- Would you like your response to be confidential?
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No |
| 2. If you answered yes to this question, please give your reason(s) |
- |
| 3. What is your name? |
Redacted - Personal information |
| 4. What is your email address? |
Redacted - Personal information |
| 5. In which part of the United Kingdom are you based? |
England |
| 6. Which part of the UK are you primarily interested in? |
England |
| 7. Who are you responding as (select one option only)? |
Public body or local authority |
| 8. If you are responding on behalf of an organisation, what is its name? |
Greater London Authority |
New stove emission limits
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| 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 |
| 10. If no, please explain what you feel the emissions limit should be and why |
- |
| 11. 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. |
The GLA supports a new UK-wide smoke emission limit of 1 gram per hour for new stoves (down from 5 grams per hour in Smoke Control Areas (SCAs) and replacing emission limits applying to SCAs and in the EcoDesign regulations with a single nationwide standard).
This is also in line with London’s Environment Strategy which calls for tighter minimum emission standards for new stoves.
There are concerns that this may impact homes in London which rely solely on solid fuel burners as their primary heat source such as canal boats. However, the grace period should enable these homes to upgrade. We suggest that a grant should be provided to support this transition.
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| 12. 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? |
agree |
| 13. If you disagree, please explain why and give your views on an alternative timeframe |
- |
| 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 |
| 16. If you put agree or strongly agree, how often do you think retesting should be carried out? |
Every 2 years |
New mandatory labelling scheme for solid fuel appliances
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| 17. To what extent do you agree or disagree with the introduction of mandatory labelling scheme for solid fuel appliances? |
strongly agree |
| 18. Please provide further detail to support your response |
Labelling opinion :
The GLA strongly agrees with the introduction of a mandatory labelling scheme for solid fuel appliances and sees it as an impactful reminder of the negative effects on health from their use. This is also in line with the Mayor’s commitment to raising awareness of the health impacts from wood burning. |
| 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? |
neither agree nor disagree |
| 20. Please provide further detail to support your response. |
Further detail on air pollution information :
We believe the label could communicate information about air pollution emissions more effectively. While we strongly support presenting emissions on a rating scale based on measured performance, consumers currently have no benchmark to understand how these ratings relate to WHO guidelines, DAQI levels, or national standards. We recommend including additional information to indicate the emissions level associated with each rating so that consumers can make more informed purchasing decisions. |
21. To what extent do you agree or disagree that the example label above effectively informs consumers about the fuels permitted for use in a
given solid fuel appliance? |
agree |
| 22. Please provide further detail to support your response. |
Detail on fuel information:
We agree the graphics effectively informs consumers. We suggest ensuring the terminology used such as ‘Manufactured Solid Fuels’ is described so it is clear what this means to a lay person. |
| 23. To what extent do you agree or disagree that health labelling should be mandatory on solid fuel appliances? |
strongly agree |
| 24. Please provide any evidence you have to support your response. |
Detail on health labelling:
The GLA strongly agrees with the introduction of a mandatory health labelling scheme for solid fuel appliance and agrees it’s important this is consistently introduced across all appliances to ensure consumers have access to clear, standardised information, available at the purchase point so they can make an informed choice before they buy. |
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? |
neither agree nor disagree |
| 26. Please provide further detail to support your response. |
Details on health impacts:
We believe it is clear and effectively conveys that use of solid fuel appliances harms health, however we would recommend providing further information about the risks to those who are particularly vulnerable to the health impacts, such as pregnant women, the elderly and children. |
| 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? |
neither agree nor disagree |
| 28. If you disagree, please suggest an alternative health statement |
Alternative health statement:
We strongly recommend including a statement highlighting the risks to individuals who are particularly vulnerable to the health impacts of poor air quality, including emissions from solid fuel burning – such as pregnant women, older people and children. |
| 29. Are there any additional elements or considerations which you think should be included in the labelling specification or design? |
Yes |
| 30. If yes, what considerations you think should be included in the labelling specification or design? |
Labelling considerations:
We suggest adding a QR code linking to further information on the health impacts of poor air quality and practical steps people can take to reduce their exposure, especially those in vulnerable groups. |
| 31. Do you agree or disagree that Trading Standards should be the enforcing body for the proposed labelling requirements? |
Don’t know |
| 32. If disagree, please provide further detail to support your response. |
- |
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? |
agree |
| 34. If you disagree, please provide alternative options |
- |
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? |
agree |
| 36. Please provide further detail to support your response |
- |
| 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? |
agree |
| 38. Please provide further detail to support your response. |
- |
| 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 agree |
| 40. Please provide further detail to support your response. |
- |
Mandatory health labelling for fuels
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| 41. To what extent do you agree or disagree that health labelling should be mandatory on solid fuel packaging? |
strongly agree |
| 42. Please provide any evidence you have to support your response. |
Views on mandatory health labelling:
The GLA strongly agrees with the introduction of a mandatory labelling scheme for fuels as an impactful and regular reminder that burning these fuels have a negative effect on health. This is also in line with the Mayor’s commitment to raising awareness of the health impacts from wood burning. |
| 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 |
Additional elements:
We strongly recommend including a statement highlighting the risks to individuals who are particularly vulnerable to the health impacts of poor air quality, including emissions from solid fuel burning - such as pregnant women, older people, and children.
