Creosote in France 2026: what treated wood manufacturers and importers must do

Key data

If your company manufactures, imports or distributes railway sleepers, electrical poles or construction elements treated with creosote, this decision directly affects you. The European Commission has published Implementing Decision (EU) 2026/1377 of 11 May 2026, which amends Implementing Decision (EU) 2019/961 and extends the provisional measure adopted by France under Article 129 of the REACH Regulation.

This is not a brand new restriction from scratch: France already had a provisional measure in place since 2019. What this decision does is extend its validity, reinforcing national restrictions on the use and marketing of wood treated with creosote and other substances related to this compound.

What does this regulation establish?

Creosote is a chemical compound derived from coal tar, classified as carcinogenic and hazardous to the aquatic environment. Its use in wood treatment—especially in railway sleepers and electrical poles—is subject to progressive restrictions in the European Union under the REACH framework.

Decision 2026/1377 amends Decision 2019/961 in the following terms:

Article 129 of the REACH Regulation allows Member States to adopt provisional restriction measures when they consider that there is a serious risk to human health or the environment requiring urgent action, before the EU adopts a harmonized restriction at European level.

This extension also has a regulatory signal value: when a Member State maintains and reinforces a provisional measure over years, it typically precedes a REACH restriction at European scale. Companies operating in other Member States should take this into account in their planning.

Economic and operational impact

The main impact is not a direct fine, but the restriction of market access to France for products containing creosote-treated wood or related substances. This translates into concrete operational consequences:

• Supplier review: Companies supplying treated wood to customers in France must verify that their products do not contain creosote or related substances, or that they comply with authorized exceptions.
• Material change: Sectors that have historically used creosote-treated wood—railway, electrical, construction—must accelerate the transition to alternatives (wood treated with other preservatives, concrete, composite materials).
• Risk of border retention or market withdrawal: Products that do not comply with restrictions may be withdrawn from the French market by the competent authorities.
• Anticipatory effect in other EU markets: Although the measure is French national, its prolonged maintenance anticipates a possible harmonized REACH restriction. Companies operating in other EU countries must prepare in advance.

No specific economic impact figures are published in the regulation. The actual cost will depend on the volume of affected product in each company and the cost of material substitution.

Who does it affect?

• Manufacturers of creosote-treated wood that export or sell in France.
• Importers of treated wood that introduce these products into the French or EU market.
• Distributors and marketers of wood for industrial use or in infrastructure in France.
• Railway sector companies that use creosote-treated wooden sleepers.
• Electrical and telecommunications companies that use treated wooden poles.
• Construction companies that use structural elements of wood treated with these substances.
• REACH compliance advisors and product managers in companies operating in France or exporting to the EU.

Practical example

A Spanish company manufacturing railway sleepers that treats wood with creosote and exports part of its production to railway infrastructure managers in France is directly affected by this decision.

With the extension of the French provisional measure, that company cannot market its creosote-treated sleepers in the French market without breaching the national restrictions in force. The options it has are:

1. Verify whether its product falls within any exception authorized by French regulations.
2. Replace the creosote treatment with an alternative approved preservative for railway use.
3. Redirect that production to markets where creosote is still permitted, assuming that window may close if the EU adopts a harmonized REACH restriction.

This case illustrates why the decision is not just a French matter: any European manufacturer or importer with a presence in France must review their compliance situation now.

What should companies do now?

1. Audit your product catalog: Identify which references contain creosote-treated wood or related substances and whether they are marketed in France.
2. Review the supply chain: Verify with suppliers whether the materials received comply with REACH restrictions and the French provisional measure.
3. Consult current exceptions: The regulation may contemplate specific authorized uses. Review the full text of Decision 2026/1377 and Decision 2019/961 that it amends.
4. Plan material substitution: If the company depends on creosote-treated wood, start evaluating technical alternatives and their impact on costs and approvals.
5. Monitor REACH developments at European level: The prolonged maintenance of this French provisional measure may anticipate a harmonized EU restriction. Stay informed of procedures underway at the European Chemicals Agency (ECHA).
6. Document compliance: Maintain updated records that demonstrate that products marketed in France comply with current restrictions, in case of inspections.

Official source

Consult full regulation at official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601377