With the withdrawal of Low Risk Waste Position (LRWP43) in 2021, the Environment Agency (EA) introduced a Regulatory Position Statement (RPS248) framework based on certain conditions such as testing for specific chemicals and removing all contamination from the carpet waste streams to allow the practice of shredding carpet waste for use as equine surfaces. The introduction of the RPS was a way for the EA and recycling sector to continue to build their understanding and evidence of the practices of using shredded carpet and textile flooring material on equine surfaces. RPS248 was adopted in England, Ireland and Scotland with Natural Resources Wales (NRW) deciding to opt-out and not allow the practice to continue unless both the producer and the end customer had an environmental permit. As with all Regulatory Position Statements, these are to be reviewed on an annual or regular basis to ensure the practice is still classed as being a low risk.

At the beginning of October 2023, the EA contacted CRUK to discuss RPS248 and its latest position. The EA informed CRUK that it no longer considers the practice to be low risk and therefore has decided to withdraw the framework. The key issues mentioned are that certain samples tested do contain both traces of PFOA and PFOS chemicals.  At the time of testing the samples (2021/22), the thresholds of such chemicals were 50mg/kg. The European Union (EU) has now reduced these to 1mg/kg.  Although the majority of the samples were under the applicable thresholds, the EA is still concerned that they exist, albeit, in small traces.  In addition, they are also concerned with the issue of microplastic being released from the synthetic surfaces which could potentially pollute neighbouring areas and water courses.  However, no specific analysis or testing has been conducted by the EA to say that surfaces once laid release microplastics.

The EA has now sent out information on its withdrawal of RPS248 to all interested parties on its database and this has also appeared in certain publications. CRUK is concerned that the withdrawal date is not sufficient enough time for alternative outlets to be established and the effects of this will be quite widespread across the waste management industry.

From our understanding, the PFOA and PFOS chemicals were mainly used as stain retardant chemicals across nearly all manufacturing industries (not just the carpet sector) that would need to protect its products in such a way. Certain aftercare products may also have used these chemicals, which the manufacturing sector would have no knowledge or control over. However, it should be stated that the key concern for chemicals is in the old waste/legacy products and not recent or new carpets and textile flooring. CRUK is working with its manufacturing members to better understand when these and other chemicals classed as POPs (Persistent Organic Pollutants) were eliminated from the manufacturing process, so we can better understand what is contained in the waste streams.

CRUK would wants to measure the impact of this withdrawal so we can report back to the sector and the EA and would like to know from you if you have been directly or indirectly affected. Please do contact us at info@carpetrecyclinguk.com