The legal requirements

Legal and regulatory compliance

Regulatory requirements for spray foam insulation focus on manufacturer certifications, proper installation by trained professionals, compliance with building standards, and providing appropriate documentation to homeowners.

Professional installation

Due to the hazardous chemicals and specific application process, it is strongly advised that spray foam insulation is installed by a trained, accredited professional. The National Insulation Association warns against DIY installation.

National recognised qualification

The ABBE Level 3 NVQ Diploma in Spray Foam Insulation and Application is the UK's first nationally recognised qualification for spray foam installers. It certifies individuals to apply spray foam insulation in both residential and commercial settings.

Professional credibility

While not legally required, having a recognised qualification can:

• improve customer trust
• reduce liability risks
• increase job opportunities

Manufacturer control

Spray foam manufacturers are legally responsible for approving and continuously monitoring their accredited installers.

Competence checks

The Construction (Design and Management) Regulations 2015 (CDM) apply to domestic contracts and require competence in the installation process. A lack of knowledge of these Regulations is an indication of an unqualified installer.

Product certification

The spray foam product used must hold an independent test certificate from a recognised body, such as the British Board of Agrément (BBA) or Kiwa.

A product with BBA or Kiwa certification is considered compliant with building regulations.

The installer should provide a manufacturer or insurance-backed warranty for the installation.

Building regulations

All installations must comply with national building standards, which are governed by a framework of building regulations:

• Building Regulations 2010 (these Regulations cover England and Wales)
• Building (Scotland) Regulations 2004

A set of approved documents (see below) provide guidance on ways to meet the building regulations, particularly those relating to moisture control, airtightness and ventilation.

Moisture management

Incorrect spray foam installation can trap moisture against roof timbers, leading to condensation, damp and rot.

Moisture plans should be in line with BS 5250: Management of moisture in buildings. Code of practice and the relevant sections of the building regulations.

Approved documents:

• England - Approved Document C
• Scotland - Section 3 of the Technical Handbook
• Wales - Approved Document C

Airtightness

Airtightness helps prevent moisture-laden air from entering colder roof spaces, which can condense and cause structural damage.

Airtightness plans should be in line with BS 5250 and the relevant sections of the building regulations.

Approved documents:

• England - Approved Document L
• Scotland - Section 3 of the Technical Handbook
• Wales - Approved Document L

Ventilation requirements

The installer must be aware of the specific ventilation needs of the property, as the installation of spray foam can affect how well outside air gets into the building. Spraying foam directly on the underside of roof tiles can be hazardous. Proper airflow is required, both pre- and post-installation.

Ventilation plans should be in line with BS 5250 and the relevant sections of the building regulations.

Approved documents:

• England - Approved Document F
• Scotland - Section 3 of the Technical Handbook
• Wales - Approved Document F

Industry bodies like the Insulation Manufacturers Association (IMA) and RICS also provide guidance relating to installations.

Protected / listed buildings

Listed buildings or protected structures require consent before installing spray foam installation. However, it is unlikely to be approved due to the permanent nature of the foam and its potential to cause damage to the property.

Consumer rights

Under the Consumer Rights Act 2015 (CRA), the installation service must be performed with reasonable care and skill, be fit for purpose, and meet satisfactory quality standards. If the work is substandard, consumers will have the right to a repeat performance or a price reduction.

For information on how the CRA applies to goods and services, please see 'Selling and supplying goods' and 'Supplying services'.

Under the Digital Markets, Competition and Consumers Act 2024 (DMCCA), it is illegal for traders to mislead consumers by act or omission, or to engage in aggressive sales practices.

The DMCCA gives the Competition and Markets Authority (CMA) powers to determine whether consumer law breaches have occurred, and to impose fines and order firms to pay compensation to affected consumers.

For more information on the DMCCA, see 'Protection from unfair trading (criminal law)'.

The Act will also provide a way for consumers to make a claim themselves. However, this part of the Act is not yet in force; claims are currently still covered by the Consumer Protection from Unfair Trading Regulations 2008 (CPRs).

For more information on the CPRs, please see 'Protection from unfair trading (consumers' rights of redress)'.

The Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013 (CCRs) require that pre-contract information is presented to consumers before any agreement is finalised. For off-premises or distance contracts, they also provide consumers with a 14-day cooling-off period before any work commences; this is particularly important if carrying out door-to-door or online sales of insulation services.

To find out how the CCRs affect your business, see:

• 'Consumer contracts: on-premises sales'
• 'Consumer contracts: off-premises sales'
• 'Consumer contracts: distance sales'

Record keeping

Homeowners should be provided with all paperwork related to the installation. This includes:

• contract details
• manufacturer's recommendations
• installation warranty
• independent test certificates (BBA / Kiwa)
• photographic evidence of the roof and timbers before, during and after installation

Spray foam insulation installation checklist

Pre-installation preparation:

• complete site survey. Assess structure, ventilation, moisture levels and suitability for spray foam
• advise homeowner to check with their mortgage provider before proceeding with installation
• consumer consultation and contract agreement. Discuss insulation type, coverage area and potential risks (for example, mortgage implications); obtain written approval
• confirm material. Choose between open-cell or closed-cell foam, based on thermal, acoustic and moisture needs
• review building regulations. Ensure compliance with the relevant sections of the building regulations for the appropriate nations of Great Britain, as well as other relevant building codes / standards
• put ventilation strategy in place. Plan for adequate airflow, both during and after installation
• complete health and safety risk assessment. Identify hazards and mitigation strategies
• check PPE and equipment. Confirm availability and condition of respirators, suits, gloves, goggles and spray rigs

Installation day procedures:

• secure area and put signage in place. Restrict access to work zone and display safety notices
• prepare substrate. Ensure surfaces are clean, dry and free of dust or oil
• activate ventilation. Use fans or extraction systems to maintain airflow
• apply spray foam in controlled layers. Follow manufacturer's guidelines for thickness and curing time
• monitor temperature and humidity. Maintain optimal conditions for foam adhesion and curing
• manage waste properly. Dispose of empty containers and overspray according to environmental regulations

Post-installation checks:

• observe curing time. Allow sufficient time before re-entry or further construction
• complete visual inspection. Check for gaps, uneven application or thermal bridging
• reassess ventilation. Ensure long-term airflow is not compromised
• client walkthrough and sign-off. Review work with client and provide care instructions
• finalise documentation. Include installation report, product information sheets and warranty information

Legislation, guidance documents and Standards, and how they relate to installation of spray foam insulation

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