Policy paper

Responses received and government response

Updated 16 October 2026

Executive summary

Defra held a call for comments 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) by 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 a revised draft Risk Profile (RP) document for these substances.

The call for comments was held to gather additional information and insights to support the ongoing work of the Stockholm Convention’s intersessional working group responsible for developing and refining draft risk profiles as part of their broader consultation process.

Number of responses

We received 3 responses relating to the revised draft RP for PBDD/Fs and PBCDD/Fs from:

• a private citizen
• Association of Healthcare Technology Providers, Imaging, Radiotherapy & Care (AXREM)
• National Association of Waste Disposal Officers (NAWDO)

Full responses

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

NAWDO

The National Association of Waste Disposal Officers (NAWDO) is the principal professional network representing senior local authority officers with statutory responsibility for waste disposal in the United Kingdom. With a membership of over 80 organisations, NAWDO represents approximately 80% of all local authorities with waste disposal duties, including London boroughs, joint waste disposal authorities, waste partnerships, metropolitan, unitary and county councils across all UK regions. Collectively, NAWDO members are responsible for the management of approximately three-quarters of municipally managed waste in the UK.

With regard to the above call for comments, NAWDO acknowledges the information set out in the draft risk profile identifying waste management activities, including the incineration of waste streams containing brominated flame retardants, as sources of the unintentional production of polybrominated dibenzo-p-dioxins and dibenzofurans (PBDD/Fs) and mixed polybrominated/chlorinated dibenzo-p-dioxins and dibenzofurans (PBCDD/Fs). While NAWDO does not have additional technical evidence to submit at this stage, we wish to draw Defra’s attention to 2 key considerations relating to the potential implications for Waste Disposal Authorities should PBDD/Fs and PBCDD/Fs be listed as POPs. We request that these matters are fully reflected in any future impact assessments.

Firstly, over 50% of all local authority collected waste in England is treated by incineration, and an estimated 80 to 90% of the UK’s Energy from Waste facilities are utilised by local authorities for the treatment of residual waste. Emissions from waste incinerators are regulated under the Environmental Permitting (England and Wales) Regulations 2016, which already require mandatory monitoring of polychlorinated dibenzo-p-dioxins and furans (PCDD/Fs). The costs associated with the abatement, monitoring, analysis and reporting of these emissions are, in practice, borne by local authorities as the primary users of these facilities. Under long-term waste disposal contracts, such costs are typically recoverable by operators through Qualifying Change in Law (QCiL) or equivalent contractual provisions. Consequently, the introduction of a regulatory requirement for routine monitoring of PBDD/Fs and PBCDD/Fs alongside existing PCDD/F monitoring would be expected to lead to significantly increased costs for Waste Disposal Authorities through these contractual mechanisms. NAWDO considers it essential that this potential financial impact on local government is explicitly recognised.

Secondly, NAWDO notes that the combined effect of current and forthcoming waste policies - including Simpler Recycling, packaging Extended Producer Responsibility and the inclusion of waste incineration within the Emissions Trading Scheme - is likely to alter the future (chemical) composition of residual waste treated by incineration. This, coupled with government’s intention to substantially increase the destruction of POPs found in waste by 2030 (as detailed in the Environmental Improvement Plan 2025), where some POPs contain bromine and chlorine, this has the potential to increase the concentration of these elements in waste streams directed to incineration.

While NAWDO recognises that the relationship between the concentrations of bromine and chlorine in waste and the formation of PBDD/Fs and PBCDD/Fs is non-linear, the draft risk profile itself notes that elevated inputs of these elements can increase the potential for their formation. NAWDO therefore requests that the cumulative and dynamic impacts of waste policy changes on the chemical composition of waste treated by incineration over time are very carefully considered when determining the low POP content limits for PBDD/Fs and PBCDD/Fs.

Consideration of the above risks is particularly important to avoid unintended consequences of Waste Disposal Authorities being penalised, either through exposure to non-compliance risk or through the incurrence of disproportionate costs, as a result of policy-driven changes that are outside their direct control.

NAWDO would welcome the opportunity to engage with Defra as this work progresses and would be pleased to provide further input should this be helpful.

A private citizen, UK

Please find below my formal comments and recommendations regarding the revised draft risk profile for polybrominated dibenzo-p-dioxins and dibenzofurans (PBDD/Fs) and mixed polybrominated/chlorinated dibenzo-p-dioxins and dibenzofurans (PBCDD/Fs).

My submission focuses specifically on the critical need for robust policing and periodic inspection schedules within the UK agricultural sector. As the UK remains a significant net importer of food and agricultural inputs, the current ‘risk profile’ must account for the vulnerability of our domestic food chain to contamination from imported precursors and uncontrolled environmental processes.

I have also included a section regarding the National Security implications of these persistent organic pollutants (POPs) in light of current geopolitical instability and the UK’s strategic food self-sufficiency targets.

I am submitting these comments as an interested stakeholder concerned with the long-term safety and economic resilience of the UK’s agricultural infrastructure.

Title: Technical recommendations for the protection of the UK agricultural sector and food chain against PBDD/Fs and mixed PBCDD/Fs

1. Executive summary

The UK agricultural sector faces a dual threat from Polybrominated Dibenzo-p-dioxins and Furans (PBDD/Fs). Contamination enters the UK food chain via imported feed and chemical precursors, while local ‘on-farm’ practices, such as the burning of plastic waste, risk the long-term chemical integrity of UK soil. This submission proposes a ‘policing-first’ regulatory framework to ensure the safety of the UK food chain and the economic security of British farmers.

