV loss of sales value added to EPS converters (1,000 €)

5,582 5,367 5,161 4,962 4,771 4,588 4,411 4,242 4,079 3,922

Total NPV loss of sales value added for use 1 + 2 (1,000 €)

13,334 12,821 12,328 11,854 11,398 10,960 10,538 10,133 9,743 9,368



64,500 64,500 64,500 64,500 64,500 64,500 64,500 64,500 64,500 64,500


41,898 40,287 38,737 37,247 35,815 34,437 33,113 31,839 30,614 29,437


8,063 8,063 8,063 8,063 8,063 8,063 8,063 8,063 8,063 8,063


5,237 5,036 4,842 4,656 4,477 4,305 4,139 3,980 3,827 3,680


5,805 5,805 5,805 5,805 5,805 5,805 5,805 5,805 5,805 5,805


3,771 3,626 3,486 3,352 3,223 3,099 2,980 2,866 2,755 2,649


9,008 8,662 8,328 8,008 7,700 7,404 7,119 6,845 6,582 6,329






129,000 129,000 129,000 129,000 129,000 129,000 129,000 129,000 129,000 129,000


124,038 119,268 114,681 110,270 106,029 101,951 98,029 94,259 90,634 87,148


16,125 16,125 16,125 16,125 16,125 16,125 16,125 16,125 16,125 16,125


15,505 14,908 14,335 13,784 13,254 12,744 12,254 11,782 11,329 10,893


11,610 11,610 11,610 11,610 11,610 11,610 11,610 11,610 11,610 11,610


11,163 10,734 10,321 9,924 9,543 9,176 8,823 8,483 8,157 7,843


26,668 25,643 24,656 23,708 22,796 21,919 21,076 20,266 19,486 18,737



129,000 129,000 129,000 129,000 129,000 129,000 129,000 129,000 129,000 129,000


83,796 80,573 77,474 74,494 71,629 68,874 66,225 63,678 61,229 58,874


16,125 16,125 16,125 16,125 16,125 16,125 16,125 16,125 16,125 16,125


10,474 10,072 9,684 9,312 8,954 8,609 8,278 7,960 7,654 7,359


11,610 11,610 11,610 11,610 11,610 11,610 11,610 11,610 11,610 11,610


7,542 7,252 6,973 6,704 6,447 6,199 5,960 5,731 5,511 5,299


18,016 17,323 16,657 16,016 15,400 14,808 14,238 13,691 13,164 12,658


25





193,500 193,500 193,500 193,500 193,500 193,500 193,500 193,500 193,500 193,500


186,058 178,902 172,021 165,405 159,043 152,926 147,044 141,389 135,951 130,722


24,188 24,188 24,188 24,188 24,188 24,188 24,188 24,188 24,188 24,188


23,257 22,363 21,503 20,676 19,880 19,116 18,381 17,674 16,994 16,340


17,415 17,415 17,415 17,415 17,415 17,415 17,415 17,415 17,415 17,415


16,745 16,101 15,482 14,886 14,314 13,763 13,234 12,725 12,236 11,765


40,002 38,464 36,984 35,562 34,194 32,879 31,614 30,399 29,229 28,105



193,500 193,500 193,500 193,500 193,500 193,500 193,500 193,500 193,500 193,500


125,694 120,860 116,211 111,741 107,444 103,311 99,338 95,517 91,843 88,311


24,188 24,188 24,188 24,188 24,188 24,188 24,188 24,188 24,188 24,188


15,712 15,107 14,526 13,968 13,430 12,914 12,417 11,940 11,480 11,039


17,415 17,415 17,415 17,415 17,415 17,415 17,415 17,415 17,415 17,415


11,312 10,877 10,459 10,057 9,670 9,298 8,940 8,597 8,266 7,948


27,024 25,985 24,985 24,024 23,100 22,212 21,358 20,536 19,746 18,987



Appendix 2– Explanation of the BASF global PolyFR demand model

1. Estimate global demand of HBCD in 2011 (reference: Great Lakes, 2013b; VECAP, 2014)

Global Demand for HBCD in 2011 (t) EMEA 12,400 Japan 2,480 Americas 2,480 PRC 12,090 Korea 1,550 TOTAL 31,000 2. Estimate the demand growth of flame retardants per region from 2011 to 2019 FR Demand Growth (%) 2011 2012 2013 2014 2015 2016 2017 2018 2019 EMEA 0.0% 0.0% 0.0% 0.0% 3.0% 4.5% 5.5% 6.5% 6.5% Japan 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% Americas 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% PRC 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% Korea 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Note: BASF has used the same assumptions on flame retardant demand growth as the applicants in order to make comparison easy for the reader. However, we want to note that in reality growth rates for the EPS industry in Europe in 2012 and 2013 were negative. Furthermore, European growth rates in this model after 2015 are quite optimistic 3. Calculation of global FR demand 2011 to 2019 on the basis of HBCD demand (1) and flame retardant demand growth (2) FR Demand on basis HBCD (tonnes) 2011 2012 2013 2014 2015 2016 2017 2018 2019 EMEA 12,400 12,400 12,400 12,400 12,772 13,347 14,081 14,996 15,971 Japan 2,480 2,480 2,480 2,480 2,480 2,480 2,480 2,480 2,480 Americas 2,480 2,480 2,480 2,480 2,480 2,480 2,480 2,480 2,480 PRC 12,090 12,090 12,090 12,090 12,090 12,090 12,090 12,090 12,090 Korea 1,550 1,550 1,550 1,550 1,550 1,550 1,550 1,550 1,550 TOTAL 31,000 31,000 31,000 31,000 31,372 31,947 32,681 33,596 34,571 4. Estimation of the proportion of regions to remain with HBCD, based on expected POP listing implementation Regions to remain with HBCD (%) 2011 2012 2013 2014 2015 2016 2017 2018 2019 EMEA 100% 100% 90% 50% 0% 0% 0% 0% 0% Japan 100% 100% 0% 0% 0% 0% 0% 0% 0% Americas 100% 100% 100% 75% 50% 50% 50% 50% 50% PRC 100% 100% 100% 100% 100% 100% 100% 100% 100% Korea 100% 100% 100% 100% 75% 50% 50% 50% 50%


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Note: According to BASF Korean colleagues, Korea is not expected to ban HBCD before 2019. Nevertheless, we have used an optimistic assumption in favour of PolyFR by assuming a progressive switch out of HBCD in Korea between 2015 and 2019.

5. Calculation of the global HBCD demand by region from 2011 to 2019 (using 3 and 4)

HBCD Demand (tonnes) 2011 2012 2013 2014 2015 2016 2017 2018 2019 EMEA 12,400 12,400 11,160 6,200 0 0 0 0 0 Japan 2,480 2,480 0 0 0 0 0 0 0 Americas 2,480 2,480 2,480 1,860 1,240 1,240 1,240 1,240 1,240 PRC 12,090 12,090 12,090 12,090 12,090 12,090 12,090 12,090 12,090 Korea 1,550 1,550 1,550 1,550 1,163 775 775 775 775 TOTAL 31,000 31,000 27,280 21,700 14,493 14,105 14,105 14,105 14,105

6. Calculation of the global demand for alternative flame retardants from 2011 to 2019 (using 3 and 5) Demand of alternative FR (tonnes) 2011 2012 2013 2014 2015 2016 2017 2018 2019 EMEA 0 0 1,240 6,200 12,772 13,347 14,081 14,996 15,971 Japan 0 0 2,480 2,480 2,480 2,480 2,480 2,480 2,480 Americas 0 0 0 620 1,240 1,240 1,240 1,240 1,240 PRC 0 0 0 0 0 0 0 0 0 Korea 0 0 0 0 388 775 775 775 775 TOTAL 0 0 3,720 9,300 16,880 17,842 18,576 19,491 20,466 7. Estimation of how much of the alternative flame retardant will be PolyFR PolyFR (%) 2011 2012 2013 2014 2015 2016 2017 2018 2019 EMEA 0% 0% 100% 90% 90% 90% 90% 90% 90% Japan 0% 0% 75% 75% 75% 75% 75% 75% 75% Americas 0% 0% 100% 90% 80% 80% 80% 80% 80% PRC 0% 0% 0% 0% 0% 0% 0% 0% 0% Korea 0% 0% 75% 75% 75% 75% 75% 75% 75% Note: Alternatives to HBCD that are not PolyFR (as mentioned in the US EPA report on alternatives to HBCD from 2014) are already being used by the XPS industry and in Japan.

8. Global demand for PolyFR from 2011 to 2019 calculated using 6 and 7 and a conversion rate of HBCD to PolyFR of 1:1.2

Demand PolyFR (tonnes; conversion rate HBCD to PolyFR 1:1.2) 2011 2012 2013 2014 2015 2016 2017 2018 2019 EMEA 0 0 1,488 6,696 13,794 14,414 15,207 16,196 17,248 Japan 0 0 2,232 2,232 2,232 2,232 2,232 2,232 2,232 Americas 0 0 0 670 1,190 1,190 1,190 1,190 1,190 PRC 0 0 0 0 0 0 0 0 0 Korea 0 0 0 0 349 698 698 698 698 TOTAL 0 0 3,720 9,598 17,565 18,534 19,327 20,316 21,368



Appendix 3 – Explanation on the incorrect demand calculations on the applicants’ Socio-economic Analysis (as laid out in p. 25-31) The applicants’ SEAC wrongly calculates the Non-EU demand of HBCD and PolyFR even when using their own assumptions.

