In June 2025, the UK Environment Agency published a flame retardant scoping review where 124 flame retardants (FRs) used in GB consumer products were assessed1. The review set out to establish priorities for further FR assessment at the same time as supporting the UK Government’s development of a strategy for FRs currently used in products.
This commentary provides the opinions of Fidra and The Cancer Prevention & Education Society (CPES) on the final published version of the Environment Agency’s 2025 Flame Retardant Scoping Review. Fidra and CPES sat on the advisory group for this work and provided feedback on earlier drafts of the report. After reading the final published report, Fidra and CPES think that the report does not sufficiently highlight high volume flame retardants currently under close scrutiny in the European Union. There is such a wealth of detail and tables that the reader risks to not see the wood for the trees. Here we review strengths and weaknesses of the report, exposing important flaws that may further widen the regulatory gap between the UK and EU countries.
Why flame retardants?
Differences in chemical restriction legislation between countries is becoming increasingly challenging to address as chemical exposure differs between countries depending on their approach to risk management of chemicals and waste disposal. The Environment Agency’s new report confirms the staggering amount of FRs used globally which continue to impact the sustainability and health of modern society. It states that “Worldwide consumption of FRs was around 3.18 million tonnes in 2020 (Pinfa, 2021)” and that “European consumption amounted to 452,000 tonnes in 2015 (Pinfa, 2017).”
The UK’s overall chemical flame retardant consumption is estimated to be up to 826,000 tonnes/year, representing approximately 26% of the global total1, 2.
Strengths – raising awareness of toxic and persistent chemicals and their impacts on product circularity
The Environment Agency’s FR review predicted some of the highest risks for organophosphorus FRs, where there is a large body of evidence connecting these chemicals with detrimental impacts to public and environmental health. This review was welcomed as a much-needed update of the Environment Agency’s 2003 ‘Prioritisation of flame retardants for environmental risk assessment’ report3. It was also produced to meet a commitment under the UK Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) programme to review current evidence of potential risks posed by flame retardants used in or relevant to the GB market.
The study identified substances that should be prioritised for further assessment based on volumes used (tonnages) and identified hazards and potential risks to the environment, taking existing environmental monitoring data into account. Follow-up investigations of substances identified as highest priority are expected to be undertaken by the Environment Agency and UK Government hazardous substances advisory committee.
Fidra and CPES welcome mention of the 2019 inquiry into Toxic Chemicals in Everyday Life by the UK Parliament’s Environmental Audit Committee4 and striving for a non-toxic UK environment, improvements to support the circular economy and chemical transparency for consumers.
Raising awareness of the impact of FRs on product circularity was also a strength of the Environment Agency’s review but the term ‘Recycling’ was used very broadly as it included incineration for energy recovery. The report acknowledged the ongoing challenges associated with chemical FRs classified as persistent organic pollutants (POPs) that contaminate waste materials and hinder the UK’s circular economy ambitions. Technological developments in POPs contaminated waste detection and separation were also mentioned but there was a lack of detail and supporting evidence for readers. The amount of waste upholstered domestic seating in the UK requiring incineration, with similar values estimated and reported recently by Fidra5 was also presented: “approximately 250,000 tonnes of upholstered domestic seating waste is produced every year”
Weaknesses – unanswered questions
The review screened GB relevant flame retardants and because of its length and detail it appears to be thorough and robust, but on closer inspection several weaknesses have been identified.
Limited literature was reviewed as part of the FR scoping review and one research paper cited provided evidence of concerning developmental neurotoxicity caused by organophosphate ester FRs6. The listing of important UK exposure and contamination studies is important, but they were unfortunately delegated to an Appendix. There are hundreds of papers in the scientific literature reporting developmental, metabolic, neurotoxic, endocrine disrupting and other effects of FRs, and many studies show effects at environmentally relevant concentrations7, 8.
Although an exhaustive literature review was outside the scope of the project, these studies should be considered as part of follow-up work on specific FR substances or groups. Fidra and CPES also recommend that new predicted no effect concentration (PNEC) values should be accounted for in the future and that UK and EU chemical restrictions are aligned when research evidence flags concerns around health impacts posed by chemicals.
