Guidance

Shredding waste upholstered domestic seating containing POPs: RPS 264

Updated 9 June 2026

Applies to England

This regulatory position statement (RPS) does not change your legal requirement to take all reasonable steps to avoid contaminating other waste with persistent organic pollutants (POPs) when you shred waste upholstered domestic seating at a waste treatment site.

However, the Environment Agency will not normally take enforcement action against you if you do not comply with this legal requirement provided that:

• your activity meets the description set out in this RPS
• you comply with the conditions set out in this RPS

In addition your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:

• cause a risk to water, air, soil, plants or animals
• cause a nuisance through noise or odours
• adversely affect the countryside or places of special interest

Activity this RPS applies to

This RPS applies to waste treatment sites that have a permit to store and shred waste upholstered domestic seating (WUDS) waste code 20 03 07. It allows the shredding of WUDS without equipment to capture and abate emissions whilst fugitive monitoring is carried out.

WUDS must only be shredded where the destination incinerator requires it. If there is no requirement for WUDS to be shredded this RPS does not apply.

Conditions you must comply with

You must:

• have evidence that the destination incinerator requires WUDS to be shredded
• store and shred WUDS on an impermeable surface and prevent water contaminated with particulates from shredding WUDS entering drainage systems
• shred WUDS inside a building or within a temporary waste storage shelter which is enclosed on 3 sides with a roof
• minimise fugitive dust emissions from shredding waste upholstered domestic seating, examples of methods you can use are included in the ‘things to note’ section
• prevent dust and particulates from being tracked out of the building or shelter
• if the shredding equipment is also used for other wastes clean the equipment before the other types of waste is shredded to prevent cross contamination
• store the shredded WUDS inside a building, in a sealed container, or bale and securely wrap it
• send the shredded WUDS and fractions from the shredding process for destruction at an appropriately authorised Industrial Emissions Directive Chapter 4 compliant permitted incinerator
• once shredded the waste must be transported directly to the destination waste incineration site
• agree a fugitive monitoring plan for your shredding process with the Environment Agency
• monitor the fugitive emissions from shredding waste upholstered domestic seating in line with the agreed fugitive monitoring plan
• email the results of the fugitive emissions monitoring to the Environment Agency at popsinsofas@environment-agency.gov.uk 
• commission and install equipment to capture and abate fugitive emissions by 31 December 2028 if your monitoring results indicate fugitive emissions need abatement
• keep records for 2 years from the date of the last use of the RPS to show that you have complied with this RPS and make these records available to the Environment Agency on request

You must not shred WUDS if the destination incinerator can accept it un-shredded.

Things to note

Examples of methods you can use to minimise fugitive dust emissions from shredding waste upholstered domestic seating include:

• installing misters and sprays over the shredder hopper, conveyor systems and within buildings
• installing hoods on shredder and conveyor outlets
• reducing how far the shredded material drops from loading and conveyor systems into the storage areas
• using dust suppression canons or sprays to control point source emissions of particulates
• cleaning the shredder and areas around it regularly to prevent build-up of particulates
• using wind reduction netting, lamella curtains or other wind reduction measures in wide doorways

Further guidance is available about managing WUDS containing POPs.

When you must check back

The Environment Agency will review this RPS by 31 December 2028.

The Environment Agency can withdraw or amend this regulatory position before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

You can subscribe to email updates about this RPS. These will tell you if the RPS has changed and when it has been withdrawn. Use the ‘Get emails about this page’ feature on the RPS publication page. 

If you cannot comply with this RPS

If you operate under this RPS but can no longer comply with it, you must:

• stop the activity to which this RPS relates
• tell the Environment Agency immediately by contacting popsinsofas@environment-agency.gov.uk with RPS 264 in the subject

Contact the Environment Agency

If you have any questions about this RPS, email popsinsofas@environment-agency.gov.uk with RPS 264 in the subject.