NGCNext Generation Chemical

Rules, Plainly

UK and EU rules that affect polyurethane buyers, explained plainly.

Short, dated summaries with the official source for each. What the rule is, who it hits, the dates, and what to do this week.

General information, not legal advice. Each summary is dated and links to its source. Rules change; check the source for your own situation before acting.

The watchlist

Upcoming dates, soonest first. Each one is covered below, with its source.

DateWhat happensWhere
10 Nov 2026Defra technical consultation on the UK REACH alternative transitional registration model (ATRm) closesGB
1 Jan 2027UK HFC phasedown step goes ahead unchangedGB
23 Mar 2027Compliance date for the September 2025 GB mandatory classification and labelling (MCL) updateGB
24 Mar 2027Future Homes and Buildings Standards in force (non-higher-risk buildings)England
24 Sep 2027Future Homes and Buildings Standards in force for higher-risk buildingsEngland
1 Jan 2028Revised EU CLP label formatting and relabelling rules apply (a provisional deal would move this to 1 Jan 2030)EU
24 Mar 2028Future Homes transition ends: earlier projects must have started workEngland
By Aug 2028Diisocyanate training refreshers due at the latest for anyone trained before the August 2023 start (earlier if trained earlier)GB + EU
2 Sep 2029BS 476 fire-resistance classifications removed from Approved Document BEngland
27 Oct 2029First UK REACH dossier deadline under the new timetableGB
1 Jan 2033EU ban on foams containing fluorinated greenhouse gases (including HFOs), unless needed for safetyEU

The rules

GBAs of 11 Oct 2026

UK REACH: the October 2026 registration deadline has moved

What it is
Substances that were on the GB market under EU REACH must be fully registered with HSE. The first deadline was 27 October 2026. The REACH (Amendment) (No. 2) Regulations 2026 moved it.
Who it affects
Anyone who imports a chemical into Great Britain or makes it here. A manufacturer outside GB can't register directly: a GB importer registers, or a GB-based only representative does it for the maker. Downstream users need their suppliers' substances covered.
Key dates
27 Oct 2029: 1,000 tonnes or more a year; CMRs at 1 tonne or more; substances very toxic to aquatic life at 100 tonnes or more; SVHCs listed by 27 Oct 2027. 27 Oct 2030: 100 tonnes or more. 27 Oct 2031: 1 tonne or more. Defra is designing a lighter alternative transitional registration model (ATRm); its technical consultation closes on 10 Nov 2026.
What to do
  • Email each supplier of imported substances and mixtures: who is the GB registrant or only representative for each substance, and which deadline applies?
  • Keep the answers with your SDS file. If a supplier can't answer, treat it as an early warning.
Sources
GBEUAs of 11 Oct 2026

Diisocyanate training: certificates expire

What it is
Since 24 August 2023, industrial and professional users of products containing more than 0.1% monomeric diisocyanates (MDI, TDI, HDI and others) must be trained before use. Since 24 February 2022, packs must carry a statement that training is required. Employers must document the training, and it must be renewed at least every five years.
Who it affects
Every processor handling PU systems, prepolymers, adhesives, sealants and coatings with more than 0.1% diisocyanates: foam, panel, spray, moulding and CASE. Suppliers must label packs and make training material available. HSE confirms the restriction applies in Great Britain under UK REACH.
Key dates
24 Feb 2022 (label statement); 24 Aug 2023 (training required); refreshers due on a rolling five-year basis, so by August 2028 at the latest for anyone trained before the 24 August 2023 start, and earlier for anyone trained earlier.
What to do
  • Keep a register: name, training level, date and provider.
  • Put each five-year refresher date in the calendar now.
  • Check every drum you receive carries the training statement.
Sources
EnglandAs of 11 Oct 2026

Future Homes and Buildings Standards from 24 March 2027

What it is
New Approved Documents L and F and amending regulations, published 24 March 2026: low-carbon heating, high fabric efficiency and a new on-site renewable electricity requirement. Not a chemical rule, but it shapes demand for insulation.
Who it affects
The insulation supply chain in England: PIR and PUR boards, sandwich panels, spray foam, pipe insulation and the systems behind them.
Key dates
24 Mar 2027: in force for non-higher-risk buildings. 24 Sep 2027: higher-risk buildings. Projects applied for before 24 Mar 2027 can build to the 2021 standard if work starts before 24 Mar 2028.
What to do
  • Expect specifiers to ask for declared thermal performance backed by the right standard: EN 13165 for factory-made PU products, EN 14315 and EN 14318 for in-situ foams.
  • Ask your system supplier what test data exists for your product before you quote.
Sources
EUGBAs of 11 Oct 2026

Construction products: the new EU CPR, and UK reform

What it is
The EU Construction Products Regulation (EU) 2024/3110 has applied since 8 January 2026. Product families move to it one by one as new harmonised standards are cited, bringing life-cycle environmental declarations and a digital product passport. In GB, the government published its Construction Products Reform White Paper on 25 February 2026, alongside a separate consultation on a general safety requirement for all construction products.
Who it affects
Manufacturers of construction products, such as insulation board and panel makers, and their system suppliers, who will be asked for supporting data. Who must issue the declaration of performance depends on what exactly is placed on the market, which is less obvious for in-situ products such as spray foam. Check with a notified body for your product.
Key dates
8 Jan 2026 (new EU CPR applies); notified bodies reassessed by 8 Jan 2030; old CPR (305/2011) fully repealed in 2039. GB reform: regulations planned, timing not yet fixed.
What to do
  • Board and panel makers: watch for your product family's new harmonised standard and plan your environmental data.
  • Spray foam: ask your system supplier for its declaration of performance and its UKCA or CE basis.
Sources
EUGBAs of 11 Oct 2026

