EPS insulation, what to watch out for in order not to lose the 110% super bonus

14/09/2021 – The European market for Expanded Sintered Polystyrene (EPS) products is characterized by many companies that operate mainly on a national level by purchasing the raw material from the most important producers. But in recent months the shortage of building materials has pushed some realities to buy EPS insulation panels from foreign manufacturers.

In the current scenario AIPE (Italian Expanded Polystyrene Association) e Cortexa (the Association of Cladding Insulation Manufacturers) warn: to guarantee the quality of the interventions, it is essential check the quality and conformity of these insulators, also so as not to preclude the project from accessing the tax benefits of the 110% Superbonus.

EPS insulation, European and national rules

The European Community – recall AIPE and Cortexa – has issued harmonized standards for the free exchange of goods with a precise operational reference that is sanctioned by Regulation 305/2011 for construction products, which lists the players who can operate in the market and their responsibilities in compliance with industry standards. Other regulations regulate particular application sectors and identify in detail the performances required of the various products that belong to them and that are declared.

The presence, nowadays, of foreign companies producing EPS insulation throughout the country – the two Associations warn – highlights the need to comply with the compliance obligations and current regulations of the Italian market, which is experiencing a contingent and particular situation of shortage of material, especially in the thermal insulation sector with the Thermal Insulation System Coat.

The EPS used as thermal insulator in the external coating application is fully part of the tax incentive procedures provided for by Superbonus 110%, which provides that the insulating materials applied on the external walls of the buildings comply with the dictates of CAM Construction which DM 11 October 2017. To access the Superbonus 110%, compliance with point “dangerous substances” of the Ministerial Decree is also required.

In the choice of insulating materials, AIPE and Cortexa recommend particular attention in the documentary verification of suitability / correspondence to the CAM (Minimum Environmental Criteria), both in the case of Italian producers and, in particular, of foreign ones. Although the material may be suitable for its intended uses, may not allow access to the 110% Superbonus benefit as it does not respond to CAM.

EPS insulators, regulatory references for material and application

The normative references for the insulating material and for its application are numerous. AIPE and Cortexa offer an overview, in support of the verification activity carried out by the various players in the supply chain and by professionals, regarding the characteristics of the materials that will be used in thermal insulation projects.

CE marking and product standard
According to regulation 305/2011, with the issue of the Declaration of Performance – DoP. This document must be drawn up in Italian, reporting the provisions of the harmonized reference standard EN 13163. It should be noted that the Regulation clearly describes the market operators and their obligations and responsibilities. In the specific case of foreign companies it is not necessary, but appropriate, that there is a national representative that assumes responsibility for compliance with performance, so as to act as a reference for any non-conformities, including for the end user.

The DoP reports the characteristics foreseen by the “external coat” application for EPS insulators. The declaration of performance should include the provisions of the EN 13499 standard, in order to allow the insulation system manufacturer to respond, as requested by the body issuing the ETA.

EN 13499 standard
Specifically referred to EPS used in external insulation. The standard is the operational reference for the whole sector, but it is a non-harmonized standard (which therefore does not involve the CE marking). The standard reports the essential parameters to be declared and which also correspond to the requests of the ETA certification issued to the producers of external insulation systems. The required characteristics are: thermal resistance, dimensional stability and tolerances, water absorption.

ETA for the coat
Procedure that provides for the CE marking, in the event that the manufacturer of external thermal insulation systems uses it. This standard provides that a DoP is issued which declares specific services dedicated to thermal insulation use. The holder of the ETA is the systems engineer who makes use of the declarations of performance of the insulation manufacturer mentioned in the same document. Cortexa recommends always choose External Thermal Insulation Systems supplied as a kit from a single manufacturer, equipped with ETA and CE marking.

CAM building
The CAM protocol requires the manufacturer of the insulating material to declare the provisions of criterion, relating to the performance common to all insulating materials:

– they must not be produced using flame retardants that are subject to restrictions or prohibitions provided for by applicable national or community regulations;
– they must not be produced with blowing agents with an ozone-depleting potential greater than zero;
– they must not be produced or formulated using lead catalysts when sprayed or in the course of plastic foaming;
– if produced from an expandable polystyrene resin, the blowing agents must be less than 6% of the weight of the finished product;
– if made up of mineral wool, these must comply with note Q or note R referred to in Regulation (EC) no. 1272/2008 (CLP) and subsequent amendments (29);
– in addition to compliance with the performance common to all insulating materials, EPS products must be made with a minimum recycled content ranging from 10 to 60%.

The latter must be declared using one of the following three procedures:
– EPD, environmental product declaration containing the minimum percentage of recycled explicitly. The EPD must be issued by a body that appears in the list of accredited bodies to have official validity;
– Certification by Istituto ReMade in Italy – Second Life Plastic;
– company declaration according to ISO 14021 certified by a third party. In the opinion of the writer, for the Italian market the Entity should be accredited by Accredia, and its name should be published on the website www.accredia.it in the list of accredited bodies for quality control.

It should be noted that the recycled content must originate from “waste” and the use of by-products to reach the required percentage is not allowed.

Behavior to fire
The harmonized product standard provides for the declaration of the classification of the reaction to fire of the material, which for the EPS is Euroclass E, if it is coated with suitable materials it can reach Euroclass B.

In Italy there is a regulation that contemplates the fire classification of the KIT or of the insulation used on the facade in case of buildings with a height greater than 12 m and which provides for Euroclass Bs3d0. In the case of buildings with a higher height, it is necessary to proceed with a specific design that includes the analysis of risks and occupants.

EPS insulation, how to verify that they benefit from the super bonus

To access the Superbonus 110% tax benefits it is necessary that the insulating materials meet the CAM requirements. The manufacturers of external thermal insulation systems, as well as professionals in the sector, construction companies and ESCos are invited to verify that the EPS insulation products are accompanied by the specific documents required, filled in correctly and in compliance with the rules and regulations in force.

AIPE and Cortexa advise particular attention in the documentary verification of suitability / correspondence to CAMs (Minimum Environmental Criteria), both in the case of Italian producers and, in particular, of foreign ones. Although the material may be suitable for the intended uses, it may not allow access to the 110% Superbonus benefit as it does not comply with the CAM.

Source: Le ultime news dal mondo dell'edilizia by www.edilportale.com.

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