Domestic waste upholstered seating furniture, such as sofas and beanbags, has been found to contain high levels of legacy chemical flame retardants banned under the Stockholm Convention on persistent organic pollutants (POPs). The Environment Agency (EA), Natural Resources Wales and Scottish Environment Protection Agency (SEPA) all recently introduced rulings requiring the separation of waste upholstered domestic seating furniture from general waste streams and disposal via incineration to destroy harmful POPs, while Northern Ireland continues to implement European Union regulation on POPs(1).
Although these new legal requirements are a step forward in protecting the environment and human health against the danger of these legacy chemical flame retardants, compliance places additional financial and resource burdens on local councils who manage this waste. To prevent regrettable substitution and further chemical management challenges in the future, updating the UK furniture fire safety regulations to enforce chemical labelling and reduced use of chemical flame retardants in upholstered furniture is urgently needed.
POPs presence in UK furniture
Chemical flame retardants (CFRs) are widely used in UK upholstered furniture and soft furnishings to comply with UK Furniture and Furnishings (Fire) (Safety) Regulations 1988(2). CFRs have been linked to human and environmental health impacts, with several historically used CFRs, notably decabromodiphenyl ether (decaBDE), now classified as a persistent organic pollutant (POP) and restricted under the Stockholm convention(3,4). However, many CFRs commonly used in UK furniture, e.g. the chlorinated organophosphate esters used in place of decaBDE, have not been classified as POPs but have been found to have harmful properties(5).
As the name suggests, POPs are highly persistent in the environment taking a long time to break down, while also being highly mobile. Over time POPs can enter and accumulate in organisms and food chains. Exposure to POPs is linked to multiple health impacts including; increased risk of cancer, endocrine, immune and reproductive systems disruption(6–8).
The classification of decaBDE as a POP under the Stockholm convention required UK industry to begin phasing out its use from 2006, before being fully banned in 2019. However, due to furniture’s long lifespan, furniture treated with this banned CFR will continue to enter waste streams for many years to come. This poses a serious issue for the UK’s circular economy and furniture waste management, as well as presenting continued environmental implications.
Environmental authorities response
A 2021 study commissioned by the Environment Agency (EA) sampled waste upholstered domestic seating from across England. They assessed POP CFR contents in these waste samples and identified the widespread presence of POPs at levels up to four times the legal threshold concentration (1,000 mg/kg) (9). The unacceptably high levels of POPs within waste upholstered domestic seating prompted the Environment Agency to issue a ruling that, as of January 2023 all POPs contaminated waste upholstered domestic seating (WUDS) was to segregated and disposed of by incineration, in order to destroy POPs and prevent lasting environmental harm and impacts on food chains by ensuring these waste items are not reused, recycled or disposed via landfill(10). A comparable ruling to the EA‘s, including the immediate need to segregate, was also subsequently issued by the Scottish Environment Protection Agency (SEPA) as of October 2023(11).
Although these rulings recognise the environmental health risks posed by POPs contaminated waste upholstered domestic seating, compliance places additional financial and resource burdens on local authorities and the waste management sector that must deal with POPs waste appropriately(12,13). Meanwhile ongoing use of CFRs in UK upholstered furniture and soft furnishings at some of the highest levels in the world due to outdated furniture fire safety regulation, risks perpetuating the issue of regrettable substitution of banned CFRs with those which may be classed as POPs in the future and continue to hinder the UK’s safe circular economy ambitions(14).
The challenges of WUDS disposal
To ensure compliance with the UK POPs regulations, local authorities must ensure POPs contaminated WUDS are identified, kept separate from other waste, and incinerated in an authorised incinerator or cement kiln at temperatures high enough (at least 800 °C) to destroy the POPs(10).
