Waste Upholstered Domestic Seating (WUDS) containing Persistent Organic Pollutants (POPs)

There are rules covering the disposal of waste upholstered domestic seating (WUDS) that contains Persistent Organic Pollutants (POPs). The rules apply to the transport, crushing or shredding and treatment/disposal of these WUDs. 

What are POPS and where do they occur

Domestic seating that has fabric and/or foam upholstery that was manufactured before 2019 will contain chemicals that have been used as fire retardants.

These chemicals are known as Persistent Organic Pollutants (POPs) as they do not break down naturally in the environment and pose a risk to the environment and human health if not managed correctly. POPs are usually present as a result of a flame-retardant chemical, Decabromodiphenyl Ether (DecaBDE), which has been banned since 2019 and is no longer used. 

The types of furniture that will contain POPS includes:

  • Sofas
  • Sofa beds
  • Armchairs
  • Kitchen and dining chairs
  • Stools and foot stools (upholstered)
  • Home office chairs
  • Bean bags
  • Futons
  • Floor and sofa cushions
  • Electrical reclining chairs

This list includes any part made of or containing leather, synthetic leather, other fabric, or foam. 

Furniture that doesn’t contain POPs includes:

  • Wooden chairs without fabric/textile backs or seats
  • Deckchairs

The new rules don’t apply to:

  • Mattresses
  • Curtains
  • Blinds
  • Beds

Anyone who is disposing of WUDS, and those responsible for managing WUDS, are now required to change the way these items are handled.

Producers and waste holders of POPs

If you are a producer or holder of waste containing POPs you must:

  • Take all reasonable steps to avoid, where possible, contamination of other wastes with POPs waste.
  • Dispose of, or recover POPs waste as soon as possible, in such a way that ensures the POP content is destroyed or irreversibly transformed.
  • Not carry out disposal or recovery operations that may lead to the recovery, recycling, reclamation or re-use of POPs.

Collectors of WUDS

If you collect, store or treat WUDS you must ensure that you:

  • Check if WUDS contain POPs.
  • Classify waste correctly.
  • Comply with the guidance on collection.
  • Comply with the guidance on storage.
  • Treat and dispose of WUDS appropriately.

Checking if WUDS contain POPs

You can use X-Ray fluorescence (XRF) to scan for bromine. This test indicates if POPs are likely to be present.

Staff require appropriate training using XRF.

If you are unsure if the WUDS contains POPs you must assume the waste does contain POPs and manage the waste accordingly.

Classify WUDS containing POPs

Waste Transfer Notes: The code used when transporting WUDS containing POPs is 20 03 07. You should also include a list of all of the other chemicals present (or likely to be present) in the waste.

The POPs that may be present in the furniture include:

  • HBCD
  • DecaBDE
  • PentaBDE
  • TetraBDE

In addition, the following hazardous chemicals may be present:

  • Antimony Trioxide (often used with DecaBDE).
  • Synthetic leather has often been treated with chlorinated paraffins, a plasticiser to make it more flexible.
  • Other flame retardants, and hazardous components of PVC.

Collection of WUDS

Take all reasonable steps to avoid, where possible, contamination of other wastes with POPs waste.

If other waste is mixed with POPs waste, the whole load of ‘mixed waste’ is considered to be POPs contaminated waste. If the POPs WUDS cannot be removed the ‘mixed waste’ must be dealt with as POPs waste and sent for destruction.

Where separate collection is not possible, POPs WUDS can be collected in the same vehicle as other wastes as long as they:

  • Are not damaged,
  • Are not mixed with other wastes, and
  • Are segregated from other waste during transfer and when unloaded.

The vehicles/containers used for collecting WUDS should be appropriate for the waste type and where appropriate should be covered to avoid escape.

Storage of WUDS

Sites authorised to store household mixed residual and bulky waste (20 03 01) or bulky waste (20 03 07) can accept POPs WUDS as long as the following are met:

  • Segregate and keep POPS WUDS separate from other wastes.
  • Sort and store POPS WUDS in a way that does not damage the WUDS and cause a release of POPs or contaminates other wastes.
  • Store on impermeable surface or in a way that prevents any release to the environment.

Treatment of WUDS containing POPs

Separating POPs from other materials

Separating POPs from other materials is regarded as a waste treatment process and as such must be authorised by your environmental regulator.

When separating POPs manually, you must ensure that:

  • All foam and textiles are completely removed from the WUDS.
  • You prevent and contain any dust, or fragments of foam and textiles and manage these as POPs waste.
  • You store separated material containing POPs in a building, under cover, or in a sealed container.
  • No POPs are released to the sewer or surface water.

Shredding of WUDS containing POPs

Before incineration WUDS are likely to be shredded or crushed. The process of shredding or crushing POPs WUDS is regarded as a waste treatment process and as such must be authorised by your environmental regulator.

Shredding or crushing POPs WUDS can release dust and particles that contain POPs. To avoid releasing dust and particles into the environment you must:

  • Locate shredding or crushing plant on an impermeable surface inside a building or under cover, away from drainage systems.
  • Use misting and spray systems to control dust and particulates. These should be operated so that they do not create large amounts of contaminated water.
  • Not allow unabated point source or fugitive emissions of particulates from the plant or building.
  • Control fugitive emissions using either local extraction to abatement, or full building extraction under negative pressure to abatement.
  • Use bag filters on abatement plant that are designed to release particulates below 5mg/m3. They should be fitted with continuous and alarmed pressure monitoring to make sure the filters are working correctly.

Storage of shredded POPs WUDS should be on an impermeable surface and either:

  • Inside a building.
  • Under cover.
  • In sealed containers.
  • Baled and securely wrapped.

Blending segregated WUDS containing POPs

In certain circumstances, at the point of destruction you may be able to blend segregated WUDS containing POPs with other wastes to:

  • Make loading easier.
  • Control the calorific value.
  • Optimise combustion.

When blending use the least amount of non-POPs waste to avoid contaminating more waste the necessary.

Disposal of WUDS containing POPs

Landfill ban

There is a ban on Landfills accepting WUDS that contain POPs. Landfill sites can only accept WUDS if there is confirmation that it doesn’t contain POPS. This means you need to have tested the materials using the correct identification procedures - see the section ‘Checking if WUDS contain POPs’ for more details.

If you operate a landfill site you must have procedures in place to identify and exclude WUDS containing POPs. Any WUDS containing POPs which are accepted should be quarantined before being sent to an appropriate facility for destruction.

Incineration

You must dispose WUDS containing POPs either at a HT incinerator or an Energy from Waste plant. Incineration will destroy or modify the chemicals to make them harmless.

Incinerator operators must have appropriate contingency plans in place to manage WUDS containing POPs for destruction in the event of a planned or unplanned shutdown, as the waste cannot be sent to landfill.

Further information

In Northern Ireland contact: Chemicals and Industrial Pollution Policy (CIPP) Branch | Department of Agriculture, Environment and Rural Affairs (daera-ni.gov.uk)

In Scotland see waste-upholstered-domestic-seating-containing-pops-guidance.pdf (sepa.org.uk)

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