Fidra and CPES strongly recommend that any follow-up work by the UK Government include the high-volume chemicals TCPP and DBDPE as the 2025 review has not sufficiently stressed the scrutiny that these chemicals are now undergoing. Firefighters, recyclers and manufacturers have elevated occupational exposure to these chemicals, particularly DBDPE9, 10. Furthermore, due to delays in publication, information used to produce the report may now be outdated, demonstrating a missed opportunity to highlight current issues from these widely used chemicals. For example, the report failed to include ‘POPs & EU REACH’ status information for the brominated chemical TBPH. Shortly before publication of this report, the EU’s European Chemicals Agency (ECHA) proposed that TBPH be listed as a new POP11. Also, ECHA have now identified TPhP as a substance of very high concern (SVHC) and included it in the candidate list for authorisation11.
Although the report noted that eleven FRs had already been screened through the EA Prioritisation and Early Warning System (PEWS), only two (Trixylyl phosphate and TBBPA) were ranked as high priority in their FR scoping review with Trixylyl phosphate being used in relatively low volumes compared to TCPP and DBDPE. The review gave low overall rankings for TCPP and DBDPE, thereby downplaying the current ongoing evaluations of these chemicals by ECHA11.
The high volume FRs TCPP and DBDPE were given low scores based on the risk characterisation ratios (RCRs). A 2-year study by the US National Toxicology Program confirmed that TCPP chronic exposure led to a statistically significant increase in the incidence of liver tumours in mice12. While the Environment Agency’s FR review cited this important study, the cancer risks identified were not sufficiently stressed.
As stated in the EA report, TCPP is the most detected organophosphate ester in UK rivers, such as the Rivers Thames and Aire13–15. Does an RCR < 1 mean that UK rivers are ‘sub-optimally’ contaminated and that nothing will be done by the environmental regulators until levels exceed the PNEC? Flame retardants were not present in rivers and lakes until comparatively recently, so we do not consider this would be a prudent approach to managing pollutants.
In the case of DBDPE, this chemical has been shown by the Swedish Agency Kemi to be very persistent and very bioaccumulative (vPvB) and ECHA recently proposed its classification as a substance of very high concern (SVHC). The Environment Agency has critiqued the proposal whereas other countries (France, Germany, the Netherlands) have supported it11. Given DBDPE’s persistence and water insolubility, does this mean levels of DBDPE in sediment (where it is mainly found) will be allowed to rise unchecked? We were particularly concerned to read that, “1,1′-(Ethane-1,2-diyl)bis[pentabromobenzene] (DBDPE) is not included in the EA monitoring programme at the time of writing” given that this is the most used flame retardant in furniture textiles.
The widely referred to Norman ecotoxicology PNEC database16 was not used for this scoping review which may have weakened chemical risk assessments and priority rankings. For example, the PNEC for DBDPE in sediment used in the report is far higher (100 mg/kg (or 100,000 µg/kg) dry weight) than that in the Norman database (21.2 µg/kg dry weight). These discrepancies have implications on the risk (or RCR) calculations. Also, the PNEC for TCPP in freshwater used in the report was slightly higher (0.32 mg/L) than the Norman value (0.26 mg/L).
The sum of groups of chemicals (e.g. organophosphate FRs and/or brominated flame retardants)7 are not addressed in traditional risk assessment approaches, including this scoping report, as they are not generally used by regulators who look at individual chemicals only. This begs the question, what are the impacts of all the flame retardants combined that people and the environment are polluted with? We would welcome sum of chemical groups and cocktail effects (with other chemical pollutants) being included in future reports as research suggests that the risks posed to exposed organisms increase when chemicals are present as mixtures, as is often the case in environmental compartments such as soils and sediments where persistent chemicals accumulate17. Also, water contains sums of water soluble chemicals and Defra’s recent interim position statement acknowledged difficulties in assessing and managing risks individually for substances that are highly persistent and mobile18.
Important human health impacts evidence, including exposure to FRs from indoor air and dust, was not included in the FR scoping review19–22. Studies documenting human skin and respiratory sensitisation associated with FR exposure were not collated and used because they were not considered to be relevant to environmental concerns. But because humans spend most of their time in indoor environments this is a major omission in this report.
Professor Stuart Harrad who also sat on the EA FR scoping review Advisory Group said “The study insufficiently considers exposures via indoor air and dust and there is no scientific justification for that whatsoever. This highlights the glaring hole in the UK’s approach to regulating chemicals – a lack of joined up thinking that the general public would find incomprehensible.”
Next regulatory steps
Even for chemical experts reading the report, it is hard to discern what chemicals the authorities are concerned about and will prioritise for regulatory action? We are particularly concerned that the chemicals TCPP and DBDPE might not be prioritised for regulatory action by the UK Government’s Health and Safety Executive because of the low RCR scores recorded in this report. We consider this to be of major concern given the high-volume use of these chemicals in mattress and furniture foam and textiles.
