POPs waste explained: what persistent organic pollutants mean for your records

POPs waste is one of the most tightly regulated waste streams in the UK — with a landfill ban, strict segregation rules, and from October 2026 a dedicated flag in Digital Waste Tracking. Here is what it is, which EWC codes apply, how to dispose of it correctly, and what your records must show.

What is POPs waste?

The substances classed as POPs are listed in the UK POPs Regulation (Assimilated Regulation (EU) 2019/1021). Waste containing any Annex IV substance above the specified concentration limits must be handled under the POPs waste rules, which are more restrictive than the standard duty-of-care regime for most other waste streams.

UK furniture fire safety legislation historically required the use of brominated flame retardants in upholstered seating. Environment Agency sampling found the average PBDE concentration in upholstered seating well above the current legal threshold — which means virtually all pre-ban domestic seating should be treated as POPs waste unless you can demonstrate through analysis that it is not.

Which waste streams commonly contain POPs?

Since 21 May 2025, the UK threshold for the sum of listed PBDE congeners in waste is 500 mg/kg — halved from the previous 1,000 mg/kg limit by the Persistent Organic Pollutants (Amendment) (No. 3) Regulations 2025 (SI 2025/605). If you cannot prove a piece of upholstered domestic seating is below this limit, you must manage it as POPs waste.

What EWC code applies to upholstered seating containing POPs?

This surprises many operators: because EWC 20 03 07 is non-hazardous, you use a Waste Transfer Note — not a hazardous waste consignment note — when collecting whole items. The waste description on the note must state “domestic seating containing POPs” and name the specific pollutants present, for example “DecaBDE” or “HBCDD”. The non-hazardous EWC classification does not exempt the waste from the POPs disposal rules.

Can POPs waste go to landfill?

Article 7 of the UK POPs Regulation requires POPs waste to be disposed of so that its POP content is destroyed or irreversibly transformed — not merely contained. This rules out landfill for most POPs waste streams. The narrow exception in Annex V Part 2 (hazardous waste landfill below specified concentration limits) does not apply to upholstered seating containing PBDEs above the 500 mg/kg threshold.

• →Permitted routes: IED Chapter IV compliant incinerator, energy-from-waste facility, or cement kiln (co-incineration).
• →PCB exception: waste containing PCBs above 50 mg/kg is not eligible for energy recovery (R1) and must go to a dedicated destruction facility.
• →Prohibited: landfill, general mixed recycling, open burning, and any recovery route that leaves the POPs substances intact in a reused material.

What does POPs waste mean for Digital Waste Tracking records?

Under the Digital Waste Tracking (England) Regulations 2026, receiving site operators must submit a Receipt of Waste for each arriving load from October 2026. Where that load contains POPs, the record must carry an affirmative declaration — the Annex IV substance name and its measured concentration — which the Environment Agency can access through the service. This is the POPs flag in the DWT system.

How do I handle waste upholstered domestic seating correctly?

• →Apply the presumption rule: if domestic seating is upholstered, treat it as POPs waste unless testing proves otherwise.
• →Collect separately: do not place it in a skip or vehicle compartment with other waste — a mixed load becomes EWC 20 03 07 POPs waste in its entirety.
• →Complete a Waste Transfer Note: EWC code 20 03 07, description “domestic seating containing POPs”, naming the pollutants present (e.g. DecaBDE). No hazardous consignment note is needed for whole items.
• →Confirm the destination is authorised: not all transfer stations can accept WUDS — verify the receiving site is permitted for POPs waste before booking.
• →Retain records for 3 years: keep all Waste Transfer Notes for at least three years from the date of transfer.
• →Record the POPs flag from October 2026: receiving sites must include the substance name and concentration in the Digital Waste Tracking Receipt of Waste for every arriving POPs load.

This guide is general information about POPs waste and waste records, not legal advice. Check your obligations against the primary sources below and, if in doubt, contact the Environment Agency (England), SEPA (Scotland), or NRW (Wales) for guidance specific to your site.