In table 2.5 they summarize the demand of HBCD in 2011 in all regions.

From this table we can calculate that the HBCD demand in Non-EU (Japan, Americas, China, Korea) in 2011 was 18,600 tonnes. Of this total amount, 12,090 tonnes were demanded in China and 6,510 tonnes in all the other Non-EU regions. Then the applicants estimate which regions will continue using HBCD, summarising their assumptions in table 2.6. By their own assumptions, China will continue using HBCD until 2019 and the Americas will remain with HBCD for 50% of their demand.


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From this table it is follows that, assuming no demand growth of FR in Non-EU (as stated in Table 2.8), in 2015 the non-EU demand for an HBCD alternative must meet the equivalent of HBCD demand for:

• 100% Japan, • 50% Americas, • 0% China, and • 100% Korea

i.e. in 2015 there will be a need to replace 5,270 tonnes of HBCD. Given the conversion rate of HBCD to PolyFR and the availability of different alternatives to HBCD other than PolyFR, it is evident that the 13,091 t of estimated Non-EU demand of PolyFR in 2015 mentioned in Table 2.9 of the applicants’ Socio-economic analysis has been wrongly calculated. In order to estimate the demand of flame retardant in the future, and therefore be able to estimate the demand of PolyFR from 2015 to 2019, the applicants estimate the annual growth in demand for EPS and XPS in Non-EU regions (the model assumes no growth of demand for EPS and XPS) (see table 2.8).

Finally, the applicants estimate how much of the HBCD alternative will be switched to PolyFR in every region for EPS and XPS. For Non-EU regions it is assumed that 80% of FR demand is for EPS and 20% for XPS (see table 2.7).



Note 2 for table 2.7 gives the explanation on how the figures of demand of Non-EU have been calculated. “Non-EU figures are calculated as follows: The starting point is that 43% of global demand for FRs will be met by HBCD (and therefore up to 57% will be met by the pFR) in 2015-2018 (See Table 2.6) and this proportion will fall to only 18% in 2019”.

The mistake the applicants make is applying the global share of HBCD in 2015 (43%) to calculate Non-EU demand of HBCD:

The 43% of table 2.6 is the total proportion of global demand for HBCD and includes the EU, which is expected to switch completely out of HBCD. Therefore, it is wrong to use this figure to calculate the demand for HBCD in Non-EU, which should only have considered the Non-EU regions that are expected to switch out of HBCD.

The share of HBCD of Non-EU demand for flame retardants from 2015-2018, using the applicants own assumptions, is 72% while the share of Non-EU demand for alternative flame retardants from 2015-2018 is 28% (half of what the applicants used).


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The correct way to calculate the Non-EU PolyFR demand figures based on the assumptions of the model of the applicants would have been as follows:

1. Calculate the demand of flame retardant on the basis of HBCD in Non-EU regions

Demand of FR Non-EU (tonnes)

2011 2012 2013 2014 2015 2016 2017 2018 2019

Japan 2,480 2,480 2,480 2,480 2,480 2,480 2,480 2,480 2,480

Americas 2,480 2,480 2,480 2,480 2,480 2,480 2,480 2,480 2,480

PRC 12,090 12,090 12,090 12,090 12,090 12,090 12,090 12,090 12,090

Korea 1,550 1,550 1,550 1,550 1,550 1,550 1,550 1,550 1,550

Total Non-EU 18,600 18,600 18,600 18,600 18,600 18,600 18,600 18,600 18,600

(Demand growth rate in Non-EU: 0 as described in Table 2.8)

2. Estimate the proportion of Non-EU regions likely to continue using HBCD

Proportion of regions likely to continue using HBCD (%) 2011 2012 2013 2014 2015 2016 2017 2018 2019 Japan 0% 0% 0% 0% 0% Americas 50% 50% 50% 50% 50% PRC 100% 100% 100% 100% 50% Korea 0% 0% 0% 0% 0%

3. Calculate the resulting HBCD demand in Non-EU regions HBCD Demand (tonnes) 2011 2012 2013 2014 2015 2016 2017 2018 2019 Japan 0 0 0 0 0 Americas 1,240 1,240 1,240 1,240 1,240 PRC 12,090 12,090 12,090 12,090 6,045 Korea 0 0 0 0 0 Total Non-EU 13,330 13,330 13,330 13,330 7,285

4. Calculate the demand of alternative flame retardants in Non-EU regions Alternative FR Demand on basis HBCD (tonnes) 2011 2012 2013 2014 2015 2016 2017 2018 2019 Japan 2,480 2,480 2,480 2,480 2,480 Americas 1,240 1,240 1,240 1,240 1,240 PRC 0 0 0 0 6,045 Korea 1,550 1,550 1,550 1,550 1,550 Total Non-EU 5,270 5,270 5,270 5,270 11,315

The proportion of alternative flame retardant demand for Non-EU is thus 28% (5,270 / 18,600) and not 57% as wrongly concluded in the Applicants’ Socio-Economic Analysis.

5. The final step is to translate from HBCD demand in Non-EU regions to PolyFR demand. The applicants assume that 80% of the demand comes from EPS, where a conversion ratio of 1:1.3 is



considered and 20% of the demand comes from XPS, where a conversion ratio of 1:1.1 is considered. Furthermore, the applicants’ assumption is that 100% of HBCD will be replaced by PolyFR in the EPS industry. In the XPS industry the replacement rate of HBCD by PolyFR varies from 90% in 2015 to 53% in 2019 (Table 2.7 of the applicants Socio-economic analysis)

On this basis, demand for PolyFR in Non-EU is calculated as follows:

PolyFR (tonnes; assumption: 80% of EPS with a conversion ratio HBCD/PolyFR of 1:1.3 and 20% XPS at 1:1.1)

2011 2012 2013 2014 2015 2016 2017 2018 2019 Japan

3,070

3,070

3,043

2,907

2,868 Americas

1,535

1,535

1,521

1,453

1,434 PRC

- -

-

-

6,992

Korea 1,919

1,919

1,902

1,817

1,793

Non-EU 6,524

6,524

6,466

6,176

13,087

Using all assumptions of the applicants’ model and calculating the model correctly, the results would be the following: 2015 2016 2017 2018 2019 Demand PolyFR EU 17,747 18,560 19,145 18,014 18,456 Demand PolyFR non-EU

6,524 6,524 6,466 6,176 13,087

Total Demand PolyFR

24,271 25,084 25,611 24,190 31,543

Total Supply PolyFR

23,350 29,850 31,350 31,350 31,350

Deficit/Surplus -921 4,766 5,739 7,160 -193

However, BASF notes that there are a number of assumptions in this model that are not correct and lead to overestimations, for example:

- The European demand of HBCD in 2011 has been largely overestimated (by roughly 2,000 t, as shown by the Chemtura presentation at POPRC (reference: Great Lakes Solutions, 2013b; VECAP, 2014) and leads to inflated PolyFR demand figures for EU from 2015 to 2019

- The conversion ratio for EPS of HBCD to PolyFR of 1:1.3 is too high. To achieve the same bromine content, a maximum of 1:1.2 is required

- Korea is not expected to ban HBCD before 2019 - China is expected to allow the use of HBCD in 2019 and possibly beyond that date

BASF has included in this submission a demand model which corrects these four elements.

Taking these facts into account and given the results of the rightly calculated model of the applicants’ socio-economic analysis, it is obvious that concerns regarding the availability of PolyFR are unfounded.

Since the socio-economic analysis bases its estimation of the costs of a refused Authorisation on reduced production levels due to lack of alternative product (PolyFR), an assumptions which is demonstrated to be unfounded, it is to be concluded that a refused Authorisation would actually result in no economic or societal costs and would have significant environmental benefits.


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Research Project: EPS-Insulating Material

Exchange of Flame Retardant IVH and Plastics Europe

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Framework conditions for representative results: •Respectively old and new raw material (identical supplier & type) will be compared •Historical results can not be compared due to lack of raw material‘s traceability •No recycled material allowed •No preparation for dynamic stiffness •Boards from identical block positions •Drying of the boards at 60°C for one week •Anonymisation of the test results

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PRESUPPOSITIONS:

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REFERENCE GRAPH THERMAL CONDUCTIVITY EPS GREY MANUFACTURER 1:

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REFERENCE GRAPH THERMAL CONDUCTIVITY EPS GREY MANUFACTURER 1, 2, 3 AND 4:

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REFERENCE GRAPH COMPRESSIVE STRESS EPS GREY MANUFACTURER 1:

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REFERENCE GRAPH COMPRESSIVE STRESS EPS GREY MANUFACTURER 1, 2, 3 AND 4:

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RESULTS ADDITIONAL TESTS EPS GREY:

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Test Bending Strength

Tensile Strength

Dimensional Stability

Unit kPa D kg/m³

kPa D kg/m³

L % B % D % D kg/m³

Manufacturer 1 Raw Material A

old 125 14,5 136 14,1 -0,1 -0,1 -0,1 14,8

new 120 14,1 138 14,1 -0,1 -0,1 -0,1 14,2


old 110 14,0 130 13,7 0,0 0,0 0,0 14,2

new 105 14,1 122 14,0 -0,1 -0,1 -0,2 14,3

Manufacturer 3 Raw Material B

old 126 13,9 152 13,8 0,0 0,0 0,0 14,2

new 108 13,7 125 13,6 -0,1 -0,1 -0,1 13,8


old 127 13,8 156 13,8 0,0 0,0 0,0 13,9

new 118 13,9 142 14,0 0,0 0,0 0,0 13,9

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RESULTS ADDITIONAL TESTS EPS GREY:

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Test Deformation DLT 1 Deformation DLT 2

Unit % D kg/m³

% D kg/m³


old -2,9 19,6 -1,9 25,7

new -2,1 19,5 -1,7 25,8


old -4,5 18,2 -3,0 24,8

new -5,9 18,6 -4,3 24,6


old -3,7 19,6 -1,6 26,0

new -2,4 19,8 -1,0 27,7


old -2,1 19,6 -1,0 25,9

new -2,3 19,7 -1,8 25,7

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CLASS E TEST RESULTS EPS GREY :

Density 14 kg/m³ Maximum flame

height cm


height cm

Manufacturer 1 Raw material A

4

10

Manufacturer 2 Raw material A

4

10

Manufacturer 3 Raw material B

6

12

Manufacturer 4 Raw material B

10

11

Maximum allowable flame height is 15 cm.

