Construction Insulation: ESPR Requirements, Blowing Agent GWP, Recycled Content, and DPP Compliance Guide
Construction insulation products are a priority category for ESPR due to the EU Renovation Wave initiative. The delegated act is expected in 2026–2027. The DPP will require thermal performance data, blowing agent GWP (for XPS and PIR/PUR), recycled content, and end-of-life recycling instructions. Insulation manufacturers using HFC blowing agents face additional compliance pressure from the EU F-Gas Regulation.
Low — no blowing agent; lower recycled content than glass wool
EPS (expanded polystyrene)
0–30% recycled EPS
Pentane (GWP 7)
Medium — low blowing agent GWP; recycled content varies
XPS (extruded polystyrene)
0–20% recycled XPS
HFC or CO2 (GWP 1–1,500)
High — HFC blowing agents under F-Gas phase-down
PIR/PUR (polyisocyanurate/polyurethane)
0–10% recycled content
HFC or pentane (GWP 7–1,500)
High — HFC blowing agents under F-Gas phase-down
Natural insulation (hemp, cellulose, sheep wool)
High (cellulose: 80–100% recycled paper)
N/A
Low — natural materials, high recycled content
Truth Anchor: ESPR Article 5(1) identifies construction products as a priority category for delegated acts. The EU Renovation Wave initiative creates urgency for the construction insulation delegated act. — EUR-Lex CELEX:32024R1781
Expected DPP Data Fields for Construction Insulation
Data Field
Annex III Category
Notes
Thermal conductivity λ (W/m·K)
Energy performance
Already required under Construction Products Regulation
Thermal resistance R (m²·K/W)
Energy performance
Already required under Construction Products Regulation
Fire reaction class (Euroclass)
Durability and reliability
Already required under Construction Products Regulation
Recycled content (%)
Recycled content
New under ESPR delegated act
Blowing agent type (XPS, PIR/PUR)
Substances of concern
New under ESPR delegated act
Blowing agent GWP
Carbon footprint
New under ESPR delegated act
Carbon footprint per m² (EPD)
Carbon footprint
New under ESPR delegated act; ISO 14025 EPD
End-of-life recycling instructions
End-of-life information
New under ESPR delegated act
Environmental Product Declarations (EPDs): The DPP Foundation for Construction Insulation
Environmental Product Declarations (EPDs) are ISO 14025-compliant documents that disclose the environmental performance of construction products, including carbon footprint, energy consumption, and waste generation. EPDs are already required for construction products in many EU public procurement specifications. The ESPR DPP for construction insulation will build on the EPD framework — manufacturers who already have EPDs for their products will have a lower DPP preparation burden.
What Construction Insulation Manufacturers Must Do Now
Obtain Environmental Product Declarations (EPDs): EPDs provide the carbon footprint and lifecycle data required for the DPP. If you do not have EPDs for your products, commission them now.
Audit blowing agent use (XPS, PIR/PUR): Document blowing agent type and GWP for all products using blowing agents. Plan transition to lower-GWP alternatives.
Audit recycled content: Determine recycled content percentages for all insulation materials. Glass wool manufacturers should document the percentage of recycled glass used.
Prepare DPP data templates: Create DPP data templates for all insulation product models, including thermal performance, fire class, recycled content, and blowing agent data.
Select DPP registry service: Evaluate DPP registry service providers with experience in construction products.
Construction Insulation Under ESPR: A Long-Lifetime Product
Construction insulation products (mineral wool, expanded polystyrene, polyurethane foam, and other insulation materials) have expected lifetimes of 30-50 years. This creates a DPP data hosting obligation of at least 40-60 years — one of the longest of any product category. The ESPR construction insulation delegated act is expected to be adopted in 2026-2027, with mandatory compliance from 2028-2029.
Many construction insulation manufacturers already produce Environmental Product Declarations (EPDs) that contain lifecycle assessment data including carbon footprint. EPD data can be used to populate the carbon footprint field in the ESPR DPP, reducing the additional data collection burden for manufacturers who already have EPDs. Manufacturers who do not have EPDs should consider commissioning them now, as the data will be required for the ESPR DPP.
Insulation Product Categories Covered by ESPR
The ESPR delegated act for construction insulation will cover all major insulation product categories used in the EU construction market. Mineral wool products — including glass wool (glasswool) and stone wool (rockwool) — represent the largest market segment by volume. Expanded polystyrene (EPS) and extruded polystyrene (XPS) are the dominant rigid foam insulation types. Polyurethane (PUR/PIR) foam boards are used extensively in flat roof and facade applications. Cellulose insulation, made from recycled paper, is a growing segment. Aerogel insulation, while expensive, is used in high-performance applications where space is constrained. Each of these product types will have specific DPP data requirements reflecting their different material compositions, manufacturing processes, and end-of-life pathways.
Thermal Performance Data in the Insulation DPP
The most critical performance data for insulation products is thermal conductivity (λ value, measured in W/m·K) and thermal resistance (R value, measured in m²·K/W). These values are determined through testing to harmonised European standards — EN 12667 for rigid products and EN 12939 for loose-fill products. The ESPR insulation DPP will require manufacturers to declare the declared thermal conductivity value (λD) at the reference conditions specified in EN ISO 10456, the thermal resistance at the declared thickness, and the product's reaction to fire classification under EN 13501-1. Manufacturers must ensure that the values declared in the DPP match the values on the CE marking label and in the declaration of performance — any discrepancy will constitute non-compliance under both ESPR and the Construction Products Regulation.
