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Status Update

Oct 8, 2024

Moderator

by Huntsman Polyurethanes. Discussing the scope, timeline, and direct implications of this new regulation, and how producers will need to adapt their portfolio, we are pleased to welcome today's presenters, Shpresa Krtari, EU Lead and Global Sustainability Senior Expert at Huntsman Polyurethanes, and Magda Ceska, Senior Strategic Marketing at Huntsman Polyurethanes. Between them, Shpresa and Magda have half a century's experience in the polyurethanes industry. Shpresa has worked in the chemical industry for nearly 40 years and has spent the last 30 years focusing on sustainability. Magda has 20 years B2B strategic experience across several industries and has spent the last ten years at Huntsman Polyurethanes. During the course of this webinar, you can ask questions by opening the Q&A icon at the top or bottom of your computer screen, depending on your operating system, and then typing in your question.

Your question will be answered in the order received after the presentation portion of the webinar is completed. Now, let me turn the presentation over to Magda Ceska. Magda, the floor is yours.

Magda Ceska
Senior Strategic Marketing, Huntsman Polyurethanes

Thank you, James. Good afternoon, everyone. In terms of format today, we will cover the Green Deal and its impact on the Construction Products Regulation, the expected scope and timeline, as well as what this means for construction materials. We will also briefly highlight the Huntsman solutions we have available and how we can help. Huntsman is a global chemical manufacturer. We are present across the globe with our three divisions: Advanced Materials, which focuses on adhesives and composites, primarily with epoxy solutions, Performance Products, which markets amines, maleic anhydrides, and carbonates, and our division, Polyurethanes. Across the divisions, we have more than six thousand associates and are present around the world in more than one hundred countries. We provide valued solutions from our sixty facilities to a wide range of applications. In terms of end markets, our core competence is in the construction and infrastructure market.

In the Polyurethanes division, our 2,700 associates are passionate to offer solutions across many industries, from automotive, bedding and furniture, to footwear and construction. We deliver products across a wide variety of technology platforms, including adhesives, coatings, binders, and rigid foams. Within construction, we focus on insulation and composite wood products. Our activities in the construction sector span a number of technologies. Through our adhesives and coatings products, we enable resource efficiency. Our materials help to protect as well as to make finished goods more durable. Our versatile solutions for composite wood products enable efficient use of wood in a variety of composite wood panels, and so help support efforts to increase carbon storage in buildings. Our portfolio also includes specialty structural wood prepolymers for applications like cross-laminated timber.

In the area of rigid foam insulation, we provide efficient thermal solutions for metal-faced panels, insulation boards and walk-on, and also have a range of products suitable for technical applications like pipes and tanks. We support developments across our industries from a number of locations. We are proud to share with you that earlier this year, we inaugurated a state-of-the-art research and development facility in Tienen, Belgium. The site spans 11,000 sq m and provides a home to 115 research and development associates. Our focus in the new innovation center is on polyurethanes and performance products. Our labs are laid out in an open space concept. This allows the different teams to interact and to build on each other's knowledge. The site has modern analytical labs, as well as highly automated physical testing for our applications.

There are also two machine halls where we can simulate production conditions for our major end-use markets. In addition to the Tienen capabilities, we also have pilot lines at our Rotterdam site, one for slabstock flexible foams and one for composite panels. I will now hand over to Shpresa, who will guide us through our key topic today.

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

Thank you, Magda, for this introduction. Today, indeed, we are going to talk more about the sustainability and the construction sector. But why is it so important to talk today about sustainability? If you look at the mega trends in that sector, we see that at least 50% of the raw material consumed in Europe is consumed in the construction sector. We are also producing 40% of the greenhouse gas emission, as well as consuming roughly 30% of the fresh water and producing 30% of the total waste. So there is no surprise that a lot of legislation from the European Commission is actually tackling this sector. In 2020, the Green Deal, which is actually an overarching set of legislation, was proposed by the European Commission.