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REFERENCE GRAPHS THERMAL CONDUCTIVITY EPS WHITE MANUFACTURER 6:

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REFERENCE GRAPHS THERMAL CONDUCTIVITY EPS WHITE MANUFACTURER 6, 7, 8 AND 9:

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REFERENCE GRAPHS COMPRESSIVE STRESS EPS WHITE MANUFACTURER 6:

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REFERENCE GRAPHS COMPRESSION EPS WHITE MANUFACTURER 9:

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REFERENCE GRAPHS COMPRESSIVE STRESS EPS WHITE MANUFACTURER 6, 7, 8 AND 9:

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RESULTS ADDITIONAL TESTS EPS WHITE:

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Tensile Strength

Dimensional Stability

Unit kPa D kg/m³

kPa D kg/m³

L % B % D % D kg/m³

Manufacturer 6 Raw Material D

old 85 10,9 135 14,1 -0,1 -0,1 -0,1 14,4

new 104 12,0 139 14,5 -0,1 -0,1 -0,1 14,6


old 91 10,9 144 13,6 -0,1 -0,1 -0,1 13,5

new 89 11,2 165 14,3 -0,1 -0,1 -0,1 14,2

Manufacturer 8 Raw Material E

old 69 12,3 145 14,6 -0,1 -0,1 -0,1 14,4

new 64 11,6 181 15,9 -0,1 -0,1 -0,1 15,3

Manufacturer 9 Raw Material F

old 61 11,1 133 13,7 -0,1 -0,1 -0,1 13,6

new 101 11,7 190 13,7 -0,1 -0,2 -0,1 13,5

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Test Deformation DLT 1 Deformation DLT 2

Unit % D kg/m³

% D kg/m³


old -6,4 19,9 -1,8 26,5

new -3,1 19,8 -1,9 26,1


old -2,7 18,3 -1,5 23,9

new -2,8 19,3 -1,0 25,6


old -2,2 19,3 -1,0 25,5

new -1,3 19,1 -0,7 26,6


old -1,5 19,1 -0,8 24,7

new -0,8 18,6 -0,6 23,8

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Test Dynamic Stiffness Compressibility

Unit MN/m³ D kg/m³

mm D kg/m³


old 27,6 11,0 2,9 11,2

new 33 12,0 2,7 11,6


old 21 11,1 3,4 11,0

new 14 11,2 3,7 11,2


old 8 11,6 4,1 12,2

new 8 12,0 4,5 12,3


old 12 11,0 4,1 11,2

new 15 11,5 3,0 11,7

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CLASS E TEST RESULTS EPS WHITE:


height cm


height cm

Manufacturer 6 Raw material D 5 10

Manufacturer 7 Raw material D 7 10

Manufacturer 8 Raw material E 9 11

Manufacturer 9 Raw material F 4 15


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TEST RESULTS MECHANICAL AND THERMAL PROPERTIES EPS PERIMETER WHITE:


Compression Stress

Thermal Conductivity

Unit

kPa D

kg/m³

60 mm 200 mm 60 mm 200 mm kPa

D

kg/m³ kPa D

kg/m³ λ10°C dry

D kg/m³

λ10°C wet

λ10°C dry

D kg/m³

Manufacturer 11 Raw Material H

old 276 28,0 200 26,9 205 27,5 0,0330 27,0 0,0338 0,0337 27,5

new 323 28,4 198 27,6 195 27,4 0,0331 27,3 0,0384 0,0335 27,7

Manufacturer 12 Raw Material I

old 283 28,2 169 26,8 187 27,9 0,0329 27,2 0,0370 0,0323 28,0

new 387 28,4 189 27,4 196 28,2 0,0325 27,9 0,0326 28,6


old 301 28,2 169 26,5 186 27,8 0,0324 26,9 0,0327 27,8

new 292 28,3 186 28,1 192 28,4 0,0325 27,9 0,0326 28,3


old 326 28,7 201 28,0 202 28,1 0,0332 29,0 0,0424 0,0332 28,6

new 299 26,8 168 26,0 183 26,7 0,0337 25,8 0,0337 27,0

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TEST RESULTS WATER ABSORPTION EPS PERIMETER WHITE:

Test Total Immersion Diffusion Freeze Thaw Resistance

Unit

60 mm 200 mm

Vol.-% D

kg/m³

Water Absorption

Compression stress

after freeze thaw

Vol.-%

D kg/m³

Vol.-%

D kg/m³

Vol.-% D

kg/m³ wet kPa

dry kPa

D kg/m³


old 2,5 27,2 3,7 28,2 2,1 27,5 13,0 27,5 206 188 27,1

new 1,2 27,7 2,2 27,7 4,2 27,8 17,5 27,9 195 180 27,7


old 3,9 27,7 3,6 28,3 3,4 27,8 1,7 27,8 195 177 27,3

new tests are running


old tests are running

new tests are running


old 2,8 29,0 1,8 28,3 5,1 29,8 14,5 29,9 209 187 29,2

new tests running

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CLASS E TEST RESULTS EPS PERIMETER WHITE:

Density 27,5 kg/m³ Maximum flame

height cm

Manufacturer 11 Raw material H 5

Manufacturer 12 Raw material I 10

Manufacturer 13 Raw material I 11

Manufacturer 14 Raw material H tests are running


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12 samples were tested: 4 x block grey 4 x block white 4 x perimeter white There were 8 results with HBCD amount below detection limit. Two results were slightly over the detection limit, and another two results had traces of HBCD up to 5% of the minimum usual used amount. The reason of these traces of HBCD can be not completely cleaned production lines before production with the new raw material.

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HBCD ANALYSIS OF POLYMER FR BOARDS EPS BLOCK GREY AND WHITE AND PERIMETER WHITE:

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and Polymer FR CAS #1195978-93-8 as fire retardant. The test results for both fire retardant types are within the measurement uncertainties almost identical. Exceptions are observed for deformation under load and temperature, bending strength, tensile strength and in a single case for the relation compressive stress to density. The reason for these deviations is, that the production process is not optimized for raw materials with new fire retardants. After optimizing the production process the old level of performance can be achieved. For the Perimeter material there are deviations at a single manufacturer that can be explained by the difference of the densities. For comparing the water absorption results all test results have to be finished. All reaction to fire tests according to EN ISO 13501-1 and DIN 4102-B1 finished at this point were successfully. The result shows that it is possible to prove that the same level of performance can be reached by an optimal fractional test design. As a consequence the insulation manufacturers can avoid the whole amount of ITTs if the similarity of the product was proven by the reduced test program. This is only valid in correspondence with a valid ITT. Renewing the ITT for the reaction to fire behavior is necessary in any case. Task of the manufacturers is to demonstrate a similar level of performance according annex ZA1 of EN 13163 of their products with new fire retardant. More test results with water-repellent raw material will follow.

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SUMMARY:

of 23

GNB-CPD

SG19 Guidance from the Group of Notified Bodies

for the Construction Products Directive

89/106/EEC

NB-CPD/SG19/09/111r4

(SG19 N87) Rev 10

Issued: 2012-09-20

SG19 GUIDANCE

EN 13162 through EN 13171, EN 14064-1, and EN 14303 through EN 14314

QUESTIONS AND ANSWERS

Revision 1: Q&A nos. 28 and 29 added.

Revision 2: Q&A nos. 30 through 34 added

Revision 3: Q&A nos. 35, 36, and 37 added


Revision 5: Q&A no. 44 added


Revision 7: Q&A no 47 modified

Revision 8: Q&A nos. 46 and 47 modified


Revision 10: Q&A nos. 52 and 53 added, nos. 34, 43, 44, and 51 modified, nos. 38 through 51 approved

GENERAL Below is found guidance form Sector group 19 related to the product standards EN13162 through EN13171 used in

combination with EN13172, which is mandatory for CE-marking.

The guidance is given in the form of agreed answers to questions raised within SG19.

In the below text, the form "shall" indicates that all notified bodies are expected to work in accordance with the

answers. The form "should" indicated that the answer is considered a recommendation.

As new questions are raised frequently and the standards are being continuously developed by the working groups

of TC88, this position paper is being developed continuously as well.

