Restriction on the placing on the market, re-use and secondary use of wood treated with creosote or related substances
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Link to the Consultation Guidance Link to the Information Note
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It is possible to provide both general comments on the Annex XV restriction report subject to this Consultation and answers to the specific questions posed. In both cases, it is necessary to provide supporting evidence to allow ECHA’s Committees to take your comments into account. It is important not to leave the submission of any socio-economic information until the consultation on SEACs opinion but already submit relevant comments at this stage.
General Comments
Select the relevant boxes that cover the content of your comments and provide your non-confidential comments below, (maximum 9 000 characters)
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Please provide your general comments in the box below
Which substances among the nine listed in Entry 31 of REACH Annex XVII have been used in the EU to treat wood in the last decades https://echa.europa.eu/documents/10162/a27e80a3-3798-3c76-01a0-32357cc09f6f )? In which country? Please provide all available information, including examples of uses, and indicate when the use has taken place.
* Compulsory Fields
Creosote-treated wood (railway sleepers and transmission poles for telecommunication/electricity) can be reused for the same purpose as the original use (e.g. sleepers can be reused as sleepers). Are you aware of reuse of creosote-treated wood in your country or in other countries? Please also include information on the volume of reuse in specific countries and its expected future development.
Secondary use of creosote-treated wood can also take place in some countries (e.g. railway sleepers used for other purposes, such as agricultural fencing or residential landscaping). Is creosote-treated wood currently available in your country for secondary uses by consumers and/or professionals? Please provide examples of known secondary uses in your country. Where possible, please include any available information on their volume and indicate if information about the year/date the wood had been treated with creosote is usually available at the point of sale.
What is the volume of imports, in your country, of creosote treated wood (as railway sleepers and transmission poles) from other EU and non-EU countries? What is the volume of exports to other EU and non-EU countries? If possible, indicate how those volumes are expected to develop in the future.
Is imported creosote-treated wood being classified as hazardous waste in your country?
Please provide qualitative or quantitative information about the expected socio-economic impacts of the restriction proposal for the private/touristic railway networks, NRIMs (National Railway Infrastructure Managers) and other actors in the EU or at national level. This could include information on, for example: 1) installation and maintenance costs of different types of railway sleepers, 2) additional costs besides installation and maintenance costs, 3) indirect impacts from substitution and resulting extra costs (e.g. freight traffic ending on some sidings), 4) affordability and economic feasibility of substituting reused creosote-treated wooden sleepers with alternatives.
Chemical alternatives to creosote as well as alternative materials such as concrete, steel or plastic have been identified by the Biocidal Product Committee, (BPC) as potential alternatives to creosote-treated railway sleepers and transmission poles (https://echa.europa.eu/documents/10162/fc41edcf-3732-2ba9-6a14-0fb9b423fd6c). However, BPC also concluded that additional time is needed to enable the necessary progress on the availability and technical applicability of these alternatives. Please provide any additional information on the availability and costs of alternatives to a) reuse of creosote-treated railway sleepers and transmission poles, and b) secondary use of creosote-treated railway sleepers and transmission poles.
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