Managing Chemicals of Concern within a Circular Economy: The Impacts and Solutions for Chemical Flame Retardant Use in UK Mattresses
Many furniture manufacturers supplying the UK market comply with the Furniture and Furnishings (Fire) (Safety) Regulations (FFRs) 1988 (as amended) by using chemical flame retardants (CFRs). The use of these chemicals, particularly legacy CFRs such as brominated flame retardants (BFRs) and polybrominated diphenyl ethers (PBDE), has been a subject of dispute due to their negative impact on human and environmental health. Emerging evidence suggests that current CFRs in use, including organophosphate esters, may have similar adverse effects.
Previous studies have highlighted the health and environmental risks posed by flame retardants, with some substances being classified as persistent organic pollutants (POPs) and substances of very high concern (SVHCs). Regrettable substitutions have occurred, where banned CFRs were replaced with similar chemicals later subject to the same restrictions. International restrictions on SVHC usage in various products have been increasing, indicating a need for action.
Regrettable substitutions and a lack of chemical transparency and traceability pose significant barriers to achieving a successful circular economy and can undermine public and environmental health. Multiple case studies have demonstrated the detrimental impacts of harmful chemicals used in everyday products.
Regarding CFR use in UK furniture and furnishings, multiple noteworthy reports have recommended measures to restrict regrettable substitutions and introduce a new permanent label for upholstered furniture products containing flame retardants. Studies have also suggested that CFRs limit recycling opportunities and increase end-of-life treatment costs compared to CFR-free waste.
This study focuses on a cost-benefit analysis (CBA) of CFRs in mattresses in the UK, assessing their impact on fire safety, environmental sustainability, human and environmental health, and economics. While fire safety is crucial, the study questions how the UK compares to other jurisdictions in terms of CFR usage, such as continental Europe and North America (who do not require the same stringent flammability tests as the UK). The project took into account the entire mattress life cycle, including manufacturing, use (including online sales), and end-of-life management options like landfill disposal, energy recovery, recycling, remanufacturing, and reuse. It also recognised that not all mattresses contain CFRs since some manufacturers comply with the fire safety regulations by carefully designing and selecting alternative materials and components.
The study is developed around 5 possible scenarios covering different possibilities in the evolution of FFRs and use of CFRs:
Business as Usual (BAU): Existing Furniture and Furnishings Regulations (FFRs) are retained, with the assumption that there is full compliance with UK and EU REACH where applicable
Amendments to the existing FFRs that would support a reduction in the use of CFRs during mattress manufacturing
Introduction of an EPR scheme for mattresses
Introduction of a landfill and recycling ban due to mattresses containing significant levels of hazardous CFRs (that have been classified as POPs)
Introduction of chemical traceability measures
These scenarios are analysed, where possible and relevant, through the lens of different types of impacts, namely: fire safety, environmental sustainability, human and environmental health, and economics.