POPs waste: what UK waste sites must do with persistent organic pollutants
In short: waste is POPs waste when a persistent organic pollutant in it is at or above its limit, and then you must destroy (or irreversibly transform) the POPs. It can't be recycled, reused or landfilled, and mixing it with other waste makes the whole load POPs waste. The loads most sites meet are waste sofas and armchairs, and some electrical waste. POPs waste isn't always hazardous waste, but it always has to be described as containing POPs, and each load you receive is reported to Defra with its POPs.
What POPs are, and their limits
Persistent organic pollutants are chemicals that don't break down in the environment and are a danger to people and wildlife. In Great Britain the rules are the POPs Regulation as it was kept in UK law, enforced through the Persistent Organic Pollutants Regulations 2007. Northern Ireland still follows the EU POPs Regulation, with DAERA as its authority.
Each POP has a concentration limit. GOV.UK's concentration limit table for England includes:
- 50 mg/kg for most of them, including PCBs, PFOS, DDT and aldrin.
- 500 mg/kg for the sum of the brominated flame retardants known as PBDEs (tetra-, penta-, hexa-, hepta- and decaBDE). NRW's page for Wales still gives 1,000 mg/kg, so check your own regulator's table.
- 1,000 mg/kg for HBCDD, another flame retardant, and 10,000 mg/kg for short-chain chlorinated paraffins.
- Much lower limits for some: 1 mg/kg for PFOA and PFHxS and their salts, and 15 µg/kg for dioxins and furans.
Under your duty of care, it's your responsibility to know whether your waste contains POPs. You can ask the supplier or manufacturer, or have the waste tested. GOV.UK warns that a lab can underestimate some POPs, such as PBDEs in plastic, so the results must be adjusted for how much the test extracted.
Which waste contains POPs
GOV.UK has its own guidance for four kinds of waste known to contain POPs:
- Upholstered domestic seating: sofas, sofa beds, armchairs, upholstered kitchen and dining chairs, footstools, home office chairs, futons, bean bags and the like. It covers household-type seating from households or businesses, so a hotel's or a pub's sofas count, and any part made of leather, synthetic leather, other fabric or foam. Wooden chairs, deckchairs, mattresses, curtains, beds and commercial seating not used in homes aren't covered, though they can still contain POPs.
- Waste electrical and electronic equipment (WEEE): GOV.UK treats display devices, small mixed WEEE and lamps such as compact fluorescents as POPs waste when they contain POPs, in plastic casings, cables, circuit boards or insulation foam. Large white goods and fridges usually don't hold enough POPs to be POPs waste.
- Institutional mattresses.
- Lead acid batteries.
For seating, the Environment Agency's tests behind the rules found the flame retardant decaBDE above the legal limit in 30% to 40% of items made before 2019, and SEPA says the average can be four times the limit. Seating doesn't come with a data sheet, so if you can't confirm whether it contains POPs, SEPA says assume it does.
Is POPs waste hazardous?
Not always. It depends on the waste code, and the classification guidance, WM3, checks for POPs alongside hazardous properties:
- A mirror entry (a hazardous and a non-hazardous code for the same waste): the hazardous code must be assigned if the waste contains POPs above the concentration limits, even if it shows no hazardous property. It's then hazardous waste, and the POPs go on its consignment note.
- An absolute non-hazardous entry stays non-hazardous. Waste upholstered domestic seating is coded 20 03 07 (bulky waste), which GOV.UK says is classified as absolute non-hazardous, even though it may contain POPs. It travels on a transfer note, not a consignment note, but it is still POPs waste and must still be destroyed.
- WEEE containing POPs, such as display devices, is hazardous and POPs waste: 20 01 35* from households, 16 02 13* from businesses. If you've assessed it and still aren't sure, GOV.UK says treat it as hazardous and POPs waste as a precaution.
What must happen to POPs waste
- Destroy the POPs. Send it to a site authorised to destroy or irreversibly transform them by one of four operations: D9 physico-chemical treatment, D10 incineration on land, R1 use as a fuel (not for PCBs), or R4 metal recycling under the POPs Regulation's Annex V conditions. Our guide to disposal and recovery codes explains them.
- Don't recycle or reuse it. You must not recycle or reuse any waste that contains POPs. A site can separate the POPs parts out, but those parts must then be destroyed, and parts without POPs can be reused.
- Don't mix it. Take all reasonable steps to avoid mixing it with other waste. If you do, the whole load is POPs waste, and the POPs must be destroyed even if mixing has diluted them below the limit. Whole sofas can share a vehicle with other waste only if they're kept apart and separated when unloaded.
- Not to landfill. For seating, GOV.UK says you must incinerate it, mixed loads included, and landfill operators must not accept it. Other POPs waste can only be stored permanently in exceptional cases, with the Environment Agency's agreement for each one.
- Store it only on the way to destruction. Repackaging or storing it for a while before it's destroyed or separated needs an authorisation that allows it.
Describing it on the paperwork
Your duty of care description must include the POPs where they are present.