2.Regulatory focus: policing imported inputs

As a net importer of food and feed, the UK’s primary risk is the entry of dioxin precursors through global supply chains.

• Mandatory import certification: legislation should require that high-risk imports (fishmeal, fish oils, and animal fats) carry a certificate of analysis proving that Brominated Flame Retardant (BFR) levels are below established safety thresholds
• Chemical impurity standards: HSE should mandate that all halogenated agricultural chemicals (pesticides and disinfectants) sold in the UK be certified free from unintended PBDD/F or PBCDD/F impurities

3.On-farm prevention: periodic inspection schedules

Preventing the ‘on-site’ formation of dioxins requires proactive auditing rather than reactive testing.

• Waste management policing: Integrate a strict, inspected ban on the open-air burning of farm plastics (silage wrap, mulch), treated timber, and chemical containers into existing farm assurance schemes (for example Red Tractor)
• Soil and sludge governance: tighten the Sludge (Use in Agriculture) Regulations to require PBDD/F baseline testing every 3 to 5 years for any food-producing land receiving municipal or industrial sludge

4.Technical feasibility: the ‘indicator’ approach

To manage the high cost of testing for over 4,000 mixed congeners:

• Proxy testing: Use PBDEs (the parent chemicals) as marker indicators during routine checks. High PBDE detections should trigger government-subsidised deep-dive analysis, ensuring broad policing remains financially viable

5.Socio-economic benefits: protecting UK farming

• Export competitiveness: proactive policing ensures UK produce remains ‘clean’ by international standards, protecting the reputation and market access of British beef, dairy, and eggs
• Asset protection: preventing soil contamination today protects the multi-generational capital value of UK farmland from permanent toxic devaluation

6.National security: geopolitical resilience and strategic self-sufficiency

In light of current international conflicts and supply chain volatility, this risk profile is a matter of national security.

• Protecting self-sufficiency targets: the UK Government Food Strategy aims to maintain domestic production levels. To meet these targets in a crisis, the UK’s ‘natural infrastructure’ (soil and water) must be free from persistent toxins
• Strategic autarky: should global conflict halt food imports, the UK must be able to pivot to 100% domestic consumption. If our domestic land-bank is contaminated due to a lack of current policing, this pivot becomes a public health catastrophe
• Sovereign food safety: ensuring a clean domestic food supply is a defensive necessity, preventing ‘cascading shocks’ where toxic exposure could destabilise the nation during a time of emergency

7.Conclusion

The UK must transition from a reactive stance to a proactive ‘policing’ stance. Securing our food supply today is a prerequisite for national survival in an increasingly volatile world.

AXREM

AXREM welcomes the opportunity to comment on the revised documents arising from the 2025 review cycles under the Stockholm Convention, including the revised draft risk profile for PBDD/Fs and PBCDD/Fs and the revised indicative lists for long‑chain PFCAs and related substances. AXREM represents manufacturers and suppliers of medical imaging, radiotherapy and wider medical technologies used in critical healthcare settings globally.

Importance of international and EU alignment:

AXREM supports a coherent and internationally aligned approach to POP identification, risk profiling, and control measures under the Stockholm Convention. In this context, alignment between convention decisions, EU implementation, and subsequent UK domestic measures is particularly important for globally manufactured medical technologies.

Inconsistent thresholds, definitions, or exemption wording at international level can cascade into divergent national implementations, increasing supply chain complexity and compliance burdens without delivering proportionate environmental benefit.

Medical devices and exemption language:

AXREM notes that medical imaging and radiotherapy equipment are relevant to several POP discussions, including Dechlorane Plus and flame‑retardant substances. AXREM recommends the use of broad, internationally recognised terminology, specifically ‘medical devices’ and ‘in‑vitro diagnostic medical devices’, consistent with existing Stockholm Convention decisions and EU regulatory frameworks.

Such terminology ensures that convention outcomes are applied consistently across medical technologies with similar risk profiles, lifecycles, and servicing requirements, rather than creating unintended gaps or overlaps between sub‑categories of healthcare equipment.

Dechlorane Plus and trace concentrations:

AXREM highlights the importance of clarity and technical robustness when considering trace concentration thresholds for substances such as Dechlorane Plus. AXREM notes a potential inconsistency in the proposed UTC limits for Dechlorane Plus, The UTC limits for DP+ are 0.0001 (EU) & 0.001 (UK), so are less stringent for GB.

Many POPs relevant to medical devices are intentionally used additives at functional concentrations, while unintentional trace presence arises upstream during raw material production. AXREM encourages that convention‑level discussions fully consider:

• realistic points of control within the supply chain
• laboratory detection limits and analytical variability
• the need for thresholds that are technically achievable and enforceable across jurisdictions

Legacy equipment and long service lives:

AXREM supports the continued use of lifecycle‑based exemption wording within the convention framework, recognising that medical devices commonly remain in service for decades. Exemptions allowing use ‘until the end of service life or until 2041, whichever comes earlier’ are essential to ensure patient safety, continuity of care, and the responsible management of installed medical equipment.

Closing comment:

AXREM supports the objectives of the Stockholm Convention and the role of the POPRC in protecting human health and the environment. AXREM encourages that:

• decisions remain grounded in robust technical and supply chain realities
• medical technologies are addressed using clear, harmonised terminology
• international outcomes enable consistent downstream implementation by parties, including the EU and UK

AXREM and its members stand ready to support ongoing engagement and evidence development under the convention process.

Government response

Information received through this call for comments helped to inform the UK’s submission of information to the Stockholm Convention’s POPs Review Committee (POPRC).

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