Silesia Anti-Smog Resolution and PIR Thermal Upgrades

Q: Can termPIR® AL be used in ETICS?

No. termPIR® AL has a gas-tight aluminium facing that provides neither the adhesion nor the vapour permeability required in ETICS systems. For façade insulation finished with thin-coat render, the dedicated product is termPIR® ETX with glass fleece, covered by ETA 17/0066. Using the wrong facing leads to render delamination and loss of the system warranty.

Q: Does a thermal upgrade have to be reported to CEEB?

CEEB registers heat sources, not the thermal upgrade itself. If a boiler is replaced during the upgrade, the new appliance must be reported in CEEB within 14 days of commissioning. Insulating the envelope (roof, walls) does not require a separate CEEB declaration, but it often requires notification of construction works to the local authority under the Construction Law.

Q: Where can I find funding for home insulation in the Silesian Voivodeship?

For single-family buildings, the main programme is Czyste Powietrze (Clean Air, run by NFOŚiGW), which co-finances boiler replacement and thermal upgrades — including PIR board insulation. Lower-income owners can use the Stop Smog programme, run by municipalities. Additionally, the thermal modernisation tax relief is available in PIT (up to PLN 53,000 deductible from the tax base per person). Local municipal grant schemes also operate.

Fighting smog in Silesia — new regulations and the role of thermal upgrades

The Silesian Voivodeship is entering a new phase in the fight against low-stack emissions. From 1 January 2022, the region bans the use of off-class solid-fuel boilers — the so-called “smokers” (kopciuchy). Meanwhile, research by Polski Alarm Smogowy (Polish Smog Alert) shows that one in three residents of the region has not heard of the new rules, and 44% of single-family homeowners are unaware of the obligation to register their heat source in CEEB (Central Building Emissions Register). Effective emission reduction is not just about replacing the boiler — it also requires a comprehensive thermal upgrade of the building envelope in line with WT 2021 (Polish Technical Conditions 2021).

The Silesian anti-smog resolution — timeline and sanctions

The 2017 anti-smog resolution of the Silesian Voivodeship Assembly introduces a phased elimination of the most polluting heat sources. The key date for building owners is 1 January 2022 — from this day, using off-class (classless) boilers constitutes an offence punishable by a fine of up to PLN 500, or up to PLN 5,000 in court proceedings.

The schedule of subsequent phases is as follows:

Date	What is no longer permitted
01.01.2022	Off-class boilers (kopciuchy)
01.01.2023	Class 3 boilers per PN-EN 303-5:2012
01.01.2026	Class 4 boilers per PN-EN 303-5:2012
01.01.2028	Class 5 boilers per PN-EN 303-5:2012 (other than ecodesign)

In practice, this means tens of thousands of buildings across Małopolska and Silesia will need their heat sources replaced. The same applies to the Kraków metropolitan area and its surroundings — the region in which BOKKA operates as a distributor — where the ban on burning solid fuels has been in force since 1 September 2019.

CEEB — the building owner’s obligation

The Central Building Emissions Register (CEEB), maintained by the General Office of Building Supervision, collects data on heat sources in buildings with a nominal capacity of up to 1 MW. The obligation to file a declaration lies with the owner or property manager and covers:

Declaration A — for residential buildings,
Declaration B — for non-residential buildings.

Failure to file on time is punishable by a fine of up to PLN 500, or up to PLN 5,000 in court proceedings. CEEB data forms the basis for planning support programmes (including Czyste Powietrze — Clean Air, and Stop Smog) and for the enforcement of anti-smog resolutions by municipal and city guards.

WT 2021 — requirements that translate into air quality

In parallel with anti-smog measures, tightened Technical Conditions (WT 2021) apply, requiring significantly higher energy efficiency from new and deeply renovated buildings since 1 January 2021. Maximum thermal transmittance (U) values:

Building element	U_max per WT 2021
Roof, flat roof	0.15 W/m²K
External wall	0.20 W/m²K
Floor slab above unheated cellar/garage	0.25 W/m²K
Ground-bearing floor	0.30 W/m²K

The tighter and better-insulated the envelope, the lower the building’s final energy demand — meaning less fuel burned in the boiler (even a modern, ecodesign unit) and lower emissions of PM10, PM2.5 and CO₂.

