Impact assessment

Responses received and government response (PXDD/F)

Updated 24 April 2025

Executive summary

Defra held a call for information for a group of substances, polybrominated dibenzo-p-dioxins and dibenzofurans (PBDD/Fs) including mixed polybrominated/chlorinated dibenzo-p-dioxins and dibenzofurans (PBCDD/Fs), which have been proposed for listing as Persistent Organic Pollutants (POPs) on the UN Stockholm Convention. POPs proposals are reviewed by the Convention’s POPs Review Committee (POPRC), and POPRC had requested information about PBDD/Fs and PBCDD/Fs to feed into the draft Risk Profile (RP) document.

The call was held to collect information on the use or production of PBDD/Fs and PBCDD/Fs to assist with drafting the RP (Annex E of the Stockholm Convention). We also asked for any additional social and economic impacts of a ban or restriction of PBDD/Fs and PBCDD/Fs in anticipation of future calls should the draft RP be agreed.

Number of responses

We received three responses relating to PBDD/Fs and PBCDD/Fs from:

• Cancer Prevention Society/Arnika, a non-profit environment organisation
• FIDRA - an environmental charity supporting sustainability and preventing pollution
• Fuels Industry UK, representing the eight main oil refining and marketing companies operating in the UK

Full responses

These responses from UK stakeholders represent their perspectives and do not necessarily reflect the views of Defra or the government.

Cancer Prevention Society and Arnika

In collaboration with our expert partner Arnika, I am pleased to send you a completed Annex E form.

Whilst health and environmental impacts of polybrominated dibenzo-p-dioxins and dibenzofurans are international in scope what is UK specific is that we have very high use of brominated flame retardants in domestic furniture.

The recent international report Waste incineration and the environment is very comprehensive and lays out the problem clearly:

Brominated dioxins are present in gaseous emissions from incinerators, as well as in fly ash, bottom ash, and other residues from gas cleaning (Chatkittikunwong & Creaser, 1994; Wang et al., 2010a). They have been detected in the air (M.-S. Wang, S.-J. Chen, K.-L. Huang et al., 2010a), soil (Song et al., 2022), and even in eggs from domestic poultry near incinerators and sites where fly ash and bottom ash from incinerators are handled (Teebthaisong et al., 2021; Weber et al., 2015).

Unlike chlorinated dioxins, they tend to accumulate more in bottom ash than in fly ash (Bell et al., 2023a; Wang et al., 2010a; Wang et al., 2009). This also applies to brominated flame retardants, which do not completely decompose during incineration (Wang et al., 2010a; Wang et al., 2009; M.-S. Wang, S.-J. Chen, Y.-C. Lai et al., 2010b). Brominated dioxins significantly contribute to the overall dioxin toxicity in collected samples of eggs from domestic poultry (Petrlik et al., 2021). In China, there is a case of a municipal waste incinerator that was a source of contamination in its vicinity with brominated dioxins (Petrlik, 2015; Weber et al., 2015).

More scientific papers on the subject can be downloaded here: polybrominated dibenzo-p-dioxins incinerators - Search Results - PubMed

The recent UK report of three incinerators has positive elements but the following issues remain unresolved:

• Given the huge volume of furniture that needs to be incinerated (I have heard astonishingly high ranges of 7-14 million items per year although these figures need verifying), I can imagine that not all furniture is going to the incinerators studied in the report
• Is all furniture waste in the UK being burnt in high performance incinerators? If not, then all other ones need validating (both here and abroad) for their ability to destroy BFRs and not form halogenated dioxins
• Even if heat is generated, burning waste is not good for net zero commitments (foam used in furniture is derived from fossil fuels), nor is it in keeping with the circular economy.
• All this points to the need to eliminate brominated flame retardants. The move of the EU to possibly restrict aromatic BFRs as a class is a very positive step in this respect and we urgently recommend the UK follows their example.

This comment was accompanied by a completed Annex E form which can be accessed here.

FIDRA

Thank you for reaching out to Fidra with details of the recent UK REACH call for information that will be used to feed into a draft Risk Profile (as specified in Annex E of the Stockholm Convention). Fidra are calling for the removal of unnecessary harmful chemical flame retardants (especially halogenated organic substances) from upholstered furniture products. We are extremely concerned about the release of Persistent Organic Pollutants (POPs) into the environment during the manufacture, use and disposal of contaminated upholstered furniture. We are aware of the unintended release of halogenated dioxins and furans formed as a consequence of burning waste upholstered furniture containing halogenated flame retardants. As your call indeed states, POPs are “substances that persist in the environment and accumulate in living organisms. They pose a risk to our health and the environment and can be transported by air, water or migratory species across international borders, reaching regions where they have never been produced or used.”

