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POPs: which loads are caught, and what it means for disposal

29 October 2026 · CarrierNote

POPs (persistent organic pollutants) are chemicals that don't break down in the environment and harm people and the environment. Waste carrying them at or above the legal limit is POPs waste. Its POPs have to be destroyed or irreversibly transformed (changed so they can't form again), usually by incineration, and the waste can't be recycled or reused.

In England the loads most likely to be caught are upholstered domestic seating, such as sofas, armchairs and padded dining chairs, and some waste electrical equipment, such as the plastic cases of old screens. If POPs waste gets mixed into another load, the whole load becomes POPs waste.

What makes a load POPs waste

The rules come from the POPs Regulation, which the UK kept after leaving the EU. A list at the end of it, called Annex IV, sets a concentration limit for each chemical. For the brominated flame retardants found in upholstered seating, the limit is 500mg for every kilogram of waste, counting five related chemicals together.

At or above the limit, article 7 of the Regulation says the POPs content must be destroyed or irreversibly transformed. It also bans any process that would recover, recycle or reuse the POPs. The Environment Agency's guidance tells anyone holding the waste that they must not recycle or reuse waste containing POPs.

You can't usually test a sofa at the kerbside, so the guidance names the kinds of waste where POPs are likely. Two of them are upholstered domestic seating and waste electrical equipment. Our POPs guide lists the items most likely to hold them, and the code for each chemical.

Upholstered domestic seating

The seating rules cover household-type seating with any part made of, or containing, leather, synthetic leather, other fabric or foam. The Environment Agency's list includes:

  • sofas, sofa beds, armchairs and recliners
  • kitchen and dining chairs, stools and footstools
  • home office chairs, futons, bean bags, and floor and sofa cushions
  • other household seating, such as child car seats, highchairs and garden furniture with padding

A plain wooden chair with no cushioned or fabric parts is unlikely to contain POPs, and so is a deckchair. Mattresses, beds, curtains and blinds sit outside the seating rules in England, though they can still contain POPs and fall under the general guidance.

SEPA's guidance for Scotland (SEPA is the Scottish Environment Protection Agency) adds that seating of a household type from pubs, hotels, cafes and hospitals should be assumed to contain POPs too.

Waste electrical equipment

The Environment Agency's guidance on waste electrical equipment says circuit boards, cables and plastic parts can contain POPs. The plastic cases of display devices, such as old televisions and monitors, will contain POPs above the limits. So can the plastic parts and cables in fridges and freezers.

Where an item hasn't been assessed, the guidance says to manage it as POPs waste as a precaution.

Keeping it separate, and what a mixed load means

You must take all reasonable steps to keep POPs waste apart from other waste until it's treated. If it does get mixed in, the whole load is managed as POPs waste and its POPs must be destroyed. That holds even when the mixing has brought the concentration below the limit.

A sofa thrown into a skip of general clearance waste therefore turns the whole skip into POPs waste. The Environment Agency allows whole items of seating to share a vehicle with other waste, as long as they aren't damaged or mixed in and they're separated again when unloaded. The risk to the rest of the load comes from foam, covers or lining working loose.

How to describe it on the transfer note

Describe the seating as "domestic seating waste containing POPs" and use the EWC code (the six-digit European Waste Catalogue number that says what a waste is) 20 03 07, which is bulky waste. List the POPs chemicals on the transfer note or in a document given with it. Use the same description for a mixed load that has seating in it, such as a skip.

Our posts on what must be on a waste transfer note and how to pick the right EWC code cover the rest of the note.

Where the waste can go

POPs seating goes to a municipal or hazardous waste incinerator, or a cement kiln, authorised to take it. Landfill sites must not accept it, and that includes shredded seating and fuel made from it. If an incinerator shuts down, the waste waits in storage or goes to another authorised incinerator or cement kiln.

Reuse is possible only before a sofa becomes waste, or after it's been shown to contain no POPs. Anyone taking waste seating for reuse has to check each item for POPs or assume every upholstered one contains them.

POPs on a Digital Waste Tracking record

Digital Waste Tracking is the online service run by DEFRA (the Department for Environment, Food and Rural Affairs) for recording waste movements. Since October 2026, receiving sites in England and Wales have logged every load they take in on it, with Scotland and Northern Ireland following in January 2027. Carriers, brokers and dealers join in October 2027.

When a load contains one or more of the chemicals in Annex IV, the receiving site records each one by name with its concentration. Where it can't, it has to say why, for example because no breakdown came with the waste. The duty of care (the legal duty to handle waste safely and pass it only to someone allowed to take it) carries on alongside the digital record, so the load still needs its transfer note.

Wales, Scotland and Northern Ireland

This post follows the Environment Agency's guidance for England. Natural Resources Wales has its own guidance on upholstered seating, and SEPA's guidance for Scotland sets out the same landfill ban and a matching description for the transfer note. In Northern Ireland, check with NIEA (the Northern Ireland Environment Agency).

CarrierNote records POPs on the same form as the rest of the waste record. You tick that a load contains POPs, then pick each chemical and its concentration, and the form reminds you that upholstered seating usually carries the flame retardants above. See how hazardous and POPs loads work at carriernote.co.uk/product.

Sources

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