Question Answer References

001

How many samples

are needed for

initial type test of

reaction to fire

properties?

At least one sample

The number of tests is regulated by EN 13172 clause B.2.3

(system 1) or clause C.2.2 (system 3). For all other properties than

reaction to fire, ITT shall be performed on samples from four

different production dates covering the thickness range declared by

the manufacturer. As regards reaction to fire, only one result is

required. According to the above-mentioned clauses, the result

shall be based on specimens from the different production dates.

This is understood by SG19 as “using specimens from one or more

of the four production dates”. Thus, in cases where reaction to fire

is the only property to test on a particular product, only one sample

is required (unless it is necessary to test more than one thickness).

Approved by SG19 on 2003-06-03

EN13172 clause B.2.3

EN13172 clause C.2.2

002

What is the

meaning of the

term “production

unit (line)”

Depends on the product

“Production unit” may generally be understood as the production

equipment used for manufacturing the individual product.

For products manufactured on a production line, the production

unit is evidently identical to production line.

For products with a more complex production process, e.g.

of 23


products from a line being cut and/or having a facing added in a

separate department of the factory, the production unit shall be

understood as all the hardware used for the processing of this

particular product.

New definitions of the terms are planned to be included by the next

edition of EN 13172:

Production line: Assemblage of equipment that produces products

using a continuous process.

Production unit: Assemblage of equipment that produces products

using a discontinuous process.

Approved by SG19 on 2003-06-03.

003

May the same ITT

cover products

from more than

one production

unit (line) if they

are manufactured

in the same plant?

No, an Initial Type Test is only valid for the single production

unit from which the samples are taken

According to EN 13172 clause 5.3.5.1, samples for direct testing

shall be drawn from each production unit (line). Initial type test

shall be understood as part of the direct testing in the running FPC

and shall fulfil the requirement regarding direct testing in the FPC.

For properties with no minimum testing frequency, ITT is the only

requirement stated by table B.1 of the product standards.


EN 13172 clauses 5.3.5.1

and 6.

Annex B of the product

standards, EN 13162-13171

004

How to choose the

measuring load

when measuring

thickness on

mineral wool?

There is a printing error in the standard!

EN 13162 clause 4.2.3 requires that the measuring load shall be

50Pa on products with a compressive stress/strength less than 15

kPa. On products with a higher compressive stress/strength the

load shall be 250 Pa.

The correct criterion is 10 kPa – not 15 kPa.

Is cases where the exact compressive stress/strength is not known

(e.g. if it is not declared), an estimation of the compressive

stress/strength based on related parameters may form the basis for

the choice of load.


Recent development:

In AC:2005, "15 kPa" is replaced by "10 kPa" .

Added 2009-09-23:

In 13162:2008, the criterion is maintained at 10 kPa.

Hereby the error is considered corrected.


EN13162 clause 4.2.3

as stated in clause 5.3.2

005

May a lambda

90/90 – calculation

cover several

production units

(lines)

No - lambda 90/90 calculations shall be performed for each

lambda group, on each production unit (line)

Lambda is tested on an ongoing basis as part of the FPC. FPC is

always carried out separately for the individual production units

(lines). For all other tests in the FPC, the compliance criteria are

the declared values which shall be fulfilled by every single test

result.

For thermal properties, the 90/90-fractile is the compliance

criterion for the product (group). There are no compliance criteria

for individual test results except for 3rd

party ITT where all four

test results shall be better than or equal to the declared value.


EN 13172 clause 5.3.5.1,

GNB-SG19 N30 rev.

Annexes A and B of the

product standards

of 23


006

Is airflow

resistance the right

way of declaration?

A technical error in EN 13162

The EN 13162 is giving a requirement in airflow resistance “AF”

which depends on the dimensions of the test apparatus and

thickness. It is recognised as an error by experts now. The most

useful information is the airflow resistivity “r”. As the standard

cannot be changed quickly and having considered the question

raised, we can make the following proposal:

To declare the airflow resistivity as "AFr", instead of airflow

resistance as AF. The symbol of resistivity is “r” in EN 29053.

This may avoid confusion between AF, which is linked by the EN

13162 to airflow resistance only. By the next revision of the

standard, the “r” may be deleted.


Recent development:

In AC:2005, "Airflow resistance" is replaced by "Airflow

resistivity", and the symbol "AF" is replaced by "AFr" .

Added 2009-09-23

In EN 13162:2008, as well the term “Airflow resistivity" as the

symbol ”AFr" are maintained.


EN 13162 clause 4.3.12

007

Calculation of

lambda 90/90

The standards are giving different requirements for number of

measurements to get a test result

The technical bases for declaration and check of the 90/90-fractile

is not uniform because :

The EPS standard states that one test result is the result of one

measurement. For the 9 other of the 10 product families, one test

result can be obtained by averaging a number of measurements.

This will cause a significant reduction of the apparent standard

deviation.

For many products, the standard deviation also depends upon the

measuring area of the apparatus.

Furthermore, the statistical bases are not uniform between ITT,

chapter 7 of EN 13172, audit testing and routine testing.

It is discussed whether it would be wise to recommend an exact

number of measurements to obtain one test result.

After a long discussion in SG-19, it is considered difficult to

advise on this subject.

Manufacturers should be aware that in case of complaints or for

certification purpose, the third party may use n = 1 or a limited

value of n.


EN 13163 clause 5 table 13.

All other 9 standards

indicate one measurement as

a minimum to get a test

result.

008

How to handle the

mounting and

fixing in the SBI-

test

Added 2009-09-23:

The new standard EN15715 is describing in detail mounting and

fixing for the SBI-test.

EN 15715 has taken account of the guidance and recommendation

previously supplied by SG19 and SH02. Therefore, at present no

further need is identified for guidance on that issue.

However, for the completeness the previously issued guidance is

maintained below.

2003 comments:

EN 15715

EN 13501-1

EN 13823

EN 13238

FSG-recommendation 009

(only for MW)

of 23


The mounting and fixing is described in the test standard EN

13823 (standard mounting options). The test conditions shall

reflect the “end-use conditions” (See note 1). The term “end-use

conditions” has sometimes lead to the misunderstanding that the

building part in which the product is intended to be used shall be

subject to testing, but this is not correct.

All tests supporting the product standards are strictly related to the

product – not to any building parts (See note 2). Thus, the product

itself shall be exposed to the flame in the test, and it shall not be

covered by any additional facings or boards etc.

The test conditions shall reflect the “end use conditions” of the

product, i.e. the fixing method and the type of substrate in the end

use.

The choice of a standard substrate for testing is carried out

according to EN 13823, which also gives the field of application of

the test result using different substrates.

The field of application of the chosen fixing method is limited to

the one used unless a wider field of application is documented, e.g.

by guidance from GNB Fire Sector Group or by testing.

The choice of test conditions – in particular the choice of substrate

- may lead to different classifications.

Following the general “worst case” approach, the substrate and

fixing method giving the worst result shall be chosen.

On the other hand, if a manufacturer should choose to recommend

his product only to be used on non-combustible substrates, it

would be acceptable only to test the product on a non-combustible

substrate. If no specific fixing method is desired, the one giving

the worst result should be used.

Testing on a non-combustible substrate will imply a limitation in

the “field of application” stated in the classification report. Use of

a fixing method not representing the worst case will imply

limitations as well. (to be continued)

In order to avoid a product from being used in applications for

which the classification is not valid, any limitations in the field of

application shall be stated clearly in the manufacturers technical

documentation; in particular in the manufacturers declaration of

conformity.

NOTE 1:

The manufacturer does normally not know the end-use of the product. In general, it

is left to the building designer to decide and describe – in technical terms – the

requirements to the performance of the product. The product shall subsequently be

chosen on the basis of the manufacturer‟s declaration.

NOTE 2:

Performance of building parts and “kits” is not covered by the harmonised product standards. Please refer to the relevant European Technical Approval and to the

testing standards for resistance to fire.


Recent development:

On the basis of answers from the member states‟ fire regulators,

the European Commission has reached a conclusion, which can be

found in the document “RG N322”, dated 30 June 2003.

Classification of the product as put on the market will always be

necessary, i.e. the naked product must be classified.

The Additional classification based upon end-use application may

Document from the

European Commission,

Enterprise Directorate-

General, RG N322

of 23


also be included in the CE-marking for those countries which

regulate on end-use application. This additional classification will

be limited by the mounting and fixing configuration used in the

testing and the end-use application(s)simulated.

(Extract of document RG N322 by Anders Elbek, August 2003)

Annexes to the product standards describing the mounting and

fixing in the SBI-test are being developed in line with the above.

Approved by SG 19 on 2006-09-20

009

Who is responsible

for the grouping of

the products?

The manufacturer

According to clause 7 of the product standards the manufacturer

may choose to group his products in accordance with EN13172,

which allows grouping to be done property by property.

The certification body will not have to approve the manufacturer‟s

grouping.


Clause 7 of the product

standards

010

Who is responsible

for the sampling

for ITT

System 1: The certification body

According to EN13172 clause B.2.3, sampling is done by the

certification body with the manufacturer‟s representative present.

The grouping done by the manufacturer will form the basis for the

certification body‟s selection of products for initial type testing.

On the basis of the ITT and other evidence, the certification body

is certifying the conformity of the entire product group. The only

way to ensure that all the products are in conformity is - in each

group - to test the products, which have the highest risk of

nonconformity for the particular property.

