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European Wood Preservative Manufacturers Group

EWPM

The aim of the EWPM is to promote, with integrity, the correct use of wood preservatives including production, transportation, utilization and disposal, by all means including but not limited to: taking any appropriate measures which are legal and are the decision of the voting members 
 acting on behalf of members, to promote an agreed position in all technical, scientific, regulatory, health, safety and environmental protection domains which interest the industry, directly or indirectly, with particular regard to Europe.

Lobbying Activity

Response to Construction services Act

15 Dec 2025

We welcome the Commissions preparation of a Construction Services Act to improve free movement of construction services in the EU. Notably, the Construction Services Act should prioritise the identification and removal of market barriers within the EU that hinder cross-border trade, investments and growth. Such is the case with complex cross-border disposal and shipment of construction and installation waste, like wood, due to inconsistent classification of materials across countries. Particularly, for treated wood, the main barriers are inconsistent waste definitions and missing EU end-of-waste rules for wood. Treated wood is often wrongly classified as hazardous waste, blocking reuse and recycling applications. Classification rules highly differ across the Member States, meaning that the same treated wood material can be regulated differently from one country to another due to the lack of EU end-of-waste criteria for wood. We hope that the Circular Economy Act may partially address this issue by harmonizing wood waste classification rules and the management of hazardous wood waste. However, more is needed to unleash the growth potential of wood in construction, notably by promoting secondary applications aligned with the cascading use principle (reusing, recycling) throughout the construction value chain. This requires e.g. incentives for long-term use of construction materials, green procurement criteria rewarding sustainable and renewable materials with a high carbon storage potential (linked to the CRCF Regulation), and incentives for secondary construction materials (currently not existent in the EU regulatory framework). Lack of harmonised standards, infrastructure and incentives prevents secondary wood markets from developing despite strong circular potential. Diverging national rules mean the same treated wood may be waste in one country and product in another. There are currently no harmonised EU criteria for when wood ceases to be waste. This blocks investment in recycling infrastructure and inhibits cross-border use of secondary wood. Both the Construction Services Act and the Circular Economy Act should include wood in their scope, establishing EU-wide End of-Waste criteria for treated and untreated wood materials, and rewarding the use of secondary construction materials. Harmonised criteria should cover: (a) permitted input grades, (b) mandatory contaminant limits, and (c) a statement-of-conformity for every batch. The absence of harmonised end-of-waste rules and risk-based classification for wood waste fragments the single market. A unified EU framework would unlock investment and enable the free movement of recycled wood products, supporting both circularity and the bio-economy. We recommend to consider establishing EU wide End-of-Waste (EoW) criteria for treated and untreated wood materials. Separate collection of wood waste and early sorting by treatment type are essential to increase reuse and recycling rates. EU guidance should promote municipal and industrial take-back schemes for reusable and recyclable wood. Having a singular stream of waste for each type of wood waste, whether hazardous or non hazardous, with clearly defined categories, is crucial to enhance waste management practices across the EU. It enables more efficient sorting and ensures that each type of wood waste is appropriately managed.
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Response to Single Market Strategy 2025

30 Jan 2025

Ensuring a more efficient, fair and harmonized EU biocide market: EWPMs contribution to the European Commissions call for evidence on the EU Single Market Strategy (January 2025) The European Wood Preservative Manufacturers Group (EWPM) represents the wood preservation sector across Europe, bringing together companies that develop and manufacture wood protection technologies. Our members ensure that wood, as the most sustainable construction material, can be used efficiently, with extended service life and enhanced durability, supporting circularity and carbon storage objectives. Wood preservatives are essential for maintaining the longevity and sustainability of wood-based materials in construction and infrastructure. These products are regulated under the Biocidal Products Regulation (BPR, Regulation (EU) 528/2012), ensuring their safe and effective use. However, regulatory inconsistencies and inefficiencies within the BPR frameworkparticularly concerning mutual recognition procedures (MRP) and delayscreate unnecessary barriers to market access. This fragmentation hinders intra-EU trade, limits industry innovation, and undermines the EUs broader circular economy and decarbonization goals. Mutual recognition is meant to streamline the approval of biocidal products across Member States (MS). However, in practice, inconsistencies in national implementation create significant barriers for businesses operating within the Single Market. Some MS do not adhere to the Rapporteur Member State (RMS) opinion, leading to repeated risk assessments and unnecessary delays. Mutual recognition processes timelines range from 30 days to over a year, leading to market fragmentation and uncertainty. Approval fees differ significantly among MS, ranging from a few thousand euros to over 50,000, making the process unpredictable and cost-prohibitive for SMEs. Additionally, misaligned administrative requirements across MS add further complexity, increasing compliance costs and slowing down innovation in the sector. Wood preservation enables carbon storage in durable wood products, reducing reliance on carbon-intensive materials like steel and concrete. A more efficient BPR process would not only create a level playing field for businesses but also support the EUs climate objectives by promoting the use of long-lasting wood in construction. We recommend the European Commission, together with the Member State authorities: 1. To put in place a binding mutual recognition process that ensures the initial RMS position is automatically accepted by other Member States, preventing unnecessary reassessments and delays. Alternatively, the EU should introduce an automated mutual recognition system after an initial approval, reducing administrative bottlenecks and ensuring a more predictable authorization timeline. 2. To enhance market predictability and fairness, mutual recognition timelines (for MRS and MRP) should be standardized with a uniform deadline of no more than three months. These processes currently represent significant obstacles to the Single Market. Authorization fees should also be harmonized to prevent financial barriers and ensure fair and proportionate costs for market access. 3. To prevent the erosion of data protection for biocidal product dossiers, ensuring that companies investments in research and regulatory compliance are adequately protected will foster continued innovation and maintain a level playing field within the Single Market. 4. To integrate climate considerations into regulatory frameworks and establish a coordinated EU-wide approach to wood waste management, ensuring that preserved wood is recognized for its role in long-term carbon storage, waste reduction, and circularity. This will support its full potential as a sustainable alternative to carbon-intensive materials and align with the EUs decarbonization objectives.
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and EPPA SA and European Institute for Wood Preservation

23 Jan 2025 · Circular Economy

Meeting with Dino Toljan (Cabinet of Vice-President Maroš Šefčovič), Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and

2 May 2024 · Bioeconomy, decarbonisation and the role of wood

Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra) and EPPA SA and European Institute for Wood Preservation

22 Mar 2024 · 2040 target and the role of wood for sustainable construction