Biocidal Products Regulation: Association Clarifies Borderline Questions

The German Association of the Chemicals Industry (VCI) and the German Association of Hygiene and Surface Protection Industries (IHO) have developed a position paper that is to provide clarity on the interpretation of the Biocidal Products Regulation (BPR). Clarity is needed because companies are often unsure how to deal with the question of whether a biocidal product is present or not. For example, does the mere presence of an active biocidal agent like ethanol or citric acid mean that the chemical is to be classified as a biocidal product? 

The authors make quite clear that such is not the case. As the basis for their decision, they note the criteria that must be met. To meet the requirements of the BPR for classification as a biocidal product, a chemical must truly be an effective biocide and be present in the product in a sufficient concentration. Furthermore, the biocidal effect must be stated explicitly and transparently on the label for the consumer. 

According to the authors, many products that contain chemicals with biocidal agents are already covered by other legislative areas. Most disinfectants are regulated by the Medical Products Law, and products used as cosmetics are covered by the Cosmetics Regulation.  

We advise you with regard to the requirements of Regulation (EU) No. 528/2012 (Biocidal Products Regulation, BPR), check the labeling and marketability of biocidal products within the EU and carry out the biocide notification in Germany to the BAuA according to the German “Chemikaliengesetz (ChemBiozidMeldeV)”. If you have any questions, please contact us at sales@kft.de.