This is a difficult task requiring a high level of competence from

the certification body (see note 3).

NOTE 3. To assist in the selection, the correlations established by the

manufacturer for indirect testing (cf. EN13172 clause 5.3.5.2) may be

used by the certification body.


EN 13172, B.2.3

EN 13172, 5.3.5.2

011

Which properties

shall the

certification body

check under system

1+3?

All Relevant Parameters!

The system for attestation of conformity is only dependent on the

fire properties.

For products which are not subject to regulations on reaction to

fire, AoC-system 3 applies (“Any intended use”, cf. table ZA.2.1)

For products in euroclass A1, A2, B and C, AoC-system 1 applies

(unless the two-star footnote can be proven to be applicable) cf.

table ZA.2.2.

In this case the AoC system will formally be system 1 for fire and

system 3 for other properties.

However, Annex ZA states that for products under system 1, all

relevant characteristics shall be of the interest of the approved

body; in particular reaction to fire. For CE-marking, the relevant

characteristics are found in table ZA.1.

It is important to notice that the product is subject to the attestation

of conformity – not the individual properties.

In practice, if a product falls under system 1 for reaction to fire, the

entire product is under system 1 – not only the reaction to fire

properties.

Thus, the declaration (and the certificate) of conformity shall cover

the conformity of the product – not only the reaction to fire class.

Annex ZA of the product

standards

SG19 N54 revised

of 23



Added 2009-09-23

The above understanding was confirmed by representatives of the

Commission in June 2002, cf. SG19 N54revised.


012

How many tests on

thermal

conductivity /

thermal resistance

shall be performed

by a 3rd party for

ITT?

In general: 4 tests, but under certain conditions it may be

reduced to 2 tests

The number of tests for ITT is regulated by EN 13172 clause

C.2.2. It states that the samples shall be taken from four different

production dates and that the thickness range declared by the

manufacturer shall be covered.

In annex ZA, clause ZA.2.2, of the product standards it is stated

that initial type test of thermal resistance shall be carried by the

approved body. All initial type testing is per product or product

group per production unit (line).

Thus, the number of tests to be carried out by a third party for ITT

is 4 tests per product (group) for each production unit.

However, where "historical lambda data" are available, it is

possible to limit the number of new tests to be carried out from 4

to 2 tests, provided that the historical test results satisfy a number

of conditions. For the definition of historical data and for further

information on the conditions for using historical data, please refer

to document "NB-CPD/01/064r3 - SG19 Guidance to notified

bodies on the transitional arrangements for the CE-marking of

thermal insulation products".


Added 2009-09-23:

The above-mentioned position paper has been approved with the

document number NB-CPD/SG19/03/003.


EN 13172 clause C.2.2

NB-CPD/01/064r3

NB-CPD/SG19/03/003

013

When is it

necessary to test

more than one

thickness in the

SBI test?

When necessary in order to ensure that the worst case is covered

In some cases, it is impossible to predetermine the thickness which

would result in the worst behaviour in the SBI test. In these cases it

will be necessary to test more than one thickness. In most cases, it

will be possible to limit the suspected worst cases to two

thicknesses, typically the maximum and minimum thicknesses.

NOTE:

For mineral wool products guidance is found in FSG recommendation 009..


Added 2009-09-23:

The above issue is now dealt with by EN15715 and described in

further detail.

Note: Reference to FSG recommendation 009 is no longer relevant and hence replaced by reference to EN 15715.


EN 15715

014

What is the

meaning of the

tolerances for

compressibility in

EN 13162, table 3?

Tolerances apply to the individual specimen

All requirements in chapter 4 are related to the test results

calculated as the mean value of the individual specimen

measurements, except the thermal properties where the 90/90-

principle apply.

EN13162 clause 4.3.10

of 23


As regards compressibility an additional requirement for the

tolerance of the single measurements apply. E.g., in class CP3 the

compressibility may not exceed 3 mm as an average and the

compressibility of the individual specimens may not exceed 5 mm.


AC:2005, Table 3 is revised in line with the above


Added 2009-09-23:

The above problem has been solved by EN13162:2008 by the

addition of clause 4.3.10.3, note 2


015

At which age shall

the dimensional

stability of EPS

products be

determined?

At an age not exceeding the lowest possible age when delivered to

a customer

The dimensional stability under constant climatic conditions is

strongly dependent on the age of the product. The change of

dimensions (in practice: shrinkage) are normally decreasing

exponentially over time. Age is therefore a very crucial point in

this regard. EN13163 clause 4.2.6 does not specify any limit;

neither does the test standard, EN1603.

Therefore, any product could pass the test provided that the test is

carried out on samples of a certain age.

Referring to the general “worst case” approach, the test should be

initiated before the sample has reached an age which exceeds the

age of the product at the earliest possible time of delivery to the

customer.


EN13163 clause 4.2.6

016

Are products with

special profiling in

the edges covered

by the standards?

If they are, how to

declare thermal

properties?

In most cases yes, but there may be exceptions

The lambda-value should normally not cause any trouble, as it

does normally not depend on the shaping.

The R-value is more difficult. It is not clear how to determine the

R-value on products with a special shaping of the edges; e.g. a

profiling allowing for special fixing systems. It would obviously

not be correct to determine the R-value as if the cross-section were

rectangular. On the other hand, if the actual shape is taken into

account in a detailed two-dimensional calculation, it would not

necessarily be more correct as such a calculation could not predict

the influence of fixtures etc.

The SG19 recommends the R-value to be determined on the basis

of the central, uniform, rectangular part of the cross-section. It

should be stated in the declaration of conformity that the R-value

does not apply to the full area of the product and that this should

be taken into account by the building designer. However, the

applicability of the above principle should be considered in each

case.


Product standards EN13162-

13171, clause 4.2.1

017

Which properties

are covered by the

designation code?

Thermal properties, euroclass and dimensions are stated

separately on the label. All other harmonised properties are

covered by the designation code

The first part of the designation code is the reference to the product

standard, e.g. “EPS-EN13163”. This reference is stating that the

of 23


(017 continued)

product meets all the basic requirements of clause 4.2 (limit

values).

Additionally, clause 4.2 gives different classes for some properties.

These classes are indicated by the designation code. E.g. thickness

tolerances are declared by the letter “T” and one digit (T1, T2, T3

etc.).

The “voluntary” harmonised properties in clause 4.3 are always

mentioned in the designation code, when declared.

However, annex ZA is limiting the harmonisation to the properties

mentioned in table ZA.1. This implies that some of the properties

are not referenced by the designation code for CE-marking.

For instance, some of the product standards are giving different

classes for tolerances on squareness, flatness etc. These properties

are not harmonised and therefore they are not covered by the

designation code for CE-marking.

Further, annex ZA is opening for the so-called "NPD-option", even

for some of the harmonised requirements of chapter 4.2.

This is not foreseen by the product standards and the designation

code cannot indicate whether the NPD-option is used on

requirements of chapter 4.2.

Therefore, in order to avoid confusion of the market, it must be

stated clearly on the product label if the NPD-option is used on

harmonised requirements of chapter 4.2.

Examples:

For mineral wool, there are 3 possible declarations on dimensional

stability.

4.2.6. Dimensional stability at 23 C/ 90%RH.

This is a basic requirement covered by the reference “MW-

EN13162”. No additional code.

4.3.2.1 Dimensional stability at 70 C/ 50%RH.

This is a “voluntary” requirement indicated by the letters

“DS(T+)” in the designation code.

4.3.2.2 Dimensional stability at 70 C/ 90%RH.

This is also a “voluntary” requirement indicated by the letters

“DS(TH)” in the designation code.

In case the NPD-option is used regarding dimensional stability, it

must stated clearly on the label . Example: "Dimensional stability:

No performance determined".

For EPS, there are several possible declarations on bending

strength.

4.2.7. Bending strength minimum level at 50 kPa.

This is a basic requirement covered by the reference “EPS-

EN13163” and it may also be indicated by the letters "BS50".

4.3.6 Bending strength declared at levels mentioned in table 7 of

the product standard and indicated by the letters "BSxxx".

(to be continued)

In case the NPD-option is used regarding bending strength, it must

stated clearly on the label. Example: "Bending strength: No

performance determined".


018

How to declare

Declare the “worst case” value or divide the thickness range into

two or more thickness intervals with different declarations

of 23


properties which

depend on the

thickness of the

product?

Some properties are strongly depending on the thickness.

This is evidently the case for properties such as dynamic stiffness

and sound absorption, but even reaction to fire and compression

behaviour may in some cases depend on the thickness.

Example:

If, for instance, a product is manufactured in the range from 15 to

35 mm, the dynamic stiffness would always be better on the higher

thicknesses.

There are two ways of handling this problem.

1) Divide the thickness range into minor intervals with individual

declarations. In the interval from 15 to 24 mm the value

obtained by testing 15 mm specimens could be declared. In

the interval from 25 to 35 mm the value obtained by testing 25

mm specimens could be declared. Remember that each

thickness interval should be considered a separate product

(group) as regards dynamic stiffness. Thus, ITT and FPC shall

be performed in each thickness interval.

2) Declare the value obtained by the less favourable thickness of

the entire range.


019

What is the relation

between indirect

testing and testing

frequencies?

