Every response is important. It’s a rare opportunity for you to make a difference. Access the consultation website here.
See the guidance and considerations below to assist in answering some of the questions.
There has been some unbalanced negative media reporting about woodburning. It’s worth knowing that Air quality in the UK is the best it’s ever been. The latest government statistics show a 7.4% reduction in particulate emissions from fires 2023 to 2024. Between 2018 and 2024 there was a 26% reduction. (Emissions of air pollutants in the UK – Particulate matter (PM10 and PM2.5) – GOV.UK)
Regulatory and industry initiatives already in place will continue this downward trend and we feel that some of the proposals in the consultation are not required or fail to deliver positive messaging. Please respond to the consultation and let them know what you think?
Guidance and considerations
Questions 1 to 9 are for your personal details. The following considerations are that of the Guild of Master Chimney Sweeps and other professionals from the solid fuel industry. You may find these useful in completing your own response. The guidance is in red.
9. Do you feel the proposed new emissions limit of 1g per hour (plus 0.1g per 0.3 kW of output) for stoves is appropriate?
Yes
If no, please explain what you feel the emissions limit should be and why
Yes – Provided the stated 70% of current appliances are already meeting this limit. However, as emissions from domestic combustion are firmly on a downward trend and recent ongoing mitigations have yet to be fully realised in the statistics, new limits may not be necessary.
10. Do you have any comments on the impact (positive or negative) resulting from the proposed new standard? This could be in terms of air quality, human health, the economy or the stove industry, for example.
Broadly positive in terms of air quality although it must be noted that the downward trend in emissions from domestic burning is well established over recent years. Gains from previous regulatory changes for stoves and fuels and the pro-active efforts from the industry on consumer habits and awareness will continue to deliver improvements in air quality.
11. To what extent do you agree or disagree that a 3 – 5-year timescale for the new limits coming into force following new legislation is appropriate?
12. If you disagree, please explain why and give your views on an alternative timeframe
A suitable period should be allowed to accommodate industry adaptation
14.Do you have a view on which standard or regime could be used for a single testing regime for appliance emissions?
15.To what extent do you agree or disagree that solid fuel appliances should be subject to periodic retesting after being on the market, to ensure continued compliance with air quality and efficiency standards? [Strongly agree; agree; neither agree nor disagree; disagree; strongly disagree; don’t know]
Disagree – If the appliance design has not been modified then it’s not required to re-test the model. If there have any modifications to the design, then the appliance would be required to be retested anyway
16.How often do you think retesting should be carried out?
- Every 2 years
- Every 3 – 4 years
- Every 5 – 6 years
- Every 7 years or more
- Don’t know
17.To what extent do you agree or disagree with the introduction of a mandatory labelling scheme for solid fuel appliances?
Please provide further detail to support your response.
Neither agree or disagree but If labelling is to be used then it should prompt positive actions on appliance servicing and chimney maintenance and best burning practice which have positive impact. Warnings are not the way forward.
19. To what extent do you agree or disagree that the example label above effectively communicates information about the air pollution emissions of a solid fuel appliance?
Disagree
20. Please provide further detail to support your response.
Disagree – it doesn’t prompt any action for the consumer on what to do or where to go for positive information and advice on the things that make a difference to what comes out of their chimney such as regular servicing and maintenance and bespoke advice from their sweep.
21.To what extent do you agree or disagree that the example label effectively informs consumers about the fuels permitted for use in a given solid fuel appliance?
Agree
23.To what extent do you agree or disagree that health labelling should be mandatory on solid fuel appliances?
Strongly disagree
24.Please provide any evidence you have to support your response.
Strongly disagree. Toasters, candles, ovens, air fryers, plugin air freshners etc. have no warning labels and yet are a greater source of particulates in every home. Barbeques, firepits, pizza ovens do not have warning labels and labels are not appropriate for stoves. Any labelling should be a call to positive actions on regular maintenance and cleaner burning practice
25.To what extent do you agree or disagree that the example label above effectively conveys that there are health impacts of using solid fuels appliances to consumers?
Strongly disagree
27. To what extent do you agree or disagree that the health statement “Please be aware that this appliance emits air pollution which can harm your health” is appropriate?
Disagree
28. If you disagree, please suggest an alternative health statement
Disagree – we don’t have this on the many other appliances and products which emit particulates so it’s not appropriate for stoves. The same stove will burn wood which is a net-zero CO2 fuel at the point of use – we are told that using energy which does not contribute to CO2 emissions is a benefit – why not state this benefit instead.
“This stove can burn wood which is a net zero CO2 fuel at point of use”
29. Are there any additional elements or considerations which you think should be included in the labelling specification or design?
Any labelling should reinforce positive action such as correct fuel, correct burning practice and regular service and maintenance.
30. [If yes] What considerations you think should be included in the labelling specification or design
Any label should instruct the user ‘Speak to a Sweep’ for bespoke advice on cleaner burning practice and engage a professional sweep for regular service and maintenance.
31. Do you agree or disagree that Trading Standards should be the enforcing body for the proposed labelling requirements?
Agree
33.To what extent do you agree or disagree that a range of penalties between £300-£2000 should be used for breaches of the proposed new labelling requirements? If you disagree, please provide alternative options
Neither agree or Disagree
35. To what extent do you agree or disagree that an increased penalty within the proposed range of £300-£2000 for repeat offenders should be introduced to deter continued non-compliance?
Neither agree or disagree
37. To what extent do you agree or disagree that the enforcing body should be able to enter a premises at a reasonable time, inspect goods and require persons to provide information?
Neither agree or disagree
39.To what extent do you agree or disagree that the enforcement authority should be allowed to charge persons the costs incurred in performing their functions?
Strongly disagree
40. Please provide further detail to support your response.
An enforcement authority should be independent and free from financial incentive
41.To what extent do you agree or disagree that health labelling should be mandatory on solid fuel packaging?
Strongly disagree
42. Please provide any evidence you have to support your response.
The graphic is disproportionate and highly misleading
43. Are there any additional elements or considerations which you think should be included in the labelling specification or design?
Yes
44. [If yes] Please provide details of the other elements or considerations you think should be included in the labelling specification or design
Prompting correct storage and appropriate use / right appliance use and smoke control areas and ‘speak to a sweep’ for bespoke advice on efficient burning practice
45. Which of the following health statements do you prefer, and why?
- Option A: This product causes negative health impacts
- Option B: This product causes negative health impacts to you and your family
- Option C: Burning solid fuels to heat your home can lead to debilitating health conditions, including cardiovascular disease and asthma, which can result in premature death
46 Please give a reason for your choice
Don’t agree with any – we want positive messaged that promote best burning practice
48. To what extent do you agree that increasing the fixed penalty notice for suppliers under the Domestic Solid Fuels Regulations would deter non-compliance?
strongly disagree
49. What do you think the cost of a fixed penalty notice should be for suppliers breaching the Domestic Solid Fuels Regulations
£300 is enough for small dealers,
50. To what extent do you agree that an increased penalty for repeat offenders should be introduced to deter continued non-compliance? [Strongly agree; agree; neither agree nor disagree; disagree; strongly disagree; Don’t know].
Agree
