It appears that yet another EU Directive is to have a significant impact on the timber treatment industry from July 2015 and yet everyone is still unclear as to what the rules are, whilst many might question the logic or sense behind it and whether it is actually a constructive step. As MD of an established dual sited timber treatment company, I am certainly in this camp and feel the need to raise my concerns more prominently within the industry.
The IED (Industrial Emissions Directive) is an EU Directive that was adopted by the EU Parliament in 2010. It became effective for new timber treatment installations in January 2013 and will become effective for existing installations from July 2015. The essence of the Directive is that a timber treatment plant with the theoretical capacity to process at least 75m3 a day will need to apply for an IED permit, costing the company (regardless of size) in the region of £5,000 for the first year and then about £3,000 annually thereafter, depending on the site’s location in the UK. This cost is in addition to any necessary capital investment required to meet the IED requirements.
Whilst the UK appears not to be questioning this EU “guidance”, other countries such as Germany, Sweden and France are appreciating the lack of logic here and developing a more sensible approach. They can see it is wrong to calculate a figure on theoretical treatment capacity because even if a site did run solid for 24 hours, it may not have sufficient post treatment storage capacity or resource to manage all of the timber! So the logic is entirely wrong and needs to be questioned thoroughly. This distinct difference in interpretation of the IED by other European countries is already putting the UK timber industry at a disadvantage.
And so the UK is soldiering on with implementation whilst there is a total lack of understanding of the rules that timber treatment plants will be expected to abide by in order to gain an IED Permit. Yet we are being urged to apply for such a permit by the end of 2014 as the consequences of not having one will apparently be serious. We are being urged to apply for something that is yet to make any sense at all. Is this how the UK wishes to support so many small to medium sized companies in the timber industry?
Whilst I appreciate the environmental angle of the IED, the chemical manufacturing companies have already spent many years and many millions of Euros ensuring that preservative treatment chemicals meet the stringent European environmental requirements of the Biocidal Products & REACH regulations. This legislation saw a significant number of “active ingredients” that were used in preservative treatment chemicals being outlawed. Indeed the products that our industry now uses are in excess of 90% water! So why is the UK government now looking to impose what simply appears to be an annual tax of £3,000 per site on timber treatment companies? If I could understand the benefit to my company I might be able to take a broader view on the issue but I cannot find a single benefit to highlight, having had sight of the draft guidance notes; the UK’s interpretation of the IED (SG11).
I have personally been raising my concerns over the IED to my local politicians and anyone else that is prepared to listen! We urgently need to react to this Directive before the UK simply adopts it without any further discussion over what is actually required in our industry and sensible to progress. If our neighbours the Germans, Swedes and French can see that this Directive needs quite a bit of correction to be fair and sensible, why can we not see this in the UK? I would suggest that you contact your local politicians to urge our policy makers to employ some common sense before the IED regulations have a negative impact on our industry and ultimately the profitability of our businesses.
WJ Group MD
*REACH: Registration, evaluation, authorization and restriction of chemicals