The presence of POPs, such as the brominated flame retardant decaBDE in WUDS, can be rapidly screened using X-ray fluorescence (XRF). This technology detects bromine (or other halogen) atoms rather than the chemicals themselves in materials, therefore acting as a surrogate for laborious chemical analysis(15). This technology can facilitate the separation and adequate disposal of waste upholstered domestic seating, but specialised XRF devices are costly and require training for correct use.
WUDS items can also be separated based on dates of manufacture, with those manufactured prior to the date of which decaBDE was banned in use having higher likelihood of containing POPs, however this is not an exact method and dates of manufacture are not designed to be easily accessible or identifiable at the point in which these items become waste. As in most cases currently, where assessment of POPs in WUDS is not routinely carried out or is not possible, all WUDS are directed to incineration as a precaution.
WUDS containing POPs must be kept separate from other waste streams to prevent contamination. This requires collection, storage and processing of the WUDS containing POPs separately from other waste, which is time and resource intensive for councils. As well as resulting in inefficiencies in managing multiple waste streams there are issues such as increased carbon emissions from the use of additional vehicles dedicated to WUDS collection. Compliance with the WUDS ruling is essential but it places greater financial and resource pressures on local councils who are already struggling financially to deliver statutory and essential services.
Managing and preventing POPs in UK furniture waste
To prevent the issue of WUDS being treated as POPs waste continuing, it is vital steps are taken to address the widespread use of CFRs in the UK’s domestic upholstered furniture. The UK furniture and furnishings (Fire)(Safety) Regulations 1988 must be updated, to enforce chemical labelling and reduce reliance on CFRs by removing ineffective testing requirements and supporting innovative product design.
This reduction in reliance on CFRs will prevent the regrettable substitution of banned POPs with CFRs that are also harmful to human and environmental health and may become classified as POPs themselves in the future. Alternatives to CFRs, such as fire barrier materials, and improved use of materials in furniture design could be utilised to meet flammability requirements, thus reducing the use of CFRs.
Transparency and smart labelling of products would provide accurate information for recyclers and waste managers on the use of CFRs in products, ensuring that WUDS are disposed of or recycled appropriately. This is an important step in supporting the transition to a circular economy. Extended producer responsibility (EPR) is also an important element to supporting a circular economy for furniture and textiles by making producers responsible for the entire lifecycle of their products and shifting the financial burden of managing WUDS containing POPs away from councils to those who choose to make use of these CFRs on products.
Continued use of CFRs instead of more sustainable means to meet the UK’s fire safety regulations puts the burden of end of life management on local authorities. If the use of CFRs in UK furniture is not addressed now, this burden will continue to impact councils and the waste industry for many years into the future.
“NAWDO recognises the importance of protecting human health and the environment against harmful chemical flame retardants found in waste upholstered domestic seating. However, the measures introduced to manage this waste has placed a large additional cost and resource burden on local authorities and the wider waste sector, with no contribution from the producers that chose to use the chemicals in their products.
NAWDO is calling for the update of current furniture fire safety regulations to reduce the use of harmful chemical flame retardants, while enforcing transparency and traceability of chemicals in products to enable effective waste management. NAWDO is also calling for the introduction of extended producer responsibility schemes for furniture and textiles, to motivate producers to make design and manufacturing choices that reduce the costs of managing waste, incentivise greater levels of reuse and repair being made cost-effective and accessible to consumers, and ensure that the higher costs of managing waste from products containing these harmful chemicals are met by those who placed them on the market.”
Jon Hastings – Chair of the National Association of Waste Disposal Officers (NAWDO)
References
1. European Union. Regulation (EU) 2019/1021 of the European Parliament and of the Council of 20 June 2019 on persistent organic pollutants (recast) (Text with EEA relevance.) [Internet]. 2019 [cited 2025 Jan 10]. Available from: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1021
2. UK Government. The Furniture and Furnishings (Fire) (Safety) Regulations 1988 [Internet]. legislation.gon.uk. 1988 [cited 2024 Dec 17]. Available from: https://www.legislation.gov.uk/uksi/1988/1324/contents
3. Sharkey M, Harrad S, Abdallah MAE, Drage DS, Berresheim H. Phasing-out of legacy brominated flame retardants: The UNEP Stockholm Convention and other legislative action worldwide. Environ Int. 2020;144:106041.