F-gas rules and blowing agents

What it is
In the EU, Regulation (EU) 2024/573 bans HFCs with a GWP of 150 or more in foams other than XPS (since 2023) and, from 1 January 2033, all foams containing fluorinated greenhouse gases unless needed to meet safety requirements. That includes HFOs and HCFOs. Since 1 January 2025, foams and pre-blended polyols containing F-gases must be labelled. In GB, HFCs with a GWP of 150 or more are banned in all foams; there is no GB equivalent of the EU's 2033 ban yet.
Who it affects
Rigid foam, spray foam, panel and appliance foam makers, and system houses supplying pre-blended polyols.
Key dates
1 Jan 2025 (EU F-gas labelling on pre-blended polyols); 1 Jan 2027 (UK HFC phasedown step confirmed unchanged); 1 Jan 2033 (EU all-F-gas foam ban). A separate EU PFAS restriction proposal also covers fluorinated blowing agents; it is still a proposal.
What to do
  • Know which blowing agent is in each system: HFC, HFO/HCFO, hydrocarbon (such as pentane) or water/CO₂.
  • For EU supply, check the pre-blended polyol label carries the F-gas statement.
  • For EU products expected to be sold after 2033, start planning beyond HFOs.
Sources
EnglandAs of 11 Oct 2026

Fire classification: Euroclasses replace BS 476

What it is
Since 2 March 2025, Approved Document B no longer accepts BS 476 national classes (such as “Class 0”) for reaction to fire; Euroclasses under BS EN 13501-1 are used instead. From 2 September 2029, BS 476 fire-resistance classifications are removed too, in favour of BS EN 13501-2.
Who it affects
Insulation board, panel and spray-foam makers, and their system suppliers. Fire safety is devolved: Scotland, Wales and Northern Ireland differ.
Key dates
2 Mar 2025 (reaction to fire); 2 Sep 2029 (fire resistance), with transition for projects already under way.
What to do
  • Retire “Class 0”, “Class 1” and German DIN B1/B2 wording in UK specifications and data sheets.
  • Remember a chemical system doesn't “have” a Euroclass. The finished product, as tested, does. Keep the test report to hand.
Sources
GBEUAs of 11 Oct 2026

One drum, two labels: GB and EU CLP

What it is
GB and EU classification and labelling rules are drifting apart. In GB, notification of classifications to HSE ended on 21 May 2026 and a new GB mandatory classification (MCL) system is being introduced; GB has not adopted the EU's new hazard classes. In the EU, the revised CLP's label formatting and relabelling rules are due from 1 January 2028; a provisional agreement of June 2026 would move this to 1 January 2030, but it is not yet adopted.
Who it affects
Anyone supplying, or buying from suppliers who serve, both markets. The same drum may need a different label and SDS for GB and for the EU.
Key dates
23 Mar 2027 (compliance date for the September 2025 GB MCL update); 1 Jan 2028 (EU formatting rules, possibly 2030).
What to do
  • Ask for a GB SDS (UK REACH / GB CLP) and an EU SDS. Don't assume one works for the other.
  • Check whether any of your raw materials are in the latest GB MCL update.
Sources

On the line

How to compare a technical data sheet

Qualifying a second source? Two grades with the same name or family can run differently. Put the two TDSs side by side and check these lines before you trial. Then trial. Never switch on the name alone.

Line on the TDSWhat it tells youWhat to check
OH value (mg KOH/g)With water content, sets how much isocyanate the polyol side needs.A shift moves your index. Match it, or re-set the ratio.
FunctionalityHow many reactive arms each molecule has.Higher functionality usually means a firmer, more cross-linked network.
Viscosity (cP at stated °C)How the material pumps and mixes.Check the temperature it was measured at. Viscosity rises sharply in the cold.
EO/PO make-up (polyethers)Reactivity, and how open the cells end up.Two polyols with the same OH value can still behave differently.
Water and acid valueSmall numbers with big effects on rise, cure and catalyst demand.Compare the maximums, not just the typical values.
Reactivity profileCream, gel and tack-free or rise times.Only comparable at the same temperature, mix ratio and test method.
Free-rise and moulded densityThe foam you'll get, in kg/m³.Check whether the figure is free-rise, core or moulded.
Mix ratio and isocyanateParts of polyol to isocyanate, and which isocyanate.Confirm the basis (weight or volume) for your machine.
Blowing agentWhat makes the foam expand.Affects F-gas status, flammability in storage and lambda.
Storage and shelf lifeTemperature range and how long it keeps.If a drum has been outside the range, ask before you run it.
Test standardsHow each figure was measured.A number without a method can't be compared.

General guidance from our partner group's technical team. Your process conditions matter; ask us about your line.

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