The best solution for tackling POPs and unrestricted harmful chemical flame retardants found in furniture is to update the current UK Furniture and Furnishings Fire Safety regulations 1988. The current UK regulations and flammability testing standards result in UK citizens being exposed to significantly higher concentrations of chemical flame retardants, compared to other countries, with no clear improvements to fire safety. Legacy chemical flame retardants identified as POPs are still found in furniture today and these, as well as their unrestricted substitutes, are linked to cancer, fertility issues and neurological conditions (see peer reviewed academic consensus paper). Consultation responses on proposed revisions (led by OPSS) to the regulations have been received but as things stand, there is a real danger that the revised regulations will maintain the current status quo.

Fidra have in-depth knowledge on this issue and have worked with stakeholders across the mattress supply chain to develop an industry consensus statement demonstrating a clear desire to reduce flame retardant use. There is evidence that chemical flame retardants increase smoke toxicity which is a leading cause of fire deaths. Furniture fire smoke toxicity needs to be brought within scope of the regulations. The new regulations must exclude unrealistic flaming ignition sources in the flammability testing standards to enable more innovative designs and solutions to fire safety. Fidra sit on the BSI Committee charged with drafting the relevant flammability testing standards for the Regulation.

The ongoing use of harmful chemical flame retardants in products continues to create a significant barrier to the UK’s safe circular economy as demonstrated by the POPs in waste upholstered domestic seating ruling by the environmental regulators which means all POPs-contaminated waste products (> 1000 mg/kg limit) must be incinerated. Fidra’s 2022 and 2024 blogs have highlighted the environmental issues. This high cost is being borne not by polluters but by Local Authorities and has been exacerbated by the lack of chemical transparency and dynamic product labelling.

As highlighted in a 2024 study commissioned by the Environment Agency, institutional mattresses contain high levels of POPs and their flammability testing according to even more stringent standards than domestic mattresses, means that increased volumes of unrestricted harmful chemical flame retardants are added (see 2024 Fidra blog).

Decabromodiphenyl ethane (DBDPE), the replacement of the recognised POP decaBDE is a high-volume brominated flame retardant (10,000-100,000 tonnes per annum). As outlined in a recent joint response to the European Chemical Agency (ECHA)’s call for evidence on aromatic brominated flame retardants (BFRs), Fidra and other NGOs are calling for a group approach to BFRs as replacement BFRs will certainly lead to the same problem as the recognised POPs PBDEs and HBCDD. There is also an urgent need to remove medium-chain chlorinated paraffins from UK furniture/other products and dispose of contaminated waste accordingly, as Fidra believe that this flame retardant is also used in high-volumes (10,000-100,000 tonnes per annum) and restrictions have been proposed by ECHA.

Please see this recent report by POPs in waste experts Arnika outlining the Global extent of the POPs in waste problem: Waste incineration and the environment.

We hope that this information is useful as part of your request for additional information regarding substances proposed as POPs and that Defra will support future legislation enforcing product chemical labelling to improve the proposed UK Furniture and Furnishings Fire Safety regulations. If the above issues are tackled effectively, barriers to innovation and trade will be reduced and there will be increased opportunities for business and product circularity which is vital if government are to reduce waste contamination and the need for waste incineration. These measures will also support the UK’s ambitious circular economy and net zero targets.

Fuels Industry UK

Fuels Industry UK represents the eight main oil refining and marketing companies operating in the UK. The Fuels Industry UK member companies – bp, Essar, Esso Petroleum, Petroineos, Phillips 66, Prax Refining, Shell and Valero – are together responsible for the sourcing and supply of product, meeting over 90% of UK inland demand, accounting for a third of total primary UK energy^{[footnote 1]}.

The purpose of this letter is to provide information on the potential unintentional generation of polybrominated dibenzo-p-dioxins and dibenzofurans (PBDD/Fs) and mixed polybrominated/chlorinated dibenzofurans (PBCDD/Fs) in catalyst regeneration processes used in refineries. Although the request to provide information using the relevant information submission form is acknowledged, Fuels Industry UK does not hold much of this information – the information below is provided as background to inform the UK submission to the Secretariat of the Stockholm Convention on Persistent Organic Pollutants.

Catalytic reformers – background

There are currently six operating refineries in the UK – EET Fuels Stanlow, Esso Fawley, Petroineos Grangemouth, Phillips 66 Humber, Prax Lindsey and Valero Pembroke. All six operate catalytic reformer units, which are used to upgrade naphtha streams for use as a gasoline blending component. The units also act as the main source of hydrogen within the refineries which is produced as a byproduct in the reforming process; this is used in other units to desulphurise and upgrade diesel and gas oil streams. Catalytic reformers are key processing units for any refinery configuration using crude oil as a feedstock and will remain so in future for processing of renewable and waste feedstocks.