It looked at overall nine pillars of activities, focusing the sectors to actually become more sustainable for the future. Programs were developed around the preservation of ecosystem, the tackling of the climate change issues, looking at green finance, smart mobility, and a series of regulation were also developed to actually capture and try to make sure that the construction sector also was becoming more sustainable. Circular economy, definitely, the climate ambitions are part of it. Obviously, a focus on the building and renovation efficiency, as well as looking at the toxic-free environment. From this overall set of regulations and action plans, different regulations were developed, or different regulation had to be improved and revised.

The few ones that we are going to talk about today is obviously the Construction Products Regulation, but we are also going to discuss a little bit about the Ecodesign Regulation and the impact it has on the CPR, the Construction Products Regulation. We are also going briefly to talk about the Green Claims Directive, sorry, and the Green Public Procurement Directive as well. These are actually regulations that are mostly focused on products, but besides the product level, what is also very relevant for the construction sector is a series of developments, updates, and new regulation that are tackling the building themselves. So obviously, we have the Energy Performance of Buildings Directive, which has been recently revised to integrate additional requirements to make sure the transition to a lower carbon building sector is happening.

For example, we can say that under the EPBD, as of 2028, for example, any building, any new building will have to declare its carbon footprint, which would be actually covering both the operational carbon emissions from the fossil combustion for heating and cooling, as well as the carbon embedded in the different material. With the intention, in the medium term, to also set thresholds for all those building in terms of their carbon impact. We have the Renovation Wave, which is also going to be revised and updated to make sure that the term renovation of building is going to integrate as much as possible sustainability dimension into them, and the Level(s), which is the system to basically assess the performance of the building as such, overall, with all sorts of environmental impact, is also going to be further refined and tuned to more sustainability drivers.

But let's go back to the few regulations that we wanted to highlight today. The first one we will start is the Ecodesign. Ecodesign for sustainable products is actually a new piece of legislation that is going to be published very soon, which actually identifies what are the characteristics from a sustainable perspective that will have to be embedded in the design of any new product that will come on the European market. It looks like a series of possibilities, and we will actually come a little bit later to highlight some of the most important one. Ecodesign regulation is mostly targeted to consumer products. We know, and as you are actually working in the construction sector, that the sector itself is regulated under the Construction Products Regulation.

What will happen in this phase is that the CPR will integrate the Ecodesign regulation and recommendation for sustainability characteristics into the CPR, and in fact, through the harmonized product standard that we are most probably all very much aware of. What does it mean? It means that for the construction sector, there will be new sustainability characteristic that will appear on the CE marking of our products. Another important regulations to look at is the Green Public Procurement, because the CPR will actually enable public building owners and authorities to integrate sustainability elements in their requirements. What we expect to see is increasingly a requirement for possibly a minimum recycled content in the building brief, but also maybe other characteristics for sound durability or compositions. Then we have the Green Claims.

The Green Claims Directive is based on the principle that the Green Deal, one of the key Green Deal focus was basically the protection of the consumer. Protection in terms of protecting from pollution, but also protection towards the green claims and making sure they will not be misleading, misled, and that actually their choices should be based on science. So the Green Claims Directive, focusing on consumer goods, not directly integrated in the CPR, but we can expect that because of the focus on the clarity on the message and the well foundation of the claims, that we are protecting consumer from making bad choices.

So what we will also see is that any claims that will be done by manufacturer, also those done in the construction environment, every time we are claiming a recycled content benefit or a low carbon content benefit, we will should be in a position to be able to defend those position. So let's go back now to the CPR itself. The CPR is covering a series of products. Every construction product basically is covered to some extent by the CPR regulation. For the PU sector, what does it mean? It covers metal insulated panels, as well as insulation boards and block, as well as garage door, but also wood fiber insulation, for example, which is binded with PU technologies, coatings and adhesives, or composite wood panels, or composite wood product, which are applied to the construction sector.

So all those products, to some extent, will have basically to align their requirements into more Ecodesign-friendly environment. So let's now go back to the ESPR, the Ecodesign for Sustainable Products Regulation. And basically, that piece of legislation is providing a framework which requires every product families to look closely into how can we make those products in the future more sustainable. So what are the characteristics that we need to integrate in those product design to make sure that we are foolproof for the future? Several aspects have been highlighted by the regulation: last longer, so the durability is one way to reduce material consumption. Looking at chemical safety, addressing a key pillar of the green, the Green Deal, which is a toxic-free environment. How can we more easily repair and prevent losses of resources through replacement?