Keeping pace with other European countries
Environmental charities and some manufacturers are acutely aware that UK chemical restrictions (UK REACH) are lagging behind the EU and that the UK should keep pace with the EU chemical restrictions (EU REACH). Weaknesses identified in this latest report provide further evidence of the ongoing failings around human and environmental exposure to flame retardants and insufficient measures to provide protection.
While the EU takes steps to act on chemical flame retardants, notably persistent brominated aromatic flame retardants 23, the UK continues to lag behind. In the time it has taken Defra to agree to a restriction on lead in ammunition, the EU has adopted 13 restrictions on harmful chemicals, [adopted new classifications for identifying substances that interfere with the hormone system and other harms] and banned bisphenols in food contact materials24, 25.
Professor Heather Stapleton, Environmental chemist and exposure scientist at Duke University, Durham, North Carolina explained that “The ongoing use of halogenated and organophosphate flame-retardant chemicals in consumer products, textiles and building materials is a major concern, particularly in indoor environments. Vulnerable populations, including children and firefighters, are receiving higher exposures with potentially harmful impacts on their health.”
Our asks
As with all assessments of risks posed to public and environmental health, the growing emergence of new improved data following the completion of work, potentially affects the relative ranking of specific substances in the future. As acknowledged by the authors of the FR scoping review, the prioritisation of chemicals based on hazard potential reflects the information available at the time of compilation in 2024. Fidra and CPES request that future assessments include the latest available information. The report risks being too ‘static’ and will need to be continuously updated as new information comes in about these chemicals.
We also call for sustainable fire safety in the UK and asks that the UK Government addresses chemical barriers to the circular economy and the repeated cycle of moving from one phased-out flame retardant to poorly studied alternatives (so called regrettable substitution). Fidra’s Sustainable Fire Safety project calls for an urgent update of the UK’s furniture fire safety regulations to reduce the use of FRs. This is echoed by many other organisations.
Stay informed about the latest scientific evidence and chemical policy developments by following us on social media and sign up to Fidra’s newsletter. Consider contacting your local MP to raise concerns around unnecessary chemical flame retardants in furniture and ask for sustainable fire safety regulations.
References
1. Environment Agency (2025) Flame retardant scoping review Chief Scientist’s Group report Retrieved online September 17, 2025 from: https://www.gov.uk/government/publications/flame-retardant-scoping-review.
2. Health and Safety Executive (2025) UK registration, evaluation, authorisation and restriction of chemicals (REACH) Retrieved online March 5, 2025 from: https://www.hse.gov.uk/reach/.
3. Environment Agency (2003) Prioritisation of flame retardants for environmental risk assessment Retrieved online September 5, 2025 from: https://assets.publishing.service.gov.uk/media/5a7c8bae40f0b62aff6c26cd/scho1008bote-e-e.pdf.
4. Toxic Chemicals in Everyday Life – Environmental Audit Committee – House of Commons Retrieved online August 21, 2024 from: https://publications.parliament.uk/pa/cm201719/cmselect/cmenvaud/1805/180502.htm.
5. Fidra (2025) Plugging the chemical transparency gap for a safer circular economy – Furniture Supply Chains Retrieved online May 30, 2025 from: https://www.fidra.org.uk/download/case-studies-plugging-the-chemical-transparency-gap/.
6. Patisaul HB, Behl M, Birnbaum LS, Blum A, Diamond ML, Rojello Fernández S, Hogberg HT, Kwiatkowski CF, Page JD, Soehl A, & Stapleton HM (2021) Beyond Cholinesterase Inhibition: Developmental Neurotoxicity of Organophosphate Ester Flame Retardants and Plasticizers. Environ Health Perspect 129(10) 105001, https://doi.org/10.1289/EHP9285.
7. Yu D, Hales BF, & Robaire B (2025) Effects of an environmentally relevant mixture of organophosphate esters on the phenotype and function of HepG2 liver cells Arch Toxicol, https://doi.org/10.1007/s00204-025-04173-2.
8. Page J, Whaley P, Bellingham M, Birnbaum LS, Cavoski A, Fetherston Dilke D, Garside R, Harrad S, Kelly F, Kortenkamp A, Martin O, Stec A, & Woolley T (2023) A new consensus on reconciling fire safety with environmental & health impacts of chemical flame retardants Environ Int, https://doi.org/10.1016/j.envint.2023.107782.
