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Identify waste upholstered domestic seating that contains POPs

Waste domestic seating is any item of seating of a household type from households or businesses that is waste. Upholstered domestic seating may contain POPs. For example:

• sofas
• sofa beds
• armchairs
• kitchen and dining room chairs
• stools and foot stools
• home office chairs
• futons
• bean bags, floor and sofa cushions

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

The following items of domestic seating are unlikely to contain POPs:

• items that are not upholstered, for example, a wooden chair without a cushioned or textile back, seat, or arms
• deckchairs
• wastes from manufacturing new domestic seating that the manufacturer can demonstrate do not to contain POPs

Mattresses, curtains, blinds and beds are not domestic seating and are not covered by this guidance.

Describe and classify waste domestic seating containing POPs

In your waste transfer note you must:

• describe the waste as domestic seating waste containing POPs
• classify it with the list of waste code 20 03 07

You must add this description for waste domestic seating containing POPs where it has been mixed with other waste (not containing POPs). For example, in a skip or bay of bulky household waste.

You must list the relevant chemicals in the waste transfer note.

POPs and other chemicals that waste domestic seating may contain

Waste upholstered domestic seating often contains one of the following POPs on the back of the covers and in the foam:

• decabromodiphenyl ether (DecaBDE) the most common
• hexabromocyclododecane (HBCDD)
• pentabromodiphenyl ether (PentaBDE)
• tetrabromodiphenyl ether (TetraBDE)

These chemicals may also contaminate lining and wadding in contact with foam or covers.

The following hazardous chemicals are also likely to be present:

• antimony trioxide a carcinogenic synergist often used with DecaBDE
• medium chain chlorinated paraffins often used in synthetic leather to make it flexible

Other flame retardants, and hazardous components of PVC, may also be present.

Sort and store waste upholstered domestic seating containing POPs

You must sort and store waste upholstered domestic seating containing POPs in a way that prevents:

• damaging it
• release of POPs
• contamination with other waste

You may be able to use the regulatory position statement on temporary storage of waste upholstered domestic seating containing POPs: RPS 265 if you can keep to its conditions. This will allow you time to change your processes.

You must avoid mixing waste upholstered domestic seating containing POPs with other waste during waste:

• production
• storage
• collection
• treatment

This includes in a:

• skip or container
• bay at a household waste recycling centre (HWRC), transfer station, or treatment site

If you operate a HWRC, and you sent waste upholstered domestic seating for incineration before 31 August 2022, you may be able to use the regulatory position statement on segregating waste upholstered domestic seating that may contain POPs at HWRCs: RPS 266.

In exceptional circumstances, you can justify not segregating further where both of these apply:

• you have already taken all reasonable steps
• there are no other alternatives

You must provide evidence to the Environment Agency. However, they may not accept this.

You can collect waste upholstered domestic seating on the same vehicle as other waste items (for example, doorstep bulky waste collection) as long as they are:

• not mixed
• collected in a way that does not allow it to contaminate the other waste
• separated from the other waste when unloaded from the vehicle

If you do mix POPs waste with non-POPs waste, you must manage the whole load as POPs waste until you can separate the upholstered domestic seating. You must destroy the POPs even if the mixing has diluted the POPs to below the concentration limit.

Separating whole items of upholstered domestic seating from mixed waste

This includes where the waste was mixed unintentionally or inappropriately.

You can only separate whole items of upholstered domestic seating from mixed waste, for example fly-tipped waste or waste in a skip, if you can show that it has not contaminated the other waste.

Contamination can happen when pieces of foam, cover, lining or wadding material are released from the item.

If contamination has taken place, you must manage the whole load as POPs waste.

Identify whole items that do and do not contain POPs

You can identify items of waste upholstered domestic seating that do not contain POPs and store them separately.

You can use x-ray fluorescence (XRF) to scan for bromine, which indicates that POPs are likely to be present. However, you must:

• have the right training for using XRF and use a suitable device
• have read the Environment Agency study of POPs in domestic seating waste to understand what is required
• contact the Environment Agency to check if you need to make any changes to your permit and management system
• be able to show that your process works and is accurate the Environment Agency may ask you for this evidence

Dispose of waste domestic seating containing POPs

You must incinerate waste domestic seating containing POPs or mixed waste containing it.

The municipal or hazardous waste incinerator (or cement kiln) must be authorised to accept POPs waste.

You must not use any other waste treatment, recycling or disposal methods.

Contingency plan for incinerator shutdown

Where the incinerator cannot accept the waste, you can:

• store the waste until the incinerator is able accept it
• send it to another incinerator or cement kiln authorised to accept and destroy it

You must not send it for any other type of disposal or recovery operation, for example landfill.

Incinerator operators need to put contingency plans in place to manage accepting waste from customers with waste upholstered domestic seating containing POPs for destruction. They cannot send this waste to landfill in the event of a planned or unplanned shutdown.

Prepare the waste for destruction

If the incinerator operator requires the POPs containing waste to be shredded, because they cannot handle whole items of waste upholstered domestic seating, you must:

• use shredding plant inside a building
• not allow unabated point source or fug
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