Chemicals and the Circular Economy: What’s the Solution?

Our new Evidence Review demonstrates how chemicals of concern, such as chemical flame retardants (CFRs), can undermine product recycling initiatives. But solutions are possible. Using mattress recycling as a case study, we review ways to improve current chemical management practises and ensure better protection for public health, the environment, and the circular economy.

Chemical Transparency and Traceability

Chemical transparency and traceability could help realise a profitable circular economy with benefits to business, human health, and the environment at its heart. Access to full chemical content data along supply chains would allow appropriate reuse, recycling, and disposal of products, and prevent newly regulated or restricted chemicals from undermining material safety. Providing information to all parties along supply chains could further empower retailers and manufacturers wishing to take greater ownership of the chemical substances used in their products, as well as stimulating prospects for trade of recycled materials.

Demand for chemical transparency is growing globally. The Government of Canada recently confirmed their intention to improve product labelling of toxic chemicals, including CFRs used in upholstered furniture, as part of a broader strategy to improve supply chain transparency (1; 2). In the EU, a letter was sent by 23 investors, representing €4.1 trillion, to 50 leading chemical producers calling for greater transparency (3). This was followed by another letter in 2022 written by the International Chemical Secretariat, ChemSec, and seven major companies that was sent to the European Commission, highlighting the importance of chemical transparency for companies to deliver their sustainability commitments and future-proof their operations against potential upcoming restrictions (4). It read, “…we want to emphasise that there is one outstanding issue where your support could make the most difference in our strive towards proactive chemicals managementThis is to raise the legal obligations for transparency when it comes to information on chemical content…”. In research conducted by Fidra, UK retailers also consistently highlighted greater transparency of chemical content as an important factor in simplifying their own chemical management (5), and in a 2023 academic consensus paper, developing a “labelling system for tracking the use of chemicals in products, including flame retardants” was one of the key recommendations for the UK government to protect the circular economy from “undesirable substances” (6).

Technological developments to help track product information and improve supply chain transparency using ‘smart labelling’ are already underway. Technologies such as Radio-Frequency Identification (RFID) and blockchain have demonstrated great potential for improving waste management across the electronic, textile, and building industries, allowing large quantities of product data to be accessible along supply chains whilst protecting competitively sensitive information (7; 8; 9). The dynamic nature of smart labelling could also ensure chemical data is reactive to new research and remains aligned with the latest recommendations and restrictions, offering longer-term protection for people, the environment, and the circular economy.

Extended Producer Responsibility Schemes

Extended Producer Responsibility schemes (EPRs) are environmental policy measures that shift responsibility for the management of waste products back on to producers. This aims to incentivise sustainable product design and encourage producers to consider End-of-Life product management, promoting products that are easier to reuse and recycle (10). Numerous efforts towards increased recycling rates and EPR schemes for mattresses are already underway across the EU. For example, the Dutch company RetourMatras has introduced a fully automated mattress treatment plant capable of processing 190,000 mattresses per year (11). The Netherlands is also set to introduce an EPR scheme that aims to reach a 75% mattress recycling target by 2028 (11).  The National Bed Federation (NBF) recently supported the call for a UK mattress EPR scheme, deeming it essential for meeting current waste management targets (12).

EPR schemes also have the potential to promote sustainable chemical use. With incentives in place to ensure products are made sustainable by design, producers could be encouraged to take greater consideration of chemical content. This in turn could push improved chemical transparency and traceability higher up the agenda, giving producers greater control over their products and the ability to meet self-assigned or Government-led sustainability targets. EPR schemes could also reward those with existing commitments towards chemical sustainability and stimulate further product innovation.

Improved Furniture and Furnishings Fire Safety Regulations

The current UK furniture and furnishings fire safety regulations have been consistently challenged over their effectiveness and contribution towards unnecessarily high use of CFRs in products. The Environmental Audit Committee’s (EAC) 2019 report, Toxic Chemicals in Everyday Life, criticized the UK’s current furniture fire safety standards as being outdated and in need of reform. The report outlined how, whilst fatalities from UK house fires have undoubtedly decreased since the regulations were introduced in 1988, other countries with no or less prescriptive furniture fire safety requirements, such as New Zealand and those across the EU, had shown similar fatality trends as the UK (13).