Recycled Content and Circular Economy Requirements
The ESPR delegated act for insulation is expected to introduce minimum recycled content requirements for certain product categories. Glass wool insulation already contains significant recycled content — major manufacturers report 60–80% recycled glass cullet in their products. Stone wool insulation contains lower recycled content but manufacturers are investing in recycling infrastructure to increase this. EPS and XPS insulation have historically low recycled content but the EU's Packaging and Packaging Waste Regulation and ESPR are creating regulatory pressure to increase recycled polystyrene content. Manufacturers should begin documenting their current recycled content levels and supply chain sources now, as this data will be required for the DPP and will be subject to third-party verification.
Insulation Type
Typical λ Value (W/m·K)
Recycled Content (typical)
ESPR DPP Status
Glass wool
0.030–0.044
60–80%
Delegated act under preparation
Stone wool
0.033–0.045
10–30%
Delegated act under preparation
EPS (expanded polystyrene)
0.030–0.040
0–15%
Delegated act under preparation
XPS (extruded polystyrene)
0.025–0.035
0–5%
Delegated act under preparation
PUR/PIR foam
0.022–0.028
0–5%
Delegated act under preparation
Cellulose (loose-fill)
0.038–0.042
85–95%
Delegated act under preparation
Frequently Asked Questions: Construction Insulation ESPR Requirements
The ESPR delegated act for construction products (including insulation) is expected in 2026-2027, with a compliance date of 2028-2029. Construction insulation is a priority category due to the EU Renovation Wave initiative targeting 35 million building renovations by 2030.
ESPR covers all insulation materials placed on the EU market: mineral wool (glass wool, stone wool), EPS (expanded polystyrene), XPS (extruded polystyrene), PIR/PUR (polyisocyanurate/polyurethane), natural insulation (hemp, cellulose, sheep wool), and vacuum insulation panels.
Glass wool insulation already contains 60-80% recycled glass. Stone wool contains 10-30% recycled content. EPS and XPS can contain recycled polystyrene. The DPP will require disclosure of recycled content percentages for all insulation materials.
XPS and PIR/PUR insulation use blowing agents that have significant GWP. HFC blowing agents (R134a, R365mfc) have GWP of 1,000-1,500. The EU F-Gas Regulation is phasing down HFC blowing agents. The DPP is expected to require disclosure of blowing agent type and GWP.
Yes. The DPP is expected to require end-of-life instructions for all insulation materials, including recycling instructions, take-back scheme information, and material recovery rates. Currently, most insulation materials are landfilled at end of life.
Register Your Digital Product Passport
The EU DPP Registry goes live on 19 July 2026. EU customs will verify DPP compliance automatically from that date. Products without a valid DPP can be refused entry. Register now at Africa’s first ESPR-compliant DPP registry.
ESPR Requirements for Construction Insulation Products
Construction insulation products — including mineral wool (glass wool and rock wool), expanded polystyrene (EPS), extruded polystyrene (XPS), polyurethane (PUR/PIR) foam, and natural insulation materials (hemp, sheep wool, cellulose) — are a priority product category under ESPR. Buildings account for approximately 40% of EU energy consumption and 36% of EU greenhouse gas emissions, and improving building insulation is one of the most cost-effective ways to reduce energy consumption and emissions. The ESPR delegated act for construction insulation products will set requirements for thermal performance, recycled content, recyclability, and DPP data disclosure.
The DPP for construction insulation products is expected to include: the product's thermal conductivity (λ value) and thermal resistance (R value); the product's carbon footprint per unit of thermal resistance (kg CO2e per m²·K/W); the percentage of recycled content; information on substances of concern (particularly flame retardants, which are widely used in insulation products and may be persistent, bioaccumulative, and toxic); the product's expected lifespan; and instructions for end-of-life disposal or recycling. The carbon footprint metric is particularly important for construction insulation because different insulation materials have very different carbon footprints — natural materials like hemp and sheep wool have much lower carbon footprints than synthetic materials like XPS and PUR foam.
Frequently Asked Questions
The ESPR delegated act for construction insulation products is expected to be adopted in 2025–2026. Manufacturers should plan for compliance by 2027–2028. The Construction Products Regulation (CPR) also applies to construction insulation products — manufacturers must comply with both regulations.
The Construction Products Regulation (CPR) sets requirements for the declaration of performance of construction products, including insulation. ESPR adds requirements for DPP data disclosure, recycled content, and recyclability. The ESPR DPP for insulation products will complement the CPR Declaration of Performance by providing additional environmental data in machine-readable format.
The ESPR delegated act for construction insulation is expected to restrict or require disclosure of flame retardants that are classified as substances of concern under REACH. This includes halogenated flame retardants (HFRs), which are widely used in EPS, XPS, and PUR foam insulation. Manufacturers should assess their flame retardant use and consider transitioning to non-halogenated alternatives.
No. ESPR applies to products placed on the EU market after the compliance date. Insulation already installed in existing buildings does not need a DPP. However, insulation products placed on the EU market (sold) after the compliance date must comply with the requirements, regardless of when they are installed.
Mineral wool manufacturers already use significant quantities of recycled glass and rock in their products. The ESPR delegated act is expected to set minimum recycled content requirements that reflect current industry practice and incentivise further increases. The DPP must disclose the actual recycled content percentage, enabling buyers to compare products from different manufacturers.