How can we more easily disassemble to be able to reuse as much as possible any material that is used?... and any component of a product that has been used. A key component also is to look how can we actually design product to prevent waste production? How can we use less energy along the value chain to make sure that we are actually reducing our impact on climate change? Can we increase the recycled content of material? Can we actually facilitate the circular economy through the design of new products and overall, how can we reduce the carbon and environmental product footprint of any products that we are making? So these are the characteristics that the ESPR is asking for every product to look at and to design what should be the requirement for these future products.

These are exactly the set of characteristics that now will have to be integrated in the CPR through the harmonized product standard. So let's look at how this has been translated for the time being for the CPR. So the CPR will be published in the official journal towards the end of this year. Probably in November, we will have the official text, which is still a framework document that will need then to be translated for the different product falling under the Construction Products Regulation. So looking at the timeline for the initial CPR, it is expected that around mid-2025, we will start to see construction product being brought on the European market that will actually disclose, as a first characteristic, what is the carbon footprint of those products.

A few years later, we will actually be in an environment where all the communication along the value chain will be done through the digital product passports. And then, as you can imagine, and if you're involved in the construction sector, you know that the CPR cover so many different harmonized product standard. The intention is it would take probably around 15 years to make sure that all the product standards are being revised, and all of them are able to incorporate the sustainability characteristic to make sure that the eco design of those product is taken into account. So this is the overall CPR timeline, which needs then to be translated into the different products. So the next slide will show you what does it mean for the insulation products. This is what we expect, knowing how the different legislation development are happening.

If we look at the insulation sector, which has been identified by the European Commission as a priority product to look into and to integrate sustainability in the construction sector, we expect to receive a standardization request for all the insulation product to take place beginning of next year. From that moment onwards, we will have eighteen months to develop a harmonized product standard, including sustainability characteristics. Which means that we expect that by quarter two 2027, we will need to be able to affix to any product, insulation product, coming to the European market, what is the carbon footprint of that product. A few years later, we will have to be in the position to communicate any environmental characteristic as well as any performance through the Digital Product Passport, and several years later, we will have to start to communicate more environmental indicators besides the carbon footprint.

For those who are familiar, these will come from the EN 15804 standard on environmental product declaration. There we will have actually to disclose the core indicators, which are mandatory, so that for that standard. In 2033, we think that we will then be in the position and expected to declare the full set of environmental indicators. This is the timeline for the insulation product. There will be timeline for the other product that we have been talked about, whether it's coating, whether it's other kinds of products, adhesive or any other construction product. But this will only come as we see more clarity into what the priority will be for the European Commission.

Now, a big change to expect in the CPR is that we are going to come from what we call a declaration of performance, which is part of the CE marking, to a conformity assessment as well. So typically today, we have to disclose the performance characteristic, the safety specification of the product. We have to include information about each. What will come with the revision of the CPR is that we will have now to declare sustainability characteristics that will be defined by the harmonized standard, integrating whatever has been developed under the Ecodesign Regulation. We will have to see what is relevant or not for a certain product. We will have to come to an agreement. It will be published in the harmonized product standard, and the moment it is being published in that standard, it will be part of the CE marking.

The first characteristic will be around 28, like I said, that we will have to declare the environmental footprints of those products. A new element, which are maybe less familiar for the people who are who are used to deal with the CE marking and the different attestation of verification, is that particularly for the environmental sustainability assessment characteristic, we will have actually to apply a new rule, which we are not used to, which will require a third-party verification of our declaration, as well as inspection of our manufacturing plant, to make sure that the values we declare from a sustainability characteristic on our product has been done in the proper way.

The fact that we are moving from a performance requirement to include as well as a conformity is that it means also for the manufacturer themselves that they have to assume much more responsibility on the data that will be actually put on the CE marking and later on in the digital product passport. As we are, as manufacturer, being actually asked to make sure that we are conforming to the requirements. So there will be more legal responsibility behind the declaration that we are used to, and much more scrutiny in the way we are generating those numbers. I mentioned already the digital product passport that we have to be ready, probably for the insulation products already quarter two 2026 .

