Call for information on impact of potential ban of Propiconazole as a wood preservative for doors and windows
I am writing to you regarding the issue of the possible ban of Propiconazole, currently used by manufacturers of wooden products (e.g., doors and windows) as a wood preservative. Its ban could lead to unprecedented consequences for the timber window and door industry, which is made up primarily of small businesses, including thus perhaps some of your members at national level.
The approval period for the use of Wood Preservatives is up for renewal on 31 December 2022. The expiry date of the use of Propiconazole is primarily a consequence of its recent classification as Reprotoxic 1B (toxic for reproduction) by the Risk Assessment Committee (RAC) of ECHA (European Chemicals Agency), but at the same time there is not, to our knowledge, an alternative biocidal product for the same applications. The file is regulated by ECHA’s Biocidal Product Committee and is being increasingly monitored by the European Commission’s DG SANTE.
In this context, in its quality of Small Business Standards (SBS) coordinator for construction, EBC was contacted last year by EuroWindoor (the association of European window, door and facade manufacturers) to explore possibilities to position on the dossier. This lead to a SBS, CEI-Bois (the European Woodworking Industry Confederation) and EuroWindoor joint position in August 2021 calling for a renewal of the approval of Propiconazole until an equivalent substitute is available, tested and assessed for use in timber windows and doors. They also contributed together to the open public consultation that aimed at identifying alternatives as potential candidates for the substitution of Propiconazole that was ran by ECHA’s Biocidal Product Committee.
Recently, EuroWindoor has created a task group to assess next steps on the dossier, to which SBS will participate. Their main points of discussion will be:
- Justifying the safe use of Propiconazole as a wood preservative (e.g., different to agricultural use, which is already banned)
- Making the case for a derogation post-2023 or a prolongation of use for 5 years/until safer alternatives are on the market
- Organising a first public event to promote the joint position, extending the partnership to as many wood stakeholders possible (logo) to increase legitimacy
- Start preparing a joint reply to the upcoming consultation on derogations in summer 2022
- Do you have any technical information on the use of propiconazole and the potential impact of its ban at national level?
Please consider sending us any opinion and material you might have on the topic, so that we can better assess if there is a need for EBC to get involved directly (policy) or if we should keep monitoring the dossier through the SBS expertise (technical).
Feel free to get back to me for any additional information you may need.
The National Guild of Mastercraftsmen is Irelands representative in EBC -The European Builders Confereration.