- Seating, on its transfer note: describe it as "domestic seating waste containing POPs", even when it's mixed with other waste, and list the chemicals on the note or separately. SEPA asks for "20 03 07 - waste domestic seating containing POPs", with every POP and other chemical present or likely to be.
- Hazardous POPs waste, on its consignment note: the composition, hazardous properties and POPs from classifying it are used to complete the consignment note. In England and Wales, the receiving site's consignee return then lists POP alongside each waste's HP codes.
Reporting POPs to Defra
Since October 2026, a site receiving waste in England or Wales reports each load to Defra's digital waste tracking service. For each waste in it, Defra's specification asks whether it contains POPs. If it does:
- Where the details came from: not provided, provided with the waste, determined from guidance, or determined from your own testing. It must be given whenever the waste contains POPs.
- Each POP by its code from Defra's own list of POP names, with its concentration in mg/kg. Where you only know a limit, such as a lab's "less than", give the figure with < or >.
- The rules: if the details weren't provided, list no POPs. If they came from guidance or your own testing, list at least one. If they came with the waste, listing them is recommended.
On Defra's spreadsheet, POPs are entered by code, not by name, and our guide to Defra's errors explains the messages you get when they aren't. Scotland and Northern Ireland have their own timetable: see digital waste tracking in Scotland and Northern Ireland.
Wales, Scotland and Northern Ireland
- Wales: NRW's page sets out the same duties (know your waste, don't mix it, destroy the POPs, never recycle or reuse it) and points to GOV.UK's guidance on seating and WEEE.
- Scotland: SEPA enforces the POPs rules and has its own guidance on seating. It adds electrical recliner chairs and floor and sofa cushions to the list, and says you must not landfill seating that may contain POPs, nor mixed waste containing it, the shredded waste and fuel (RDF and SRF) made from it, or the fines from treating it. Landfill sites should check for it, and quarantine any they take in until it goes for destruction.
- Northern Ireland: DAERA says POPs waste above the limits must be traced and treated specially to destroy all POPs content, and seating above the limit goes to incineration rather than landfill.
Common questions
Is POPs waste hazardous waste?
Not always. Under a mirror entry, POPs at or above their limit make it the hazardous entry. Waste sofas and armchairs under 20 03 07 stay non-hazardous, but they are still POPs waste and must be destroyed.
Can waste sofas go to landfill?
No. In England, waste upholstered domestic seating containing POPs must be incinerated and landfill operators must not accept it. In Scotland, SEPA says it must not be landfilled, nor the waste from treating it.
Can waste containing POPs be recycled or reused?
No. You must not recycle or reuse waste that contains POPs. Parts that don't contain POPs can be separated and reused, and the POPs parts destroyed.
What if POPs waste gets mixed with other waste?
The whole load is then managed as POPs waste, and the POPs must be destroyed even if mixing has diluted them below the limit.
What do I tell Defra about POPs?
For each waste, whether it contains POPs and, if it does, where the details came from, plus each POP's code from Defra's list and its concentration in mg/kg where you have them.
Check the official guidance
This guide is based on these pages. Rules change, so check them for the latest position.
- Identify and classify waste containing persistent organic pollutants (POPs) (GOV.UK / Environment Agency)
- Manage waste containing persistent organic pollutants (POPs) (GOV.UK / Environment Agency)
- Manage waste upholstered domestic seating containing POPs (GOV.UK / Environment Agency)
- Waste electrical and electronic equipment (WEEE): how to classify (GOV.UK / Environment Agency)
- Manage waste institutional mattresses containing POPs and lead acid batteries containing POPs (GOV.UK / Environment Agency)
- Waste classification technical guidance (WM3) (Environment Agency, NRW and SEPA)
- Identify, classify and manage waste containing persistent organic pollutants (POPs) (NRW)
- Guidance on the management of waste upholstered domestic seating containing POPs (SEPA)
- Persistent organic pollutants (DAERA)
- Regulation (EU) 2019/1021 on persistent organic pollutants, as kept in UK law, and the Persistent Organic Pollutants Regulations 2007 (legislation.gov.uk)
- Receipt API specification (Defra, GitHub)
How Tippa helps
Recording POPs is free in Tippa, on every receipt, collection and load going out, and every load you receive goes to Defra with its POPs.
- Each waste has Contains POPs beside Contains Hazardous Properties. Pick each POP from Defra's own list, give its concentration in mg/kg (with < or > where a lab gives one) and say where the details came from. Defra's rules are checked as you save, so a load isn't refused afterwards.
- Every load you receive is reported to Defra with its POPs, free, and Tippa passed Defra's own test cases for POPs waste and for waste that is both hazardous and contains POPs (see the results).
- The receipt's PDF lists each POP with its concentration, and the description you give, such as "domestic seating waste containing POPs", goes on the transfer note.
- Hazardous waste with POPs gets its consignment note filled in for your nation with POP among its hazard codes, free. Your EA or NRW consignee return and each producer's return list it too, with the Consignee Returns add-on.
This guide is general information about UK waste rules, not legal or regulatory advice. You remain responsible for meeting the duties that apply to your business; check the official guidance above and take professional advice where you need it.