The digital product passport system will be defined in 2026 and will have to be applied into insulation sector, probably quarter one of 2028. So these are the main expectation we can have. At the moment, we don't have much more information on what will be the specific requirements for the insulation sector. But looking at what the ESPR has defined, we can actually expect some changes in the way we are going to have to redesign our product to be able to comply to the future. So I mentioned the Green Public Procurement, and I want to take a little bit of time here to explain what it means. Through the CPR, what we are also actually providing from that framework is the ability for the public authorities to introduce mandatory minimum environmental sustainability requirements for the public procurements.

So what we can expect, knowing what is already happening in certain countries, is that we can see that there will be probably more demand for products which can demonstrate a minimum recycled content or a lower carbon content or the use of less of substances of less concern. So this will actually lead markets for low-carbon products much faster. And the other piece of legislation I wanted to touch upon is the Green Claims Directive. Although the Green Claims Directive is mainly targeting consumer goods and actually falling under the Ecodesign regulation itself, we can expect that the need to be transparent, comparable, and verifiable across Europe will also apply to some extent to the construction sector.

We will have to be much more careful about how we are going to declare the products, and the information about them. For example, if we are making claims about the packaging that we are using, which is 30% recycled plastic, there could be questions about: Is it relevant to talk about it? Is it actually meaning that the product has less environmental impact than an alternative packaging? If we are making claims on our company environmental footprint, can we be sure, or did we actually third-party certified these claims? Or if we are comparing different product, did we actually an assessment, peer-reviewed assessment that actually demonstrate the validity of our claim?

And if we claim only an improvement on carbon footprints, are we sure that we are not degrading other environmental indicators that could be much more relevant for certain products? So green claim is not directly covered under the CPR, but the consequences of the need to be more transparent towards consumer will certainly have an effect on how, in that sector, we are going to talk about green performance. Now, I will hand over to-

Magda Ceska
Senior Strategic Marketing, Huntsman Polyurethanes

Thank you, Shpresa. So we have a number of activities, including an in-house team of experts, which helps us do all of our LCA and assessment. All right, next slide. Huntsman is focused on ensuring that we are able to shift our construction portfolio towards sustainability. A few initiatives that we are delighted to highlight are the following: We are working on a closed-loop recycling projects, where we integrate recycled materials from our customer production waste in our insulation systems. Our DALTOPIRE XHFR composite panel technology incorporates up to 20% recycled content in the polyol blend, while retaining good physical properties, low lambda values, and fast productivity. For composite wood products, we have developed specialty binders with up to 25% bio-based content.

Not only are we able to integrate this level of bio content, the overall binder shows a carbon footprint reduction of up to 40% versus other commonly used MDI binders. We are also focused on enabling the use of more sustainable raw materials. For example, wood fiber insulation, where we have worked with the industry to develop a more efficient production process and where we continue to work on new generations of binders. Of course, we do not only look at the products, but we continuously evaluate our upstream raw materials to improve their overall sustainability credentials. As a near-term solution, we have taken the decision to certify our production locations with ISCC PLUS, and are able to offer all of our MDI-based products with a mass balance attribution of bio-circular benzene. Today, mass balance is not yet integrated in the Construction Products Regulation.

However, we continue to highlight the benefits of a mass balance approach to the standardization bodies. In parallel, we are also exploring and working on proprietary projects for alternative ways to generate bio-based feedstock for our MDI production. We continuously monitor our portfolio from a regulatory perspective. We look at all the different chemicals which are used in our products. We make sure that we are phasing down or phasing out specific substances ahead of regulation. For example, we are modifying our products to eliminate the use of TCPP, to make sure that our fire-rated product portfolio is very much aligned to new regulatory requirements. Similarly, we are also phasing down the use of fluorinated blowing agents. By doing this, we want to ensure that we are able to provide our customers with the appropriate product portfolio to help them face the future.