The following description of catalytic reformer operation and emissions from catalyst regeneration have been taken from the Best Available Techniques (BAT) Reference Document for the Refining of Mineral Oil and Gas^{[footnote 2]}. Together with the BAT Conclusions^{[footnote 3]} , this is used as the evidence base to set permitting conditions for environmental permits issued by the UK environmental regulators.

In general, catalytic reformers can be classified into three categories: continuous, cyclic or semi-regenerative, depending on the frequency of the catalyst regeneration with most of the UK catalytic reformers being semi-regenerative reformers. In this process design, regeneration requires the unit to be taken offstream; depending upon the severity of operation, regeneration is required at intervals of 3 to 24 months.

In the regeneration process, carbon build up on the catalyst is burnt off with hot nitrogen diluted with air. Trace quantities of a promoter, normally an organic form of chlorine (such as tri- or per-chloroethylene, and occasionally bromine containing substances) are added to retain the catalyst activity. Moisture is removed and the regenerated catalyst is returned to the reformer.

The off-gas from catalyst regeneration varies with the reforming technology employed and the routing of the off-gas. The regeneration vent gas can contain air with diluted oxygen content, steam, CO2, traces of HCl, Cl2, CO, SO2, hydrocarbons and low levels of dioxins and furans. Depending on the technology and the system design, the regeneration vent gas may be routed over an adsorption bed, through a caustic scrubber, or combined with a basic water wash system. Air emissions of trace components such as dioxins and furans are known vary significantly depending on the unit configuration, but only limited information is available in the BAT Reference Document.

Monitoring of dioxin and furan emissions from UK refineries

As mentioned earlier, the BAT Reference Document and BAT Conclusions are used to set permitting conditions for environmental permits issued by the UK environmental regulators. Under the BAT Conclusions, BAT 4 requires monitoring of polychlorinated dibenzodioxin and furan emissions from catalytic reformers “once a year or once during regeneration, whichever is longer”, but no associated Emission Limit Values (ELVs) are given.

Under the environmental permits for each of the six UK refineries, the UK environmental regulators have included conditions requiring monitoring of dioxin and furan emissions at least annually or during catalyst regeneration for semiregenerative reformers. Typically, the test suite will include the following where chlorine containing promoters are used:

Dioxins

• 2,3,7,8-tetrachlorodibenzo-p-dioxin
• 1,2,3,7,8-pentachlorodibenzo-p-dioxin
• 1,2,3,4,7,8-hexachlorodibenzo-p-dioxin
• 1,2,3,6,7,8-hexachlorodibenzo-p-dioxin
• 1,2,3,7,8,9-hexachlorodibenzo-p-dioxin
• 1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin
• Octachlorodibenzo-p-dioxin

Furans

• 2,3,7,8-tetrachlorodibenzofuran
• 1,2,3,7,8-pentachlorodibenzofuran
• 2,3,4,7,8-pentachlorodibenzofuran
• 1,2,3,4,7,8-hexachlorodibenzofuran
• 1,2,3,6,7,8-hexachlorodibenzofuran
• 2,3,4,6,7,8-hexachlorodibenzofuran
• 1,2,3,7,8,9-hexachlorodibenzofuran
• 1,2,3,4,6,7,8-heptachlorodibenzofuran
• 1,2,3,4,7,8,9-heptachlorodibenzofuran
• Octachlorodibenzofuran

Unfortunately, Fuels Industry UK does not hold results from the motinoring programmes, although these should be available to DEFRA and the HSE from the environmental regulators.

Other information

The UK Energy Institute published an updated second edition of a briefing paper “UK Oil refining and the atmospheric emission of dioxins and furans” in 2014. This sought to review the latest health effect data available at the time, as well as the contribution of the refining industry to the UK dioxin and furan inventory. It also updated the legislative references.

Information on estimation methods for dioxin and furan emissions from refineries is available in CONCAWE Report No. “4/17, “Air pollutant emission estimation methods for E-PRTR reporting by refineries”, published in 2017.

Fuels Industry UK welcomes the opportunity to respond to the request for information and would be happy to help provide further information to aid the development of the draft Risk Profile and draft Risk Management Evaluation for polyhalogenated dibenzo-p-dioxins and dibenzofurans (PXDD/Fs) where we are in a position to do so

Government response

Information received through this call has been incorporated into the UK’s submission of information to the Stockholm Convention’s POPRC.

The Stockholm Convention website includes more information about POPRC’s calls for information.

1. BEIS Digest of UK Energy Statistics (DUKES) 2023. ↩

2. EU Joint Research Centre, Best Available Techniques (BAT) Reference Document for the Refining of Mineral Oil and Gas, 2015. ↩

3. Commission Implementing Decision 2014/738/EU ↩