The FPC testing frequencies for direct testing may be lowered if

indirect testing is used correctly

(Results of indirect testing may not be included in the calculation

of lambda 90/90)

Annex B of the product standards lists the testing frequencies for

testing the individual properties in the FPC. Methods for direct

testing are given by reference to the clause in chapter 4.

For some properties, methods for indirect testing and the

corresponding frequencies are stated as well.

The provisions for using indirect testing is given by EN13172,

clause 5.3.5.2:

- Correlation established by suitable statistical means for each

unit (line); re-examined at prescribed intervals and after

changes.

- Sampling plan and compliance criteria defined.

- At least same confidence interval as when using direct testing.

In case of dispute, direct testing shall be carried out.

The frequencies for direct testing, cf. annex B of the product

standards, are given under the presumption that the above

mentioned requirements for indirect testing are fulfilled.

If the requirements are not fulfilled, the last paragraph of

EN13172, 5.3.5.2 applies: In case of dispute, direct testing shall be

used.

In this case, the direct testing shall be performed at the frequency

stated under indirect testing. (to be continued)

Example:

In the mineral wool standard EN13162 compressive strength is

tested according to EN826 once per 8 hours and indirectly by

testing the organic content once per 4 hours and the apparent

density once per hour.

Thus, compressive strength is tested once per hour by using

indirect testing every hour and by direct testing once per 8 hours.

Annex B of the product

standards.

EN 13172 clause 5.3.5.2.

of 23


The correlation between density, organic content, and compressive

strength shall be established (and re-examined at prescribed

intervals) for each production unit. Sampling plan and acceptance

criteria based on the correlation shall be defined.

If the above mentioned requirements are not fulfilled, compressive

strength shall be tested directly once per hour (minimum).


020

Which test methods

shall be used for

reaction to fire of a

mineral wool

product intended

for use in a floor;

e.g. a floor to

ground insulation.

The test methods referenced by the product standard

When testing fire properties (if classification on reaction to fire is

required), the test methods depend on the expected classification.

The test methods for mineral wool are referenced by table B.2 of

EN13162.

These test methods apply regardless of the intended application of

the product.


EN13162, table B.2

021

How to declare

thermal properties

of tapered boards?

Only the lambda value is declared:

The new amendments and corrections, AC:2005 to the product

standards require only the thermal conductivity declared - not the

thermal resistances.

Thermal conductivity is determined as for products with

rectangular cross-section .


Added 2009-09-23:

Reference is updated to the 2008-versions of the standards.


2008-versions of the product

standards, clause 4.2.1

022

How to declare

other properties

(not thermal) of

products with non-

rectangular cross-

sections?

The product standards and the testing standards describe rather

detailed how to measure and declare the geometrical and thermal

properties of products with rectangular cross sections.

However, products are manufactured with many different

shapings, e.g. products with profiled edges and taperings (non-

parallel faces). As only rectangular cross-sections are foreseen by

the standards, it is necessary to make an interpretation of the

standards to cover these products as well.

Interpretations must be done case by case


023

Audit frequencies

EN 13172 requires inspections "normally be performed twice a

year".

In this case, "normally" refers to the situations not covered by

clause B2.4.4, which gives the conditions for extraordinary

inspections.

This means that audits must be carried out twice per year unless

extraordinary inspections are carried out according to clause

B.2.4.4.

A more precise wording is expected by the coming revision of

EN13172.


EN13172 clause B.2.4.2.

024

Frequencies for

Reference samples must be calibrated by appropriate intervals

According to table 1 of EN13172 reference samples must be

EN13172, table 1.

of 23


calibrating

reference samples

calibrated at a minimum frequency of once per 3 years.

It has been acknowledged by TC88/WG16, that this requirement in

many cases would not be justified.

Therefore, TC88/WG16 has asked SG19 to take a pragmatic

approach to this requirement and accept calibration of reference

samples "as appropriate ".

A revised table 1 without the present right column is expected by

the coming revision of EN13172.

Approved by SG19 on 2005-09-21, cf. GNB SG19 N81

Added 2009-09-23:

EN 13172:2008 has solved the problem as stated above.


025

Mounting of

substrates for the

SBI test- should the

corner be open or

closed?

Should the substrate close the corner or should the corner be left

open?

According to the current standard the corner of the substrate must

leave an opening at the width of the specimen thickness.

At the moment, within CEN TC127 it is being discussed by a task

group to revise the standard with regard to closing the corners, but

no decision has been reached at TC level.

For the time being, the current standard applies, i.e. the substrates

must NOT close the corner.


Added 2009-09-23

References corrected


EN13823

EN13238

026

How to determine

compressive

strength in case a

peak occurs before

10% deflection

The peak force is applied - not the force at 10% deflection

EN 826 gives various examples of typical force-displacement

curves. For each of the examples, it is indicated at which point to

determine the force to use as basis for the calculated

strength/stress.

In example b), a peak is found before the deflection has reached

10%.

This example covers in principle all instances of clearly

identifiable decrease in the force.

I.e. if a clearly identifiable decrease is detected, the test may be

interrupted and the peak value used.

If a "break" in the curve occurs without any decrease in the force,

the force corresponding to 10% deflection applies


EN826 figure 1, example b

027

At what time after

production shall

the thermal

conductivity of

EPS boards be

measured?

Not until the thermal conductivity has reached a stable level

For some EPS-products, the thermal conductivity may change

within the first time period after production (so-called

“conditioning effect”).

To declare thermal properties that reflect the values during the

expected life time of the product (cf. EN 13163, clause A.1), the

manufacturer must ensure that measurements are not carried out

until the thermal conductivity has reached it‟s final level, or that

the conditioning effect is taken into account, e.g. by an accelerated

procedure as described below.

EN 13163, clause A.1

of 23


(027 continued)

To determine whether or not a conditioning effect is significant,

the following procedure may be used:

1. Sample conditioning according to Chapter 5.2 of EN 13163

(min. 6 hours, max. 3 days)

2. Measurement of Lambda according to EN 12667

3. Storage at 60 °C for seven days

4. Second measurement of Lambda according to EN 12667

If the increase of thermal conductivity between the above steps 2

and 4 does not exceed 1 %, the conditioning effect may be deemed

insignificant.

If the increase exceeds 1 %, the manufacturer (and the notified

body involved) have to ensure that the conditioning effect is

known, i.e. the time and temperature dependence, e.g. by repeating

steps 3 and 4 until stability is obtained, or by an indirect procedure

like a cell gas analysis.

The necessary conditioning time may vary due to material

properties, e.g. thickness, density, and elastification. For un-

elastified samples of 50 mm thickness and a density range of 15 to

25 kg/m3 the above procedure is deemed sufficient.


028

How to speed up

the certification

process if the

required ITT

include long term

testing ?

Case by case assessment!

At present, it is being discussed in TC88 WG16 if it would be

justifiable to adapt the requirements for new production facilities.

In special cases, for manufacturers who have already similar

products from other production units certified, a certification body

may make a provisional decision on certification.

In this regard the risk for the final decision being different from the

provisional one must be identified and dealt with.

The obligation for the manufacturer to apply EN13172 clause 5.5

to any non-conforming product must be emphasised.

In such cases, the final decision by the certification body must be

taken within a specified time period not exceeding six months.


SG19 N96

029

If a standard gives

2 alternative

methods, which

one should be

preferred?

The manufacturer is free to decide

In some standards, there is more than one methods of determining

specific characteristics.

For instance, EN13165 and EN13166 allows for determination of

thermal conductivity after accelerated ageing or by adding a fixed

increment.

The certification body cannot require the manufacturer to choose

any particular method.

The manufacturer is free to choose between the methods called-up

by the harmonised standard.


SG19 N96.

of 23


030

How to determine

the correct AoC

system for products

in Euroclasses A1,

A2, B, C ?

AoC System 1 applies unless otherwise proven

Background:

In the marketplace, similar products are available with similar

declarations but with different AoC systems applied.

Normally, mineral wool products with declared Euroclass A1 are

CE-marked using AoC system 1. However, in some cases mineral

wool are found CE-marked under AoC System 3.

Answer:

The one-star footnote of table ZA.2.2 of the product standard

points out system 1 for products/materials for which a clearly

identifiable stage in the production process results in an

improvement of the reaction to fire classification (e.g. an addition

of fire retardant or a limiting of organic material).

The above rather cryptic text is applied to a wide range of

construction products and it is not specifically aimed at thermal

insulation products.

In the context of thermal insulation products, it should be

understood that the one-star footnote covers all thermal insulation

products for which the fulfilment of the declared Euroclass

depends on the manufacturer's controlling of the process.

Thus, for any product in Euroclasses A1, A2, B, and C,

attestation of conformity system 1 applies, unless the declared

Euroclass will be met regardless of the manufacturer's

controlling of the production process.

(Often referred to as 'performance not susceptible to changes')

To avoid misinterpretations of the rather cryptic footnotes, note 1

has been added to clause 7 of the product standards requiring the

manufacturer to demonstrate to a notified body that ' no stage in

the production process will result in an improvement of the

reaction to fire classification'.

In this context the 'notified body' is understood as notified

certification body.

A manufacturer wishing to apply AoC system 3 to a product in

Euroclass A1, A2, B, or C should - before he makes the final

decision on choice of AoC system - ask a notified certification

body to verify that the declared Euroclass performance is not

susceptible to changes.

Notified laboratories being requested by a manufacturer to verify

that a product is not susceptible to changes, should not accept to

perform such verification, but advise the manufacturer to contact a

notified certification body.

