Environmental guidance legislative overview replaces earlier fact file
The Fire Industry Association (FIA) has published a new Environmental Guidance Legislative Overview, replacing the withdrawn Fact File 36 from 2009.
The FIA described the document as a high-level guide to current UK environmental legislation that may affect fire protection companies.
The FIA said the overview is intended to raise awareness rather than provide an exhaustive list of legal duties.
The document focuses on England and Wales, with the FIA noting that different regulatory regimes apply in Scotland and Northern Ireland.
The FIA stated that responsibility for compliance rests with individual companies.
What the guidance covers for fire protection companies
The FIA explained that UK environmental law has changed substantially since 2009, particularly following Brexit.
The document outlines three elements of the current framework: retained EU regulations amended for UK use, new UK domestic regulations, and separate devolved regimes in Scotland and Northern Ireland.
The guidance points to the Environment Act 2021 as a starting point for understanding the current framework.
The FIA organises the overview around climate change controls, sustainable design requirements, pollution permitting, waste management regimes, and chemical product restrictions.
The climate change section includes ozone-depleting substances rules, describing bans on halon in new systems and licensing for certain critical uses under DEFRA.
The overview also summarises duties under the Fluorinated Greenhouse Gases Regulations 2015 as amended in 2020, including leak checks for stationary fire suppression systems containing F-gases, record keeping for gases charged, recovered or destroyed, and certification requirements for individuals and companies.
The sustainable design section summarises the Eco-design for Energy-Related Products Regulations 2021 and references the EU Ecodesign for Sustainable Products Regulation 2024/1781, describing an expectation that manufacturers consider impacts across sourcing, manufacture, transport, use and end-of-life recovery.
For construction products, the overview describes the Construction Products Regulations 2022 and states that since 1 January 2023 either CE or UKCA marking is acceptable for new products placed on the UK market.
The pollution permitting section summarises the Environmental Permitting (England and Wales) Regulations 2016 and describes that certain activities require an environmental permit, with conditions based on Best Available Techniques and covering emission limits, monitoring, accident prevention and site restoration.
The waste section summarises WEEE rules, stating that many fire products such as smoke detectors and control panels fall under Category 9 and that obligated producers must label products, fund end-of-life collection and recycling, and report annual tonnages to the Environment Agency.
The overview also summarises hazardous waste rules, including that certain firefighting gases such as HFC 227ea and HFC 23 are classified under European Waste Catalogue code 14 06 01 and must be accompanied by consignment notes with records retained for three years.
The packaging section describes the UK Extended Producer Responsibility scheme and references the EU Packaging and Packaging Waste Regulation (EU) 2025/40, outlining tighter targets around recycled content, material labelling and reuse.
The chemical restrictions section includes RoHS requirements for electrical and electronic equipment, UK REACH registration conditions for substances used in fire products, and PFAS controls including that certain PFAS are already banned under the UK POPs Regulation with deadlines for removing and disposing of legacy foams.
The guidance outlines Environmental Product Declarations as standardised independently verified documents, stating they are not currently mandatory in Great Britain for fire safety products while referencing EU requirements such as the EU Battery Regulation 2023/1542 digital battery passport and carbon footprint disclosure from 2026 or 2027 for certain batteries.
The overview briefly outlines the UK Carbon Border Adjustment Mechanism starting on 1 January 2027 and lists the product groups it will apply to, including aluminium, cement, fertiliser, hydrogen, and iron and steel.
The document also lists official sources of further information including GOV.UK, DEFRA, the Environment Agency, the Scottish Government, SEPA, and DAERA.
It also includes an Annex A diagram mapping how different environmental regulations intersect with stages of a product lifecycle from raw material extraction through to recycling and disposal.
The FIA’s overview frames environmental regulation as more complex than in 2009 and sets out how overlapping regimes can affect fire protection companies, with compliance remaining the responsibility of individual organisations.