9. Estill CF, Mayer AC, Chen I-C, Slone J, LaGuardia MJ, Jayatilaka N, Ospina M, Sjodin A, & Calafat AM (2024) Biomarkers of Organophosphate and Polybrominated Diphenyl Ether (PBDE) Flame Retardants of American Workers and Associations with Inhalation and Dermal Exposures Environ Sci Technol 58(19) 8417–8431, https://doi.org/10.1021/acs.est.3c09342.
10. Levasseur JL, Hoffman K, Herkert NJ, Cooper E, Hay D, & Stapleton HM (2022) Characterizing firefighter’s exposure to over 130 SVOCs using silicone wristbands: A pilot study comparing on-duty and off-duty exposures Science of The Total Environment 834 155237, https://doi.org/10.1016/j.scitotenv.2022.155237.
11. European Chemicals Agency (ECHA) Retrieved online September 17, 2025 from: https://echa.europa.eu/.
12. National Toxicology Program (2023) NTP Technical Report on the Toxicology and Carcinogenesis Studies of an Isomeric Mixture of Tris(chloropropyl) Phosphate Administered in Feed to Sprague Dawley (Hsd:Sprague Dawley® SD®) Rats and B6C3F1/N Mice , https://doi.org/10.22427/NTP-TR-602.
13. Wang R, Biles E, Li Y, Juergens MD, Bowes MJ, Jones KC, & Zhang H (2020) In Situ Catchment Scale Sampling of Emerging Contaminants Using Diffusive Gradients in Thin Films (DGT) and Traditional Grab Sampling: A Case Study of the River Thames, UK Environ Sci Technol 54(18) 11155–11164, https://doi.org/10.1021/acs.est.0c01584.
14. Onoja S, Abdallah MAE, & Harrad S (2023) Concentrations, spatial and seasonal variations of Organophosphate esters in UK freshwater Sediment Emerg Contam, https://doi.org/10.1016/j.emcon.2023.100243.
15. Cristale J, Katsoyiannis A, Sweetman AJ, Jones KC, & Lacorte S (2013) Occurrence and risk assessment of organophosphorus and brominated flame retardants in the River Aire (UK) Environmental Pollution 179 194–200, https://doi.org/10.1016/j.envpol.2013.04.001.
16. NORMAN Ecotoxicology Database Retrieved online September 17, 2025 from: https://www.norman-network.com/nds/ecotox/.
17. Hough R (2024) Using new contaminants information to re-assess environmental risks from sewage sludge Retrieved online December 5, 2024 from: https://www.fidra.org.uk/download/james-hutton-institute-re-assessment-of-environmental-risks-from-sewage-sludge/.
18. DEFRA (2025) Interim position statement on the approach to PMT concept to support UK REACH risk management of PFAS Retrieved online July 16, 2025 from: https://www.gov.uk/government/publications/interim-position-statement-on-the-approach-to-pmt-concept-to-support-uk-reach-risk-management-of-pfas.
19. Brommer S, & Harrad S (2015) Sources and human exposure implications of concentrations of organophosphate flame retardants in dust from UK cars, classrooms, living rooms, and offices Environ Int 83 202–207, https://doi.org/10.1016/j.envint.2015.07.002.
20. Gbadamosi MR, Abdallah MAE, & Harrad S (2022) Organophosphate esters in UK diet; exposure and risk assessment Science of the Total Environment, https://doi.org/10.1016/j.scitotenv.2022.158368.
21. Ma Y, Stubbings WA, Jin J, Cline-Cole R, Abdallah MAE, & Harrad S (2024) Impact of Legislation on Brominated Flame Retardant Concentrations in UK Indoor and Outdoor Environments: Evidence for Declining Indoor Emissions of Some Legacy BFRs Environ Sci Technol 58(9) 4237–4246, https://doi.org/10.1021/acs.est.3c05286.
22. Ortiz Y, & Harrad S (2023) Organophosphate esters in indoor and outdoor air in Birmingham, UK: implications for human exposure Journal of Environmental Exposure Assessment, https://doi.org/10.20517/jeea.2023.20.
23. European Chemicals Agency (ECHA) (2024) Investigation Report on Aromatic Brominated Flame Retardants.
24. Fidra Fidra’s Alignment Position Retrieved online September 17, 2025 from: https://www.fidra.org.uk/download/chemical-alignment-uk-eu-reach/.
25. CHEMTrust UK/EU differences in environmental/health protections from harmful substances since 1/1/2021 Retrieved online September 17, 2025 from: https://chemtrust.org/divergence-table/.