In conclusion, the revised Construction Products Regulation aims to boost both supply and demand for sustainable construction products in the European Union. The new eco design criteria will be integrated in new harmonized standards. This will define elements which will have to be included in Declarations of Performance and Declarations of Conformity. Digital Product Passports will be the new way to communicate and will initially feature global warming potential. For insulation products, implementation is expected by early 2028 . Coupled with this, there are likely to be mandatory environment and sustainability requirements for public building procurement. In communicating benefits of launch products, the new Green Claims Directive will have to be taken into account. We will have to be mindful of claims we make to prevent the perception of greenwashing, as any claims we make may be scrutinized. Thank you for listening to us.

We hope you found the presentation useful. Back to you, James.

Moderator

Thank you very much, Magda. Thank you, Magda, and thank you, Shpresa, for such a clear and informative presentation. And so now we move to the Q&A section of the presentation. So we're now ready for your questions. As a reminder, you can click on the Q&A icon on your computer screen and type in your question, and your questions will be answered in the order received, and we already have a few questions. So I'm gonna start with a question, excuse me. Will all insulation materials be included in System 3+?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

This is indeed what we understood so far. So actually, TC 88, which is the overarching same group that is looking at insulation product, has started the process of understanding how the different environmental indicator will have to be looked at. And all insulation product basically will be covered, should be covered by this standardization request, indeed.

Moderator

Thank you. We have a couple of questions that are on a similar topic, and Magda did just touch on this towards the end of her presentation, and it's really about the EU's acceptance of chemical recycling and mass balance. Are you engaging with authorities or EPD operators in Europe to encourage the acceptance of mass balance attribution of recycled content in your materials?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

Yes, definitely. This is the work we are doing, and I'm personally involved in, for those who are familiar, CEN/TC 350, which is actually the standardization technical committee looking at EPDs, environmental product declaration, and who has developed the standard EN 15804, which indeed today is not actually accepting the mass balance. We are working now in a technical committee, developing a technical standard, basically, and trying to identify what should be the rules to make sure that we can integrate mass balance by providing a framework that will indeed control the claims, and making sure they are not misleading, basically, the users of those claims.

But we are definitely working specifically on the construction sector through different trade association, but we are also working with a general trade association, more on the concept also to integrate mass balance in the packaging directive, the single-use plastic, to make sure that we can enable, basically, the chemical sector to transition to a circular economy. Knowing the scale at which we are working, we cannot actually start building small plants trying to catch up, so we have to be able actually to use our assets to the best possible and using gradually an increasing amount of alternative feedstock towards the fossil one. So we strongly believe it is needed for the sector, and we need to convince that we can do it in a transparent and obviously, a scientific way as well.

Moderator

Now, thanks, Shpresa. Now, one question I've been asked a lot, and I thought I'd just do this housekeeping now. A lot of people have been asking if they can see the presentation again. Well, in 24 hours, the whole presentation will be available to watch again, including this Q&A session on our website at utech-polyurethanes.com, and click on the webinars tab, and you'll find this presentation to watch again. So, maybe-

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

Maybe further, James, it will also be on our website.

Moderator

It will also be on Huntsman's website. So there we go. And now, gosh, there's a lot of questions here. So when do you see the possibility of introducing bio-based MDI?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

Ah, that's a very good question. You mean the mass balance one or the segregated one?

Moderator

I don't know.

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

If it's mass balance-

Moderator

I'm merely the messenger.

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

If it's the mass balance, it depends, of course, in how far it will be accepted into the regulatory framework to actually boost, basically, the pickup of the feedstock. If it's on the segregated end, I would say it will be very difficult because basically, MDI plants are huge plants that need huge amount of bio-based feedstock, should we have to consider a full transition at once. So I think without the mass balance, I'm not sure actually if that could happen one day from another, because it needs a new plant with a new feedstock line, and we need sufficient bio-based feedstock to start with it. So we need the mass balance as a transition, and hopefully gradually increase then this amount of bio-based or recycled feedstock.

I mean, a lot of development are happening, and I think a lot of companies are trying actually to catch up on the circular economy demand, so we have to see how can we accelerate this process to actually come to a stage where we can have actually a segregated plant, because we would have sufficient feedstock to do it, and everything has been basically implemented gradually.

Magda Ceska
Senior Strategic Marketing, Huntsman Polyurethanes

And the mass balance, if companies are interested, we are able to offer all of our MDI products mass balanced today.