4. Defra. National Implementation Plan for the Stockholm Convention on Persistent Organic Pollutants United Kingdom of Great Britain and Northern Ireland [Internet]. Defra; 2021 [cited 2024 Dec 18]. Available from: https://consult.defra.gov.uk/plan-for-persistent-organic-pollutants-pops-team/draft-update-to-uk-nip/supporting_documents/POPs%20National%20Implementation%20Plan%20for%20consultation.docx
5. Harrad S, Sharkey M, Stubbings WA, Alghamdi M, Berresheim H, Coggins M, et al. Chlorinated organophosphate esters in Irish waste foams and fabrics: Concentrations, preliminary assessment of temporal trends and evaluation of the impact of a concentration limit value. Science of the Total Environment. 2023;859:160250.
6. United Nations Environmental Programme. Why do persistent organic pollutants matter? [Internet]. 2024 [cited 2024 Dec 18]. Available from: https://www.unep.org/topics/chemicals-and-pollution-action/pollution-and-health/persistent-organic-pollutants-pops/why
7. Secretariat of the Stockholm Convention. Stockholm Convention on Persistent Organic Pollutants (POPs) – What are POPs? [Internet]. 2024 [cited 2024 Dec 18]. Available from: https://www.pops.int/TheConvention/ThePOPs/tabid/673/Default.aspx
8. Ashraf MA. Persistent organic pollutants (POPs): a global issue, a global challenge. Vol. 24, Environmental Science and Pollution Research. Springer; 2017. p. 4223–7.
9. Keeley-Lopez P, Turrell J, Peppicelli C, Vernon J. An assessment of persistent organic pollutants (POPs) in waste domestic seating [Internet]. Water Research Centre Limited. [cited 2024 Dec 18]. Available from: https://www.circularonline.co.uk/wp-content/uploads/2021/10/WRc-Final-Report_UC15080.5_An-assessment-of-persistent-organic-pollutants-in-waste-domestic-seating_270521.pdf
10. Environment Agency. Guidance – Manage waste upholstered domestic seating containing POPs [Internet]. 2022 [cited 2024 Dec 18]. Available from: https://www.gov.uk/guidance/manage-waste-upholstered-domestic-seating-containing-pops
11. SEPA. Guidance on the management of Waste Upholstered Domestic Seating (WUDS) containing Persistent Organic Pollutants (POPs) [Internet]. 2023 [cited 2024 Dec 18]. Available from: https://www.sepa.org.uk/media/tnoa12he/waste-upholstered-domestic-seating-containing-pops-guidance.pdf
12. NAWDO. NAWDO press statement – Persistent Organic Pollutants in waste upholstered domestic seating [Internet]. 2023 [cited 2024 Dec 18]. Available from: https://nawdo.org.uk/system/files/news/230106%20NAWDO%20Media%20Statement%20POPs.pdf
13. John Coates. LARAC. 2022 [cited 2024 Dec 18]. LARAC Press Release: LARAC has serious concerns over new POPs guidance from the EA. Available from: https://larac.org.uk/news-blogs-features/larac-press-release-larac-has-serious-concerns-over-new-pops-guidance-ea
14. Page J, Whaley P, Bellingham M, Birnbaum LS, Cavoski A, Fetherston Dilke D, et al. A new consensus on reconciling fire safety with environmental & health impacts of chemical flame retardants. Environ Int. 2023 Mar 1;173.
15. Sharkey M, Abdallah MAE, Drage DS, Harrad S, Berresheim H. Portable X-ray fluorescence for the detection of POP-BFRs in waste plastics. Science of the Total Environment. 2018;639:49–57.