Destroying POPs in waste upholstered domestic seating: SEPA offers guidance on reuse

In October 2023, the Scottish Environment Protection Agency (SEPA) released its much-anticipated guidance on the Management of Waste Upholstered Domestic Seating (WUDS) containing persistent organic pollutants (POPs). This was followed recently by their Reuse Activities and Waste Regulation guidance. Following in the Environment Agency’s footsteps and taking action to destroy POPs in WUDS, SEPA outlines strategies, regulations, and best practices for managing WUDS containing harmful POPs such as brominated flame retardants. Although this guidance is welcomed to advise on how best to identify POPS in WUDS, managing and detecting POPs is costly and not always straight forward.

Read on to find out more about SEPA’s POPs in WUDS guidance and why we are calling for chemical transparency throughout furniture supply chains and enforced chemical labelling for a safe circular economy.

Photo by Patrick Hendry on Unsplash

What are POPS and how do they end up in furniture?

Persistent organic pollutants (POPs) encompass a broad range of synthetic chemicals that, despite their invisible nature, pose significant threats to both ecological balance and human health[1]. These persistent chemicals include the legacy brominated chemical flame retardants, decabromodiphenyl ether (decaBDE) and hexabromocyclododecane (HBCD), that were used in furniture products to slow the spread of fires and meet prescriptive UK flammability regulations. DecaBDE was banned from use in all upholstered furniture in 2019[2], but due to the long-lived nature of furniture products, decaBDE and other banned legacy POPs in WUDS remain a modern-day challenge.

The problem with persistent organic pollutants is in the name – they persist in the environment for extended periods of time resisting degradation. This poses significant challenges to achieving a circular economy by impeding the reuse, recycling, and remanufacturing of products and materials, such as furniture and fabrics. The only way to destroy POPs is through hazardous waste incineration[3], which is why the Environment Agency (EA) and now SEPA, have enforced the incineration of WUDS containing POPs above certain concentrations [4],[5].

Managing POPs in Scotland’s waste upholstered domestic seating 

In October 2023, SEPA, in alignment with the EA, prohibited the landfill disposal of WUDs due to concerns regarding the presence of POPs at high concentrations[5]. A study commissioned by the EA highlighted that concentrations of brominated flame retardants, and other POPs, in upholstered domestic seating can be four times higher than the legal threshold concentration (1000 mg/kg)[6]. Fidra welcomes SEPA’s mandate that POPs contaminated WUDS must undergo incineration. This proactive measure diverts POPs-contaminated furniture away from landfills, averting potential environmental pollution.

More recently, in March 2024, SEPA released further Reuse activities and Waste Regulation guidance explaining how to detect and manage POPs in waste such as WUDS. The guidance sets out which furniture items may contain POPs and how to determine the level of POPs in an item of waste furniture, as items with POPs levels below  specified concentration thresholds can be reused. You can read the full guidance on the SEPA website here.

How are levels of POPs in our waste upholstered domestic seating determined?

SEPA recommend two key ways to determine the levels of POPs in WUDS: 1) testing of items through the use of handheld X-ray Fluorescence (XRF) devices, or 2) to use the date of upholstered seating manufacture (if an item was manufactured after commonly used furniture POPs were banned, then the risk of those specific POPs being present is reduced). The method of construction or the materials the WUDS item is made from also requires consideration.

The problem is, using indicators such as date of manufacture is only a proxy measure of the level of POPs in an item. Also, consumers often remove furniture labels but use of these indicators requires clear intact and useable product labels. Additionally, XRF devices can be very expensive and the burden of recycling domestic seating often rests on local authorities, whose budgets are frequently overstretched.

Charities and community reuse organisations can also be burdened with making decisions around the management of donated or unwanted domestic seating that may contain POPs. Matthew Lewis, Policy Manager from Circular Communities Scotland said:

“As an organisation that supports a thriving network of charities and social enterprises that supports Scotland’s circular economy, Circular Communities Scotland welcomes SEPA’s updated reuse guidance and the need to protect the public and the wider reuse sector from POPs in furniture.

Regulatory action is important as it reinforces the value of reuse, minimising waste and keeping things in use for longer but a safe and healthy circular economy can only be achieved by minimising the use of harmful chemicals in the future where possible”.

Support our calls for a sustainable fire safe future

The need to tackle the UK’s POPs in WUDS challenges strengthens our call for full chemical transparency across furniture supply chains through mandatory dynamic digital labelling and sharing of chemical information with waste managers and recyclers when products reach their end of life.

The best way to deal with potential future POPs use in furniture, is to avoid regrettable substitution of chemical flame retardants and the unnecessary use of chemicals in products in the first place. We also ask that the updated UK furniture and furnishings fire safety regulations reduce reliance on chemical flame retardants and introduce requirements for full chemical transparency and traceability. Unfortunately, the current 1988 ‘UK Furniture and Furnishings Regulations’ use outdated flammability testing procedures that result in the excessive use of chemical flame retardants to meet product compliance. Regulatory change is needed to protect environmental and human health from harmful chemical flame retardants.

Support our call for change

Visit our website to learn about our Sustainable Fire Safety project and sign up for our newsletter. If you want to help phase out the use of chemical flame retardants, consider writing to your local MP and support our call for chemical transparency and safe and sustainable fire safety.


[1] Defra (2021) National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants.

[2] Defra (2021) Briefing Note: Feedback from Defra working group for domestic seating waste.

[3] McKay, G. (2002) Dioxin characterization, formation and minimization during municipal solid waste (MSW) incineration: review. Chemical Engineering Journal, 86, 343-368.

[4] The environment agencies guidance on managing waste containing persistent organic pollutants (POPs),the%20materials%20that%20contain%20them

[5] Scottish Environment Protection Agency (SEPA) Guidance on the management of Waste Upholstered Domestic Seating (WUDS) containing Persistent Organic Pollutants (POPs), October 2023, available online:

[6] Water Research Centre Limited, on behalf of the Environment Agency, An assessment of persistent organic pollutants (POPs) in waste domestic seating. May 2021. Report Reference: UC15080.5. Available online at: An assessment of persistent organic pollutants (POPs) in waste domestic seating (