Are Office Chairs POPs Waste?

By Sam Coggin, Coggin Sustainable Office Solutions

The POPs rules are written for domestic seating, and commercial office chairs sit outside the automatic rule. The law still applies to any foam or fabric over the limit, so the foams and covers need evidence or incineration. Whole chairs never have to be incinerated.

The short answer

The POPs rules are written for domestic seating. Commercial office chairs sit outside the automatic rule. The law underneath still applies to any foam or fabric that is over the legal limit. So the foams and covers from a waste office chair cannot go in general waste unless you hold evidence that they are free of POPs.

What POPs are

POPs are persistent organic pollutants. The foams and coverings of some upholstered furniture contain them. They are chemicals that were used to make furnishings fire retardant. They do not break down and they build up in people and wildlife.

What the rules say about office chairs

In January 2023 the Environment Agency in England introduced rules for waste domestic seating that contains POPs. You can read the current guidance here.

The guidance says that ‘waste domestic seating is any item of seating of a household type from households or businesses that is waste.’ Its examples include:

• sofas, sofa beds and armchairs
• kitchen and dining chairs
• stools and footstools
• office chairs that are fire resistant to domestic standards
• futons and bean bags

The first version of the guidance said ‘home office chairs’. The wording has since been tightened. The guidance now says that ‘commercial seating of a type not used in the home’ is not domestic seating and is not covered.

It then adds a warning. ‘Commercial seating is at particular risk of containing POPs and you should consider this as part of your duty of care.’

So a commercial office chair is not caught by the rule that tells you to assume POPs are present. That does not put it in the clear.

What the law underneath says

The guidance sits on top of the POPs regulations. Those apply to any waste that holds POPs above the limit. For the main group of brominated flame retardants the limit in Great Britain is 500 mg/kg. It was lowered from 1,000 mg/kg in 2025.

Whoever holds the waste is responsible for knowing what is in it. The guidance gives three ways to find out. You can ask the manufacturer. You can test the material yourself. You can send it to a laboratory.

Scotland, Wales and Northern Ireland have their own guidance. It still says ‘home office chairs’ and says nothing about commercial seating.

What we were told in 2023

When the rules arrived we had the question checked with the Environment Agency. Its position then was this: until evidence emerges that says otherwise, assume that any foams and textile covers on commercial office chairs also contain POPs. The published guidance has since been updated as set out above. It does not repeat that position in those words.

Do commercial office chairs actually contain POPs?

Nobody has published test results for commercial office chairs in the UK. The nearest evidence is a 2021 study carried out for the Environment Agency. It scanned 17 office chairs for bromine, which is the marker for these flame retardants. All 17 came from household waste.

• None of the 9 textile covers was over the screening level.
• 1 of the 15 foams was over it.
• 5 of the 11 linings were over it.
• Two samples went to a laboratory. Both were over the legal limit.

That points to a real risk that sits mostly in linings and the occasional foam. It is a small sample of household chairs, so treat it as a pointer and not as proof.

What has to happen to waste office chairs

POPs material has to be destroyed. In practice that means incineration.

Whole chairs do not have to be incinerated. We have seen waste companies tell clients that they do. The guidance allows the foam and fabric to be separated from the rest of the chair, provided all of it is removed. Metal and plastic parts can then be recycled.

We are set up for this. Any waste office chairs sent to or collected by us for disposal are dismantled by hand. The foams and covers go for incineration. Everything else is kept for spares and repairs or recycled.

Seating foam and fabric must never be mixed into a general load. If it is, the whole load has to be managed as POPs waste. Diluting it does not change that.

How to show that foam and fabric is free of POPs

Foam and fabric can only be treated as free of POPs where there is evidence for that material. These are the routes.

• Manufacturer evidence. Ask the chair maker and the fabric mill which flame retardants were used. Some contract fabrics pass the fire tests with no chemical treatment at all.
• Bromine scanning. The guidance says that if no bromine is present in the rear of the cover, the foam or the other fabrics then brominated POPs will not be present. It asks for a trained operator and a suitable device. It also asks you to contact the Environment Agency first. A handheld scanner costs hundreds of pounds a week to hire and tens of thousands to buy.
• Laboratory testing by model. Samples of foam, cover and lining from a common chair model can be sent to a laboratory. One set of results can then stand for that model.
• Date of manufacture. The main flame retardant of concern was banned from new products in March 2019. A later date label is useful evidence. No regulator has published it as a rule on its own.

Until a chair model has evidence behind it we treat its foams and covers as POPs waste. That keeps you compliant whichever way the question is settled.

Can waste office chairs be refurbished?

The published guidance says that upholstered seating that has become waste can only be refurbished if:

So, we already have the T12 permit and can remove textiles and foams for incineration as if they contain POPs. It's the first requirement that’s confusing - does it mean before or after refurbishment?

We hold a T12 waste exemption for treating waste by hand. Where we refurbish a waste chair we remove the textiles and foams and send them for incineration as POPs waste.

What about chairs that are not waste?

These are the chairs we like best. Extending their working life saves a business money and avoids the carbon cost of a new chair.

Office chairs that are not waste can be reused even if they may contain POPs. For a chair to stay out of the waste rules these conditions must be met:

• it is reused for the same purpose for which it was designed
• the previous holder intended for it to be reused
• no more than minor repair is required to it
• both the previous holder and new holder know at the point of transfer that it does not need more than minor repair
• if a repair is required, it will be done
• its use keeps to the law, for example it carries appropriate fire safety labels
• it is managed as a non-waste – that is, it is not moved or stored in a way that will damage it, for example in a skip with items of waste

We can meet these conditions with you. We still collect surplus office chairs to refurbish them and sell them on.