PIR boards in the thermal upgrade of buildings covered by the anti-smog resolution

A key challenge in retrofitting existing single-family housing in the Silesian and Małopolska voivodeships is limited structural space — low attics, narrow eaves, proximity to plot boundaries, cornices. In this context, PIR boards offer a technological advantage over traditional materials:

λ_D = 0.022 W/(m·K) for termPIR® AL with gas-tight aluminium facing,
λ_D = 0.025–0.027 W/(m·K) for termPIR® ETX with glass fleece for ETICS (ETA 17/0066),
λ_D = 0.019 W/(m·K) for premium termPIR® MAX 19 AL.

A comparison of the insulation thickness required to achieve U = 0.15 W/m²K for a pitched roof (under the simplified assumption of a pure insulation layer):

Material	λ_D [W/(m·K)]	Thickness for U ≈ 0.15
termPIR® MAX 19	0.019	~12.5 cm
termPIR® AL	0.022	~14.5 cm
termPIR® ETX	0.026	~17 cm
Standard mineral wool	0.038	~25 cm
EPS 040 polystyrene	0.040	~26 cm

This means that when retrofitting a pitched roof with over-rafter insulation (system pitched roof — termPIR® over-rafter), WT 2021 requirements can be met without interfering with the roof geometry or the need to raise the ridge.

ETICS on external walls

For external walls finished with thin-coat render, the right choice is termPIR® ETX with vapour-permeable glass fleece — a product covered by European Technical Assessment ETA 17/0066 and dedicated to ETICS. termPIR® AL boards with aluminium foil are gas-tight and are not suitable for rendering — only the ETX variant must be used in ETICS (system external wall ETICS — termPIR® ETX).

Internal insulation — heritage buildings

In Silesian and Kraków tenement houses, where the conservation officer does not permit interference with the façade, termPIR® AL/GK is used — a PIR composite with gypsum plasterboard, bonded to the wall from the inside (system heritage wall — termPIR® AL/GK). The aluminium foil simultaneously acts as a vapour barrier.

Fire classification and standards

In the built-in system, termPIR® boards achieve fire reaction class B-s2,d0 per EN 13501-1, meeting the requirements for residential buildings in the ZL IV category. The products comply with EN 13165 (thermal insulation products for buildings — factory-made products of polyisocyanurate foam, PIR).

Frequently asked questions

Is a thermal upgrade mandatory when replacing a boiler under the anti-smog resolution?

Formally, the anti-smog resolution requires replacement of an off-class heat source but does not require a simultaneous thermal upgrade. From an operating-cost perspective, however, the two are complementary — an insulated building consumes up to 40–60% less final energy, meaning a shorter payback period on the new boiler and lower bills for decades to come. Programmes such as Czyste Powietrze (Clean Air) reward a comprehensive approach with a higher level of co-financing.

What PIR board thickness should be used on a pitched roof to meet WT 2021?

To achieve U ≤ 0.15 W/m²K on a pitched roof, typical thicknesses are 14–18 cm of termPIR® AL (λ_D 0.022) or 12–14 cm of termPIR® MAX 19 AL (λ_D 0.019), depending on the rafter structure and any existing between-rafter insulation. An over-rafter arrangement that eliminates thermal bridges requires less thickness than between-rafter insulation alone. Each project requires an individual calculation.

Can termPIR® AL be used in ETICS?

No. termPIR® AL has a gas-tight aluminium facing that provides neither the adhesion nor the vapour permeability required in ETICS systems. For façade insulation finished with thin-coat render, the dedicated product is termPIR® ETX with glass fleece, covered by ETA 17/0066. Using the wrong facing leads to render delamination and loss of the system warranty.

Does a thermal upgrade have to be reported to CEEB?

CEEB registers heat sources, not the thermal upgrade itself. If a boiler is replaced during the upgrade, the new appliance must be reported in CEEB within 14 days of commissioning. Insulating the envelope (roof, walls) does not require a separate CEEB declaration, but it often requires notification of construction works to the local authority under the Construction Law.

Where can I find funding for home insulation in the Silesian Voivodeship?

For single-family buildings, the main programme is Czyste Powietrze (Clean Air, run by NFOŚiGW), which co-finances boiler replacement and thermal upgrades — including PIR board insulation. Lower-income owners can use the Stop Smog programme, run by municipalities. Additionally, the thermal modernisation tax relief is available in PIT (up to PLN 53,000 deductible from the tax base per person). Local municipal grant schemes also operate.