Other contributions towards the UK’s success in reducing fire fatalities over the last 30 years include increased smoke alarm ownership in England and Wales, which increased from 8% to 90% between 1988 and 2017 (14). The rate of smoking over this time period has also almost halved (15); smoking materials are consistently recorded within the top three causes of accidental house fire across England (16). Conversely, inhalation of toxic fire smoke, exacerbated by the presence of CFRs, has been claimed to cause the majority of fire deaths and injuries since the 1990s (17). Research commissioned by the EU and individual member states concluded that there is not enough evidence to support the claim that flammability requirements, such as those in the UK, actually lead to fewer fire deaths (13; 18). This was supported by a 2023 academic consensus paper on the role of CFRs in fire safety which concluded that there was significant uncertainty about whether and to what extent flame retardants contribute to fire safety(6).

Modern research and global case studies demonstrate that effective fire safety without unnecessary use of flame-retardant chemicals can be achieved. Amendments to current furniture fire safety regulations, in line with understanding of modern furniture construction and fire risks, could therefore reduce the burden of chemical exposure on people, the environment, and the circular economy, whilst simultaneously stimulating product innovation and competitive growth for industry (13; 19).

Evidence Review

Fidra’s case study of CFR use in mattresses highlights the potential impacts of chemicals of concern within recycling initiatives, as well as positive opportunities to demonstrate workable solutions. Our new Evidence Review investigates how EPR schemes, increased chemical transparency and traceability, and changes to the UK’s furniture and furnishings fire safety regulations, could help reduce reliance on CFRs, incentivise innovative and sustainable product design, and support successful, long-term recycling initiatives.

Evidence Review

Evidence Review Summary

If you are a mattress manufacturer, retailer or recycler and would like to be involved in our on-going work, please contact the Fidra team via:


Read other blogs in this three-part series:

Chemicals and the Circular Economy: What’s the problem?

Chemicals and the Circular Economy: A Mattress Case Study



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2. Chemical Watch. (2023) What next for chemicals regulation in Canada? Available at: (Accessed: 24th January 2023).

3. REUTERS. (2021) Investors push world’s top chemicals companies over hazardous substances. Available at: (Accessed: 24th January 2023).

4. ChemSec. (2022) Open letter to the Commission regarding transparency. Available at: (Accessed: 24th January 2023).

5. Fidra. (2021) How UK retailers are tackling chemicals of concern: A case for group-based chemical legislation. Fidra.

6. Page, J., Whaley, P., Bellingham, M., Birnbaum, L.S., Cavoski, A., Dilke, D.F., Garside, R., Harrad, S., Kelly, F., Kortenkamp, A. and Martin, O. (2023) ‘A new consensus on reconciling fire safety with environmental & health impacts of chemical flame retardants.’ Environment international, 173, p.107782.

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10. EXPRA. (2016) Extended Producer Responsibility Alliance (EXPRA). Extended Producer Responsility at a Glance. EXPRA.

11. EUROPUR. (2021) The end-of-life of flexible polyurethane foam from mattresses and furniture. EUROPUR.

12. Oakdene Hollins for National Bed Federation. (2022) End-of-life mattress report 2022. Oakdene Hollins.

13. House of Commons, Environmental Audit Committee. (2019) Toxic Chemicals in Everyday Life. House of Commons, Environmental Audit Committee.

14. Home Office. (2022) Percentage of households owning a smoke alarm or a working smoke alarm by nation. Home Office.

15. NHS. (2020) Statistics on Smoking 2020. Available at: (Accessed: 20th January 2023)

16. Home Office. (2017) Fire statistics: Cause of fire. Available at: (Accessed: 20th January 2023).

17. McKenna, S.T., Birtles, R., Dickens, K., Walker, R.G., Spearpoint, M.J., Stec, A.A. and Hull, T.R. (2018) ‘Flame retardants in UK furniture increase smoke toxicity more than they reduce fire growth rate.’ Chemosphere, 196, pp.429-439.

18. ANSES. (2015) OPINION of the French Agency for Food, Environmental and Occupational Health & Safety concerning the “request regarding the fire safety of domestic upholstered furniture”. ANSES.

19. Charbonnet, J.A., Weber, R. and Blum, A. (2020) ‘Flammability standards for furniture, building insulation and electronics: Benefit and risk.’ Emerging Contaminants, 6, pp.432-441.