A certification body must apply the same techniques for the

verification as for conformity certification (evaluation of test

reports, FPC documentation, on-site audit etc.).

A written statement should be issued indicating whether or not the

manufacturer's demonstration has been verified.


EN13162-13171:

- Clause. 7

- Footnotes of table

ZA.2.2

- SG19 N27

- NB-CPD/06/234 rev.1

031

Should the surface

YES - the surface should be retained.

Products delivered with a 'curing oven pattern' may obtain

EN14706, annex A.

of 23


structure of

specimens be

retained when

testing Maximum

Service

Temperature

according to EN

14706?

different test results depending on whether the surface is ground

smooth before testing or if the surface structure is retained as

delivered.

To facilitate equivalent test results, specimens should have the

same surface structure as the delivered product.

No grinding should be carried out before testing.


Added on 2009-09-23:

For mineral wool, however, the below modification apply, cf. EN

14706, A.1.1:

“For wired mats, the wire and the stitching are removed before

testing. Any existing profile on the surface of boards has to be cut

off. Facings are not removed”.


032

Emissivity of

thermo couple

fixings in high

temperature

testing:

What emissivity

should be chosen?

An emissivity similar to the emissivity of the facing of the

specimen.

When testing according to EN ISO 8497, the emissivity of the

fixing tape may influence the test results.

Hence it is important that the tape used for fixing the

thermocouples does not have a emissivity significantly deviating

from the emissivity of the pipe section tested.

If for instance the specimen is equipped with an aluminium facing,

the thermo couples should be fixed using tape with a similar

surface, e.g. by applying an adhesive to a piece of the aluminium

foil.


033

How to interpret

the 3 years rule for

historical test

results ?

Age at the time of the initial declaration of conformity is decisive.

In the approved guidance from SG19 regarding use of historical

data (NB-CPD/SG19/03/003) it is required that historic data used

as basis for declaring thermal properties should not be more than 3

years old.

For the implementation of the WG10 standards for building

equipment and industrial insulation similar guidance is being

prepared (NB SG 19 N 108 draft 2009).

The 3 years age should be understood as the age of the test report

at the time of the initial declaration of conformity for the product.

For product under AoC system 3, the age of the data is to be

checked by the manufacturer before issuing of a declaration of

conformity.

For products under AoC system 1, the age of the data is to be

checked by the manufacturer before submitting the data to the

certification body and the certification body verifies before issuing

a certificate that the historic data are not more than 3 years old.

Once the declaration of conformity is drawn up, it is not necessary

to renew the ITT documentation.


NB-CPD/SG19/03/003

- clause 2 b).

of 23


034

Which load to

apply to low-

density products

For testing

Maximum Service

Temperature?

The load shall be reduced if necessary to avoid too much initial

deflection

This question was first raised in 2008. At that time, the WG10

standards were not yet applicable. Therefore SG 19 decided to

refer the question to TC88.

The question has now been dealt with by the 2012-edition of EN

14706 (approved but not yet published) of which clause A.3.1

states:

The test load shall be 500 Pa. If necessary the test load shall be

reduced stepwise to 250 Pa or 100 Pa to ensure that the thickness

(d1) is at least 95 % of the thickness (d0) and the load used shall

be declared.

Text proposed by Anders Elbek on 2012-09-21

prEN 14706:2012, clause

A.3.1.

035

What is the

maximum lambda

value for wood

wool under

EN13168

The scope of EN13168 is limited to products with a thermal

conductivity up to 0,1 W/mK.

This is indicated by only 1 significant figure, whereas thermal

conductivity is declared with 3 significant figures in the case of the

thermal conductivity being larger than or equal to 0,1 W/m K.

For Wood Wool it is confirmed by TC 88 WG 9 that the upper

limit value of application of the EN 13168 is 0,149 W/m K, using

normal rounding rules Approved by SG19 on 2009-09-23

036

Is it acceptable to

omit mandated

characteristics if

not regulated in a

relevant country

Yes, table ZA.1 in Annex ZA footnote makes this possible, but

SG 19 recommends keeping a unique declaration for a product

including all the declared characteristics whatever country the

product is placed on the market to avoid confusion in the market.


037

How to interpret

the term Water

permeability in

annex ZA of

EN 14303-14309,

14313 & 14314

Water permeability is Water absorption.

The tables ZA.1 and ZA.3 in annex ZA of several of these

standards are giving conflicting information. CEN/TC 88 is

recommended to clarify this.

The Water Vapour Permeability is a separate characteristic

(normally more relevant than water absorption). The reference in

the EN 14303-14309, 14313 & 14314standards, both in clause 4

and annex ZA needs to be checked too by TC 88 for clarification.


038

How to measure

and declare

lambda for HVAC

products used at

40 or 50 C?

Is it necessary to

declare a curve

and measure many

points?

To declare thermal conductivity, a lambda curve must be defined

Lambda declarations according to EN 14303 though EN 14314

must be based on a curve based on measurements at minimum 3

different temperatures. To cover the temperature range,

measurements at more than 3mean temperatures may be needed,

cf. EN 13787.

The above principle is different from the standards for building

insulation products according to which declarations of thermal

properties are based on measurements at a single mean

temperature - 10 degree C.

Clause 4.2 of EN 14303

through EN 14314

EN 13787

of 23


Approved by Sector Group 19 on 2012-09-19

039

Is it possible to

declare a

maximum service

temperature

without declaring

thermal

conductivity. Is the

lambda curve

necessary?

If the thermal conductivity is not declared, the product is not

covered by the product standards

For all TC88 standards, declaration of thermal resistance/thermal

conductivity is obligatory. Products without declared thermal

characteristics are not covered by the TC88 standards and cannot

be CE-marked with reference to TC88 standards.

If a Maximum Service Temperature (MST) is declared, the lambda

curve must be declared for the temperature range up to the MST.

However, as the MST is defined by the hot side of the test

specimens, the lamda is defined at the mean temperature. Thus the

MST can exceed the highest temperature for which lambda is

declared. For Flat products the difference between MST and the

upper end of the lambda curve would normally be smaller than for

pipe sections.


Clause 4.2 of all CEN/TC 88 Product standards.

040

May the number

of fire tests on pipe

sections be

reduced if the

‘worst case’ is

known?

No, the number of tests are fixed by the standards

Clause 4.2.4 of the product standards refer to EN 15715 that

requires 3 measurements for each thickness interval.

The document SG 19 N 113 gives a more detailed description


041

How to determine

the dimensions on

pipe sections that

may be used on a

range of pipe

diameters?

The manufacturer must decide

Some pipe sections are made with a flexible inner diameter

allowing the pipe sections to be used on pipe diameters varying

over a narrow range

The manufacturer is entitled to decide on separate declarations

depending on the diameter of the pipe.

As the thickness of the pipe may influence several declared

characteristics the conformity of the product must be evaluated for

each thickness, characteristic by characteristic.

However, the manufacturer may also decide for each

characteristic to declare a worst case covering the span of

thicknesses for which the pipe section may be used.


042

How to deal with

small companies

producing on the

basis of finished

products delivered

by another

company, e.g. by

cutting pipe

sections from EPS

block

The requirements do not depend on the organisation behind the

production.

The manufacturer placing the finished product on the market is the

manufacturer in the sense of the CPD. This means that he will

have full responsibility for the entire product, its performance,

conformity and the CE-marking.

The manufacturer is of course free to subcontract any part of the

manufacturing process and/or the FPC, but that does not reduce

the extent of the documentation he must be able to present.


043

Which load should

be applied when

measuring

thickness of wired

matts?

The manufacturers choice

EN 14303 gives two options; 50 Pa or 1000 Pa.

The manufacturer may choose on of the two options – or in special

cases - even both of them.

If both options are used, the declarations of all other

EN 14303 clause 4.2.2.1

of 23


characteristics influenced by the thickness must be declared

separately or on the safe side covering both options.


of 23

044

How to determine

minimum densities

for mineral wool

loose-fill in cavities

or closed

compartments

EN 14064-1 gives two possibilities for determining the minimum

densities for installing in closed cavities and frame constructions.

1) Densities confirmed by relevant authorities, or

2) Tabulated values, cf. table 2 of EN 14064-1

As the authorities of some member states do not „confirm‟ specific

densities and as no harmonized test methods have been developed

for settlement in cavities or closed compartments, the criteria for

applying the above option 1 remain unclear.

The tabulated densities of table 2 of EN 14064-1 are conservative

safe-side values taking into account that loose-fill products may be

made from non-specified mineral wool raw materials spread over a

wide range of densities and maybe even including waste from

other mineral wool products.

It is however a well-known fact that it is possible to produce loose-

fill mineral wool with much lower stable, settlement free densities

by applying a continuous production process and by controlling

the intermediate stages of the production.

In such cases, the tabulated values would often be far too

conservative or even impossible to apply in practice.

Therefore, it is necessary to have the possibility to declare lower

densities – not only in cases where specific densities are

confirmed by national authorities.

Guidance:

Notified bodies may accept a declaration of class S1 for lower

densities providing that the below criteria are met:

1) Tests according to national test methods support the

declaration of class S1 (“no measurable settlement”) at

the specified density.

2) The loose-fill product is based on mineral wool designed

specifically for obtaining lower density when installed

on-site.

