No more confusion on the definition of a one-component-foam: all sizes of dispensing units are banned 1):
Over the past months, different interpretations have circulated on the definition of a One-Component Foam (OCF). As OCF is generally placed on the market in cans with a content of ? 1000 ml, the latter has been interpreted as a volume limit. It has been assumed by some that products fulfilling the definition of OCF in the F-Gas Regulation, but placed on the market in larger dispensing units, would not be covered by the ban in Annex III, point 8.
When this question was raised with the EU Commission, DG CLIMA gave the following clear answer: our view is that since the definition of OCF does not say anything on size of the “single aerosol dispenser”, there is also no limit to how large such an aerosol dispenser must or must not be for the purpose of the prohibition.
Whilst this guidance from the Commission has not been legally tested in Court, it appears to be a clear and definitive interpretation of the coverage of Annex III, point 8 of the F-gas Regulation.
1) Except when required by national safety regulations or that contain HFCs with a GWP of less than 150