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

Yeah .

Moderator

Now, this question kind of leads on to what you were saying about feedstocks. What's your strategy in terms of procuring sustainable feedstocks? What are the key drivers for you to build circular or bio materials?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

So in the Polyurethanes division, we have a full sustainability strategy, obviously, looking, as any company, at our Scope 1 and 2, which is energy related. Then we have a program with our procurement team to actually look at what are the different options today with the existing feedstock, whether bio-based or circular. But that, like I said, today would mostly be through mass balance because of the volume. But we are also looking at low carbon solutions there for some of the feedstock that we have. For the side of the polyol blend, and I'm not talking about the isocyanate, but more, let's say, what we can do also with the B sides.

We are obviously looking at new technologies there, new types of polyol that could be based already today on segregated bio-based or recycled content. So that is also something we are working. Yeah, I mean, we are definitely looking and discussing with our supplier to make sure that we are developing our roadmap to decarbonization, basically.

Moderator

Okay, here's another question, and it's really about legacy materials, I guess. What about those products which have been produced in the last 20 years with PFAS or BFRs in?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

Yeah, definitely that is a topic, and certainly now that we have the revision of the F-gas regulation and of the ODS regulation, ozone depleting substances, that clearly stated requirements to deal with those end-of-life product in a responsible way, making sure we are not releasing either the F-gas or the ozone to the environment, specifically for panels and boards. So I think there we rely a lot on, let's say, the proper dismantling, but also proper treatment of those products. Obviously, containing legacy substances makes it difficult to basically recycle those products.

This is why actually, if you go back to the slide that Magda has shared, is that we are now working more for the next generation, trying to see how can we recycle the product we are going to make today or, let's say, tomorrow, so that we don't have that legacy issue in the future. But obviously, dealing with legacy issue is something that many sectors are confronted with, whether it is insulation or even the wood sector. I mean, everybody used a certain type of chemical in the past, not necessarily knowing how harmful they could be, and we all have to deal with it. I think, obviously, destruction of those material before they come to the environment is still something to consider.

But obviously, we have to do it in a proper way and with the proper energy recovery to make sure that we are not losing resources, and just discard products.

Moderator

Thank you, Shpresa. Now, another question which is kind of on the MDI side of things: Are there enough sustainable and scalable reactants for future PU in construction? And how about NIPUs, non-isocyanate polyurethanes, is that a feasible future in this sector?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

That's a very good question. Now, the size of the PU market in general, or the PU demand, I would say, is very, very big. That's why actually we need to also transition to this circular feedstock and making sure that we can increase their presence. The NIPU, I mean, the feedstock used is also in small amounts for the time being, so maybe that will increase. It would be difficult, I mean, I don't have a crystal ball. But I'm not sure that the transition can be that fast, knowing basically the size of the PU demand, and the well-established technologies and the production that is already taking place.

Moderator

Okay, I've got two similar questions here on HFO. Will HFO be phased out, or are there better alternatives coming? And any information on HFO blowing agent being phased out in North America?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

I know, that's a very, very good question. We didn't discuss it here, but I'm happy to take it on. HFO is actually in Europe covered by two regulation: the F-gas Regulation, the fluorinated gas regulation, and the current effort carried out in ECHA on the PFAS. If I take the fluorinated gas regulation, it has been basically revised and published a few months ago, and clearly state for the HFO used as blowing agent will be banned by 2033, if I'm not mistaken, unless there is a safety protection rule there that could actually be engaged, but then you have to discuss with the Member State to make sure that you have actually an authorization, basically to or an exemptions to use your HFO in foams.

But in principle, we expect the HFO, just by the F-gas regulation, will have to be disappearing from foam application latest 2033 . Yeah, earliest 2033 . And that's why actually, some of our program is looking at how can we replace HFOs in insulation products, PU. And then we have all the efforts which is carried out today under ECHA, the European Chemicals Agency, which is actually putting HFOs from blowing agents together with the PFAS family. Which there we have a different timeline that if we just look at the initial proposal, we would expect a ban in use in foams probably around 2027 , 2028 or maybe even earlier. Although, the whole process has been delayed, so very difficult to adjust.