3) Continuous production process with control of density at

intermediate stages including control of density after

curing.

4) Installed density not lower than 1,5 times the density after

curing.

5) Density not lower than 1,25 times the declared minimum

density for the same product to meet class S2 for loft

application.

6) The manufacturer demonstrates that complaints or feed-

back from clients, users, or other stakeholders do not raise

any doubt as to the fulfilment of class S1.


EN 14064-1, table 2

of 23

045

Is it obligatory to

test ‘compressive

creep’ on mineral

wool products?

If ‘compressive

creep’ is tested,

should the test be

performed by the

notified body or

the manufacturer?

Compressive creep needs only be tested if declared by the

manufacturer.

Although EN 13162:2008, clause 4.2.9.4 identifies the

requirements on compressive creep as covering the requirements

on durability of compressive strength, the manufacturer is free to

decide whether or not to declare any performance with regard to

compressive creep.

Clause 4.2.9 was introduced by the 2008-version due to the use of

a new template. It was not the intention to make it obligatory to

test compressive creep.

In case the manufacturer chooses to declare a compressive creep

performance, the initial type test will fall under the responsibility

of the manufacturer – not the notified body, cf. table ZA.3

Approved by Sector Group 19 on 2012-09-19 - agreed by TC88.

EN 13162 clause 4.2.9.4

EN 13162 clause 4.3.6

EN 13162 Table ZA.1

EN 13162 Table ZA.3

TC 88 resolution no. 545,

Malaga, 2011-12-09

046

What rounding

rules apply to the

settlement classes

of EN 14064-1

The normal rounding rules apply

EN 14064-1 clause 4.2.3.2 defines 3 classes for settlement:

S1: ≤1%;

S2: > 1% and ≤ 5 %.

S3: > 5% and ≤ 10%

As the limits between the classes are given as integer percentages,

the test results must be rounded to the nearest integer percentage

before the class is chosen.

1. Clause K.4 indicates that for each sample, the thickness is

measured at 9 positions. The reading is rounded to the

nearest integer mm.

2. Clause K.5 gives the definition of the thickness of the

sample, as the mean value of the 9 readings. The

thickness, as the reading of nine values rounded to the

nearest millimeter, must also be rounded to the nearest

millimeter.

3. The percentage s of settlement, result of the ITT, is given

by the formula :

Where :

is the initial thickness of sample , before

cycle 1 (beginning of the test)

is the final thickness of sample , after cycle

no. 4 (end of the test).

Each thickness is defined according to above no. 2.

Example:

A MW product is tested in accordance with annex K and the test

result is a settlement of 1,31 % (annex K does not define how

many significant figures to indicate).

Following the normal rounding rules, 1,31 % is rounded

downwards to 1 %, and class S1 may be chosen.


EN 14064-1 clause 4.2.3.2

EN 14064-1 annex K

TC 88 resolution no. 545,

Malaga, 2011-12-09

of 23

047

What settlement

values should form

basis for

performance

charts for loft

applications. The

declared class or

the ITT-result?

The upper limit value for the declared class of settlement shall be

used.

The standard is not unambiguous at this point, and notified bodies

have made different interpretations.

Therefore, the question was referred to TC88 for clarification.

TC88 has indicated that the intention behind defining 3 classes

was to use the upper limit values for each class as this would

ensure transparency and give safe-side values.

Hence, the settlement, “s” should be the upper limit value for the

declared class of settlement, i.e. classes

S1: s=1%

S2: s=5%

S3: s=10%

In performance charts for loft applications, the “minimum

installed thickness” is calculated by adding the expected

settlement to the “thickness after settlement” using formula H.2:

dbefore = d/(1-s)

Manufacturers and notified bodies should be aware that a proposal

for revision of the clauses on settlement has been forwarded to

TC88. Approved by Sector Group 19 on 2012-09-19

EN 14064-1 annex H

EN 14064-1, clause 4.2.3.2

TC 88 resolution no.545,

Malaga, 2011-12-09

048

Is it always

necessary to

document

maximum service

temperature for

MW products for

HVAC purposes?

For lambda declarations not exceeding 150 C, declaration of

MST would normally not be required.

EN 14303 does not define any service temperature to assume

without any documentation.

The draft amendment to EN14303:2009 suggests the below

addition to clause 4.3.2

"The maximum service temperature test needs not to be done for

declaration of thermal conductivity ≤ 150 °C

under the condition that the binder used is cured at temperatures

> 200 °C.".

To avoid unnecessary burdens on the manufacturers, notified

bodies may anticipate the approval of the draft amendment.


EN 14303 clause 4.3.2

FprEN14303:2009/A1:May

2012

049

How to classify a

product for which

the reaction to fire

depends on which

of the faces that is

exposed in the SBI

test?

To options exist:

1) Declare the worst case, or

2) Make separate declarations for each of the faces.

To identify the worst case, testing of both faces would be required.

If Euroclass F is declared for one of the faces that face would not

need to be subjected to test.

It should be noted that separate declarations would require that

the individual faces be indicated clearly and visibly by the marking

and labelling.

Additionally, certification bodies should note that separate

declarations for the two faces would be „a particular condition

applicable to the use of the product‟ and that such particular

conditions should be indicated by the certificates.

Furthermore, certification bodies should be aware that only

classes A1, A2, b and C may be subject to AoC system 1(AVCP

EN 15715

EN 13162 annex ZA 2.2

of 23

system 1) and that assessment of classes D, E and F would not fall

under the tasks of the certification bodies.

etc.);

Example: A product is classified as A1 when tested on one of the faces. When

tested on the other face, the result is only class F (does not meet

Euroclass E).

The manufacturer may of course declare Euroclass F for the entire

product. However, Euroclass A1 may be declared for one of the

faces provided that the faces are clearly and visibly indicated by

the marking and labelling of the product.

The certification body should indicate in the certificate that the

declared class A1is only valid for one of the faces.


050

How to declare

products

combining two or

more types of

thermal insulation

materials?

In general, products combining two or more types of thermal

insulation materials are not covered by the present TC88

standards.

In principle, the manufacturer is entitled to declare a product in

conformity with a standard if that standard is suitable to

demonstrate that the product meets the requirements applicable to

the intended use in the relevant member state.

However, notified bodies should be aware that TC88 standards are

only intended to cover products falling under a single standard

and therefore it seems unlikely that any of the standards should be

suitable to describe products combining two or more types of

materials.

For the above reason it seems more relevant for the manufacturer

to apply for an ETA (European technical approval or European

technical Assessment).

Example:

For a product consisting of mineral wool fibres and wood fibres,

would it be possible for the producer to declare conformity to both

EN13162 and EN13168 and write 2 separate designation codes on

the CE marking declaration?

Sector Group 19 would not recommend the described solution but

refer the manufacturer to apply for an ETA.


EN 13162 through EN

13171.

of 23

051

How many lambda

curves should be

determined for

ITT for building

equipment and

industrial

insulation?

The number is described in a separate SG 19 position paper.

The tests required for the building equipment and industrial

insulation are described by the separate SG 19 position paper:

NB-CPD/SG19/11/085 - ITT of factory made thermal insulation

products for building equipment and industrial installations

In general, one curve (based on one ITT) is required for flat

products and 4 curves (based on 4 ITT tests) are required for

cylindrical product.

Clause 7 of the above paper describes the matter in detail.


NB-CPD/SG19/11/085,

clause 7

052

What tests should

an EPS or XPS

manufacturer

conduct upon

change of fire

retardant?

ITT must be repeated for all characteristics likely to be affected

by the change.

Unless all ITTs are repeated, an assessment must be made of the

likeliness of the product no longer meeting the declaration, and it

must be justified that omission of new tests does not put the

conformity at risk.

Omission of Reaction to fire tests would normally not be

recommendable.

The following characteristics are normally considered likely to be

affected:

- Thermal conductivity

- Compressive strength

- Bending strength.

A manufacturer not repeating ITT for all characteristics, must be

able to document his reasons for not repeating ITT.

As basis for such documentation the manufacturer may use

- Documentation from the raw materials supplier

- Tests from FPC

- Technical literature, e.g. from 3rd

parties and institutes.

As EPS and XPS would normally fall under AoC system 3+4, no

certification body would be involved. The manufacturer is

therefore solely responsible.


EN 13172 clause 6

053

Do all TC 88

standards allow

for indirect

lambda testing ?

Indirect testing is normally necessary to control the processes

To apply indirect testing is always allowed, whether or not annex

B of the relevant product standard indicates specific parameters or

methods to apply.

However, use of indirect testing would not allow the go below the

minimum frequencies for direct testing indicated by table B.1 of

the standard.

Use of indirect testing is also dealt with under Q&A no. 19.


EN 13162 to 13171 clause

B.1

Q&A no. 19

054

Is declaration of

pH value always

required for

The manufacturer is free to decide

Determination of the pH-value is described in clause 4.3.7, which

is a sub-clause to 4.3, „For specific applications‟.

EN 14303 clause 4.3.7

EN 14303 clause 4.3.1

of 23

mineral wool to

EN 14303 ?

As described in clause 4.3.1, properties described in clause 4.3

need not be determined and declared if there is no requirement.

This means, that the manufacturer is free to decide whether or not

to declare the pH-value.

However, if the pH-value is not declared for a product, that

product is excluded from uses for which a declaration of that

property is required.

Text proposed by Anders Elbek on 2012-09-21

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