Spray Foam Insulation Complaints
Case reference FOI2026/02086
Received 1 September 2026
Published 30 September 2026
Request
For each of the financial years 2021/22, 2022/23, 2023/24, 2024/25 and 2025/26, please provide the following information relating to spray foam insulation, including its sale, installation or removal:
1. The number of complaints, referrals or intelligence reports recorded by your Trading Standards service concerning spray foam insulation.
2. The number of investigations opened by your Trading Standards service concerning spray foam insulation.
3. For the five most recent complaints or cases concerning spray foam insulation, please provide a brief summary of each case, including, where recorded, how the consumer was approached, what they were told, any amount paid or lost, any consequences for the consumer, and any action taken by Trading Standards.
For question 3, I am only requesting information already recorded by the authority. I am not asking the authority to create new information, carry out additional analysis or infer information that is not recorded. Please redact any information necessary to prevent individual consumers from being identified.
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If the information requested in question 2 is not held in a readily retrievable form, please provide questions 1 and 3 only.
If your authority records spray foam insulation under a different terminology or category, please provide the closest equivalent information held.
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Response
For each of the financial years 2021/22, 2022/23, 2023/24, 2024/25 and 2025/26, please provide the following information relating to spray foam insulation, including its sale, installation or removal:
1. The number of complaints, referrals or intelligence reports recorded by your Trading Standards service concerning spray foam insulation.
Answer: The Service Area have advised these figures represent records categorised by the authority as complaints, referrals or intelligence reports relating to spray foam insulation. A recorded report does not necessarily represent a substantiated breach of legislation, a separate consumer or a matter that resulted in a formal investigation:
21/22 - 29
22/23 - 27
23/24 - 24
24/25 - 29
25/26 - 24
2. The number of investigations opened by your Trading Standards service concerning spray foam insulation.
Answer: The Service Area have advised these figures represent investigations recorded by the authority. They should not be interpreted as indicating that an offence was established in every case.
21/22 - 2
22/23 - 0
23/24 - 2
24/25 - 2
25/26 - 1
3. For the five most recent complaints or cases concerning spray foam insulation, please provide a brief summary of each case, including, where recorded, how the consumer was approached, what they were told, any amount paid or lost, any consequences for the consumer, and any action taken by Trading Standards.
For question 3, I am only requesting information already recorded by the authority. I am not asking the authority to create new information, carry out additional analysis or infer information that is not recorded. Please redact any information necessary to prevent individual consumers from being identified.
Answer: Please see below:
1. Recent complaint
• Consumer: An elderly consumer whose loft contained spray foam insulation.
• Reported approach: The consumer received an unsolicited telephone call. The caller was reported to have stated that the company was working with government to address spray foam issues and offered a free survey.
• Action taken: The consumer told a family member about an appointment arranged for the following day. The family member contacted Trading Standards after being unable to cancel the appointment because the calling number did not accept incoming calls.
• Outcome: A Trading Standards officer attended at the appointment time and informed the visiting ‘surveyor’ that the appointment would not proceed. No contract was entered into and no payment was made. The potential contract value was estimated at approximately £5,000.
2. Recent complaint
• Consumers: Two elderly consumers.
• Reported approach: A family member reported that the consumers had received an unsolicited telephone call and agreed to a home visit. During the visit, a ‘surveyor’ stated that moisture readings in the roof timbers were high and that the spray foam required urgent removal.
• Contract and payment: A contract exceeding £5,500 was agreed for spray foam removal and installation of foil insulation. The consumer signed an agreement for work to begin within the 14-day cancellation period, paid a deposit of £1,100 and work started the following day.
• Action taken: Trading Standards was contacted while the work was under way. An officer advised the family to request completion of the spray foam removal only and not installation of the foil insulation. The company requested a further £3,600 to continue the removal work and referred to possible debt recovery when payment was declined. Trading Standards contacted the company and disputed the further payment and the price charged.
• Outcome: The company then stopped work, leaving removed foam on the loft floor and some foam in place. Trading Standards is seeking a partial refund of the deposit. The family was advised that no further payment should be made and was given information about options for completing the removal themselves.
3. Recent complaint
• Consumers: Two elderly consumers.
• Reported approach: A family member reported that the consumers had received an unsolicited telephone call from a caller who stated that they were contacting them on behalf of Herefordshire Council. The caller reportedly said that a survey was required to check the property's Energy Performance Certificate and insulation.
• Appointment: An appointment was arranged for the following day. The consumers' telephone number was registered with the Telephone Preference Service, and the calling number did not accept incoming calls.
• Outcome: A Trading Standards officer attended the property at the appointment time and informed the visiting ‘surveyor’ that the appointment would not proceed. No contract was entered into and no payment was made.
4. Recent complaint
• Consumer and value: Another local authority reported a complaint from an elderly consumer who had paid more than £7,000 for spray foam removal and installation of foil insulation.
• Reported approach: The consumer was reported to have received an unsolicited call to a telephone number registered with the Telephone Preference Service. It was alleged that statements made during the sales process led the consumer to enter the contract and that the work was carried out within the 14-day cancellation period.
• Reported consequence: When the foil insulation was later lifted, spray foam was reported to remain in place.
• Business address: The business used a mailbox address in Herefordshire but was reported to operate from another area.
• Action taken: The other local authority is continuing its investigation. No action by this authority is recorded in the information provided.
Please be advised the fifth complaint has been withheld because we consider this information to be exempt under Section 30 (i) (b) of the Freedom of Information Act 2000 which exempts information if it has, at any time, been held by the public authority for the purposes of any investigation which is conducted by the authority and in the circumstances may lead to a decision by the authority to institute criminal proceedings which the authority has the power to conduct.
This exemption is subject to the public interest test, and accordingly, I have weighed up the reasons for and against disclosure in the public interest as follows:
Reasons for disclosure:
Openness and transparency regarding the council's investigation in this case. In a democratic society it is important that offences can be effectively investigated and appropriate action taken and transparency would allow the public to see that an investigation is being properly carried out.
Reasons for non-disclosure:
The information relates to an ongoing investigation which may lead to criminal proceedings under The Consumer Protection From Unfair Trading Regulations 2008 & Fraud Act 2006. Disclosure under the Freedom of Information Act 2000 is essentially a disclosure to the world at large not just to the individual requesting it. If the information were disclosed now, before the investigations have concluded, it would prejudice the council's ability to carry out its investigations effectively and prejudice any further actions that the council may take in the future.
There is a public interest in maintaining a process which is fair to individuals who are being investigated but have not, to date, had any further actions taken against them. If the information were disclosed and proceedings were later taken, it would prejudice the ability for evidence to be heard impartially and this would ultimately prejudice the ability for any further proceedings to be fairly conducted.
The public needs to have confidence in the ability of responsible public authorities to uphold the law and disclosure would not serve that purpose. There is a public interest in ensuring that transparency does not undermine or prejudice an authority's ability to properly investigate allegations or offences or to take formal action such as prosecution where appropriate.
Taking the above into consideration, I find the balance in favour of disclosure of the information is outweighed by the public interest in non-disclosure. Please take this letter as a refusal notice under S17 of the Act.
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If the information requested in question 2 is not held in a readily retrievable form, please provide questions 1 and 3 only.
If your authority records spray foam insulation under a different terminology or category, please provide the closest equivalent information held.
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Documents
This is Herefordshire Council's response to a freedom of information (FOI) or environmental information regulations (EIR) request.
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