Fidra response to Smarter Regulation: Fire safety of domestic upholstered furniture consultation

Fidra’s response to the ‘Smarter Regulation: Fire safety of domestic upholstered furniture’ consultation. We recognise that no significant change to these regulations has been made for 35 years and that an overhaul is well overdue and to be welcomed. This response has been submitted via the online system, but we wanted to take this opportunity to email our submission directly to you and summarise Fidra’s key asks and concerns.

• Quantifiable and time-lined reductions in product chemical flame retardant (CFR) use to enable meaningful CFR reductions that will protect human and environmental health.
• Need action to maintain and improve fire safety but flaming ignition testing hinders sustainable product design and innovation, fails to reduce reliance on CFRs and exacerbates the unnecessary chemical burden on the UK public and environment.
• The proposed ESRs will not change the current status quo and if flaming ignition testing cannot be immediately taken out of the standards, it must be phased out over time.
• A commitment to address fire smoke toxicity exacerbated by CFRs in furniture and impacts on UK fire injury and mortality rates.
• Must prevent regrettable substitution of CFRs and increased risks to consumers from harmful CFR exposure resulting from compliance with the UK’s slow paced chemical regulatory system, UK REACH.
• Enforcement of improved chemical transparency and traceability in products throughout their lifetimes to future-proof the UK’s safe circular economy and protect the environment.

Published, October 2023.