With a little exception that maybe spray foam can take another three, four years before they will be banned in that application. But this decision has not been taken yet. ECHA is reviewing all the comments that were made by the industry. And we will know in the coming probably, first half of next year, a little bit more, what would be the timeline for regulating HFOs as PFAS in PU foam application? So there we expect indeed, 2028 probably, in all the foams. Except the spray foam, that could be a little bit later. Now, PFAS definition in Europe includes HFO as blowing agents. However, in the U.S., the PFAS definition excludes the HFOs that we are using as foam blowing agent.

From, let's say, a federal perspective, we don't expect activities or a ban on the use of HFOs in the U.S., for example, in insulation foam. However, some states have already decided that they will also ban those products in foam application, and I think California was one of them. I'm not gonna give another state name, but you can send a comment and a question to basically the QR code that you see there, and then I can take a little bit more time to identify the states where basically we expect a similar approach than the European one, because they have decided to include basically the HFOs as PFAS or they see there is a need basically to control their uses.

Moderator

Okay, I have another question. We've moved from blowing agents to flame retardants. A few questions, mostly the same. So I'll just read the one: Are you looking into solid flame retardants as an alternative to TCPP? If yes, then which?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

So same thing, put it in the QR code. To be honest, I mean, we are not in innovation. We are looking at a panel of options, of course. TCPP removal from our portfolio is part of our innovation projects, knowing that and expecting that there will indeed be an enforcement of restriction of use of TCPP in foam. So we are working on it. We look at different panel, checking also basically their sustainability credentials for the future. I don't know if you have a specific,

Magda Ceska
Senior Strategic Marketing, Huntsman Polyurethanes

I think we're happy to discuss on a one-to-one basis with our customers or those interested. Use the QR code, send us the question. We're happy to get back in touch for a discussion.

Moderator

Will that QR code be coming back up on the screen? Because we-

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

We are trying.

Moderator

I shall reference it later. Now, so, this question. All detailed information regarding System 3+ for various construction materials should be included in new harmonized standards. Am I right?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

Yes. Yeah, that's... That is actually what is already mentioned in the framework CPR regulation, that environmental characteristic will be covered by the AVCP 3+. I'm not sure we will have room to change that in a harmonized product standard. So we will have basically to endorse whatever has been decided at the CPR level. And what we can do in the harmonized product standard is identify the characteristic which makes sense for our product. And because we will have to declare anyway the carbon footprints overall, that is true for all the harmonized product standard, then, yeah, the AVCP 3+ will be basically part of that process. So the whole system today, we use EPD operators for peer reviews and so on. This will go through notified bodies.

There will be more scrutiny on the way that the data has been gathered. There will be visits of the plant to make sure that the data is indeed representative of what's happening. So it will be a slightly different way than the way we did it for typically the EPDs, for those who are familiar with it.

Moderator

Thank you. Okay, I've got another question. Going circular tends to involve higher costs. Where will the demand come from? Are there sufficient stimuli or obligations?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

That's a $1,000 question. It's a very good question. I think we'll have to see how things will evolve. I don't know if you can answer or do we have a view on this?

Magda Ceska
Senior Strategic Marketing, Huntsman Polyurethanes

I think the hopes of the European Union, it's all to do with the supply and demand. I think by incentivizing and pushing producers to act in a more environmentally friendly way, this should hopefully both boost the demand side as well as then the innovation and the production side to be able to cater to demand. So, million-dollar question, I think the future will tell.

Moderator

And now we have another legacy material question: Do we have a new asbestos issue with what we made in the past?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

We never use asbestos in our foam, for sure, and in fact, I know that sometimes people, and I've seen, like, anybody reading news, that there was a connection between asbestos, they were making PU with the new asbestos, but in fact, there is no connection between the two. There are legacy chemicals, like in any product, in fact, because in the past, chemistry were not regulated the same way than today, and there was less understanding of what could be the potential cases, but there is no asbestos in our product. Asbestos is a mineral fiber. It is not a foam chemical. So, I mean, the connection between the two, for me, it's a little bit. I think it's more, yeah, it's mineral-based, and it has different application.

