Committee’s Support for Restriction Proposal

France has proposed a restriction on the secondary use of wood treated with creosote and related substances, and the Committee for Risk Assessment (RAC) at the European Chemicals Agency (ECHA) has expressed its support for this proposal. RAC believes that an EU-wide restriction is necessary to address the harmful effects of these materials, known to be carcinogenic, persistent, bio-accumulative, and toxic. Such a restriction would help reduce environmental emissions and limit public exposure to these hazardous substances.

Exclusion of Specific Substance 

RAC has recommended the exclusion of wood creosote (CAS: 8021-39-4) from the proposed restriction, citing its dissimilar hazardous properties compared to other substances in question.

Promoting Wider Reuse 

Furthermore, the committee aligns with the Committee for Socio-Economic Analysis (SEAC) in endorsing the idea of permitting the reuse of creosote-treated railway sleepers and utility poles by all professionals within a given country, rather than limiting it to the original user, as initially proposed by France. This approach is anticipated to yield more significant environmental benefits when compared to procuring newly treated wood, which is expected to reach more pollutants than its aged counterpart.

Support for a Comprehensive Ban 

RAC is committed to backing the ban on all secondary uses of creosote-treated wood, citing the availability of safer alternatives in the market.

SEAC’s Backing and Emphasis on Benefits 

The draft opinion from SEAC similarly supports the proposed restriction, emphasizing its substantial health advantages and relatively low associated costs. SEAC has extensively analyzed the benefits of extending reuse permissions to professionals beyond the original user. However, the committee emphasized that the benefits can only be maximized if public access to creosote-treated wood is restricted.

Further Deliberations and Consultation 

In its ongoing deliberations, SEAC seeks additional information regarding the potential secondary effects of inter-company trade and the appropriateness of the suggested 12-month transition period for implementing the restriction.

Opportunity for Stakeholder Input 

Interested stakeholders and the public are encouraged to provide input during the 60-day consultation period for the SEAC draft opinion, which remains open until November 7, 2023.

Expected Decision Timeline 

A decision by the committee regarding its opinion is expected to be reached in December 2023.


Reach out to our regulation experts on chemical and product regulatory compliances