We also suggest adding a QR code linking to further information on the health impacts of poor air quality and practical steps people can take to reduce their exposure, especially those in vulnerable groups.
|
| 45. Which of the following health statements do you prefer? |
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 |
Reason for label option:
We agree that including a health statement with clear information about the potential health impacts is essential, as it enables customers to make an informed choice before purchasing. We also strongly recommend adding a specific statement on the risks to groups who are particularly vulnerable to the effects of poor air quality, including emissions from solid fuel burning - such as pregnant women, older people and children. |
47. If you would prefer an alternative health statement, please provide this and give your reasoning
Alternative |
- |
Increasing enforcement penalties for non-compliance with The Domestic Solid Fuels Regulations in England
|
| 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? |
agree |
| 49. What do you think the cost of a fixed penalty notice should be for suppliers breaching the Domestic Solid Fuels Regulations? |
£1000 |
| 50. To what extent do you agree that an increased penalty for repeat offenders should be introduced to deter continued non-compliance? |
agree |
| 51. Please provide further detail to support your response. |
- |
Additional evidence
|
52. Do you have any additional evidence, data, or relevant information that should be considered by Defra to inform the development of these
policies? |
Additional evidence:
The GLA supports the Government’s consultation on stricter emission limits for new stoves, a mandatory labelling scheme for stoves and fuels, and increasing enforcement penalties. We would also like to see the Government propose further restrictions such as extending the scope of Domestic Solid Fuel Regulations to those fuels that are used anywhere and tighter smoke emission limits for Manufactured Solid Fuels and would welcome a further consultation on these measures.
In addition, we would welcome a Defra consultation on additional powers that could be devolved to the Mayor and/or London boroughs (and other authorities/cities outside of London) to further reduce emissions from solid fuel burning, such as limiting when burning can take place (including outdoor burning such as domestic bonfires), or introducing area-specific bans, for example through establishing zero emission zones. These measures would enable the Mayor and/or London boroughs to apply further restrictions on domestic burning in defined circumstances, going beyond standard Smoke Control Area (SCA) requirements. These powers could be granted either to all local authorities or only to those with SCAs, allowing them to determine the most appropriate levels of control for their areas, including the option to prohibit domestic burning entirely in certain urban locations.
Strengthening these requirements is particularly important for London, where population density, the prevalence of homes in close proximity, and high existing pollution levels mean that even small increases in solid fuel burning can lead to disproportionately harmful air quality impacts. Tighter controls would help reduce harmful emissions in areas that are already struggling to meet ambitious air quality targets, support borough-level enforcement, and align with the Mayor’s broader commitments to protect public health and reduce exposure –especially for vulnerable groups. We hope to see a further consultation on such measures in the near future.
Finally, it will be important to compliment these regulatory changes with a national awareness campaign. This will both enable people to protect themselves and their neighbours through informed choices about burning, as well as helping people to understand why these are further measures are required
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