Impact assessment

Responses recieved and government response (MCCPs)

Updated 24 April 2025

Executive summary

Defra held a call for additional information covering a group of substances identified as chlorinated paraffins with carbon chain lengths in the range C14-17. These have been proposed for listing as Persistent Organic Pollutants (POPs) on the UN Stockholm Convention.

The call was held as a further opportunity to present any additional information relating to the production, use or social and economic impacts of any control measures under consideration for chlorinated paraffins with carbon chain lengths in the range C14-17.

Number of responses

We received four responses relating to chlorinated paraffins with carbon chain lengths in the range C14-17:

• FIDRA - an environmental charity supporting sustainability and preventing pollution
• ADS Group (UK) / Aerospace Industries Association (US) / Aerospaces, Security and Defence Industries Association of Europe – A joint response on behalf of the UK, US and European aerospace and defence industries
• INEOS INOVYN - Manufacturer and supplier of chlorvinyls
• Chlorinated Paraffins Industry Association (CPIA) - Non-profit trade association

Full responses

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

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.

ADS Group (UK) / Aerospace Industries Association (US) / Aerospaces, Security and Defence Industries Association of Europe

ADS Group (ADS)^{[footnote 1]}, Aerospace Industries Association of America (AIA)^{[footnote 2]} and Aerospace, Security and Defence Industries Associations of Europe (ASD)^{[footnote 3]} write to express concern about the draft proposal to list chlorinated paraffins with carbon chain lengths in the range C14-17 and chlorination levels ≥45% chlorine by weight as a persistent organic pollutant (POP). Such substances are commonly referred to as ‘medium chain chlorinated paraffins’ (MCCPs), CAS 85535-85-9.

MCCPs are used by the aerospace and defence industry:

• Within fluids and lubricants used in cutting, machining, hot forming processes and lubrication for parts and tools.
• In extreme pressure transmission grease.
• In aircraft carpet tapes, cargo liner tapes, tamper proof putties, pinhole fillers, urethane adhesives, and in adhesives, sealants and coatings. It is understood that MCCPs are used primarily because of their flame-resistant properties.
• In electrical and electronic equipment as a plasticiser and flame retardant, principally within PVC cable insulation, and less commonly, within coatings, sealants, and adhesives. Cables must withstand harsh environments within aerospace and defence equipment (e.g. vibration, extremes of temperature / rapid temperature cycling) and flame-resistance is crucial.

Some of the above products are supplied to aerospace and defence manufacturers as ‘articles’. Where so, there is insufficient data from suppliers to identify specific products where these substances are present and where they are not.

It is understood that in some applications, MCCPs have been introduced as a substitute for short-chain chlorinated paraffins (SCCPs) and thus constitute ‘regrettable substitution’.

The collective members of ADS, AIA and ASD recognise the need to prevent the proliferation of POPs in the environment and support their substitution where possible. However, the introduction of alternatives in the manufacture and maintenance of aerospace and defence products is subject to stringent testing and requalification programmes which support continued certification/approval of products to globally recognised Aviation and Defence requirements. The introduction of alternatives would take several years and may not be possible in all circumstances. Where so, exemptions / definitions of acceptable use will be necessary to enable critical aerospace and defence uses of MCCPs to continue.

INEOS INOVYN

Please find attached INOVYN comments on the MCCP consultation.

Our principal sales are to the EU. We have been participating in the EU REACH restriction discussions and we await the publication of the EU REACH restriction in the official journal. We expect this to happen mid/late 2025, although since the substance is not on the REACH committee agenda for December we do not know exactly when this will come. The restriction allows a two-year implementation period leading up to a ban for all uses other than oil-based metal working. We are currently not aware of whether this will be how the EU discharges the POPs decision, or whether it will draft an amendment to its POPs regulation. We assume however that the existing restriction will be the key timeline. We are engaging with customers in the EU on that basis.

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

CPIA

CPIA does not have any additional information on MCCP that was not already submitted during the POPRC review process, so we will not be submitting anything to DEFRA.

Government response

Information received through this call will be used to inform our position before the Stockholm Convention’s Conference of the Parties which will be held in April/May 2025.

The Stockholm Convention website includes more information about the Conference of the Parties including a proposed agenda.

1. ADS is the UK trade association for the aerospace, defence, security and space sectors. Representing over 1,400 companies across the UK, of which over 90% are SMEs, ADS has dedicated regional offices and teams in Scotland and Northern Ireland, alongside the organisation’s dual national offices in Westminster and Farnborough. ADS also has an office and team in Toulouse, France which is dedicated to supporting members with business development across mainland Europe. ↩

2. Founded in 1919, AIA is the premier trade association representing approximately 340 major aerospace and defense manufacturers and suppliers. Our members represent the United States of America’s leading manufacturers and suppliers of civil, military, and business aircraft, helicopters, unmanned aerial systems, missiles, space systems, aircraft engines, material, and related components, equipment services, and information technology. ↩

3. ASD is the voice of European Aerospace, Security and Defence Industries. With 25 major European companies and 25 National Associations as our members, our overall representation adds up to more than 4,000 companies across 21 European countries. Our members collectively account for 98% of the people employed, and 97% of the aerospace and defence industry’s turnover within the EU Member States. ↩