It was used as a thermal barrier, but not for application where today we use our thermal insulation. And I think-

Moderator

I presume that question was actually talking about when buildings are being repurposed and new insulation is being put in.

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

Ah, yeah .

Moderator

Yeah.

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

The whole construction sector concern, if you go for renovation, obviously, and actually the Renovation Wave focus and the energy performance building renovation obligation that will also enter into force in member states, will actually force renovation of the most the less effective buildings, which are the oldest that we have, obviously, where the chances to find asbestos is obviously there, but this is a deconstruction demolition issue as such from old buildings, not necessarily connected to the insulation, and maybe I would even say, since when do we use PU insulation? Probably 1970s, 1970s. I think that's probably the time also where we were transitioning away from asbestos, actually so there will be connection, but that's more related to the need to upgrade old buildings, which indeed could have asbestos, but that is not related basically to the material themselves.

It's more the process and the need to renovate. We need indeed to deal with what was there in the past. Yeah.

Moderator

Thank you. Now I have a question about replacement, a new regulation on trimerization catalyst, sorry, diluted into EH for rigid PIR being phased out.

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

Yeah

Moderator

If you have any thoughts on that.

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

We have thoughts, yes, we have solutions we have developed. Obviously, we are always very conscious of what can appear on a safety data sheet. We always try to make sure that we are on top of understanding how the regulation and the different chemicals will be looked at. So we looked at what are the alternatives, so we can offer alternative without basically the classification appearing on the safety data sheet. Yes. Yeah.

Moderator

Thank you. Now, I do have quite a few questions about non-EU markets, like North America and Asia Pacific, but this is specifically a webinar about EU regulations, so we are going to keep discussion to the EU. Here's another question: Do you think normal MDI will be banned as well? Do you expect low monomer, less than 0.1% free MDI PU foams, and no MDI foams are the far future for the PU industry?

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

I don't think so. I think definitely not in industrial and manufacturing environment. I think we have now a very well-thought and implemented regulation that obliges the proper training of any user of MDI to prevent, basically, exposure to the free MDI. I don't think that in the manufacturing environment there is a need to expect that it will be banned. Maybe application which are more, let's say, consumer-oriented, we could expect more stringent rules there. But it's very small, let's say, it's a small area of application of PU products. But for insulation, I mean, it's a very low lambda product.

It actually provides a lot of benefit to the building environment in terms of energy saving and so on. It is done in a controlled way. If you go to a plant with a laminator, there's very few workers, basically, that could even be exposed, and even those needs to be properly trained. So I don't think that's my opinion, but from, let's say, a manufacturing perspective, the potential risk of exposure, if we have all the elements in place, there should be no need to go further. And obviously, we are tracking, and we are going to be also scrutinized by the member state to make sure that everything is done properly. So I don't think that we have to fear, let's say, such a dramatic move, basically.

Moderator

Right. Well, thank you very much, and here concludes our Q&A session. I want to thank everybody in the audience for their lively and numerous questions. I hadn't seen so many before. There's a disclaimer on the screen now. I hope in just a minute we will be able to go back to the previous screen just so that we can, or that I can tell you that if you want to get in touch with Magda or with Shpresa, then just get your phone out, scan that QR code, and you'll have all the information you need there. So, thank you for attending this Urethanes Technology International webinar, hosted by Huntsman, or presented by Huntsman. We appreciate all your great questions. Thanks to Shpresa and Magda for a great presentation and answering so many of your interesting questions.

Obviously, if you want to contact Shpresa and Magda directly, I've told you how to do that. And as I've said before, you'll find today's presentation can be watched again by going to the Webinars section of the Urethanes Technology International website at utech-polyurethane.com. The presentation will be posted within 24 hours of today's webinar. And, yeah, you just click on the webinar link, Webinars tab on the website. So thank you all for attending, and we'll see you at a future webinar. Thank you very much.

Shpresa Krtari
EU Lead and Global Sustainability Senior Expert, Huntsman Polyurethanes

Thank you.

Magda Ceska
Senior Strategic Marketing, Huntsman Polyurethanes

Thank you. Bye-bye.

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