New Polish Act on Biocidal Products

On December 5, 2015, Polish officials issued a new administrative ordinance for biocidal products. For registered biocidal products and new registrations of biocidal products, the regulation requires certification that the supplier of the ingredients contained in the products is entered in the Article 95 List. The manufacturer or importer listed must also be certified as the vendor. The requirement also applies to the registration of biocidal products whose ingredients have not yet received final approval. With this regulation, Poland added the required certifications to the valid requirements of the EU Biocidal Products Regulation 528/2012.

According to the regulation, no biocidal product may be brought to market if it contains an ingredient without a corresponding manufacturer or importer on the Article 95 List. A transition period applies only to warehouse stock, which can be used until September 1, 2016 even if the supplier of the ingredient is not on the list.

How does a company get on the Article 95 List? According to Article 89 of the Ordinance on Biocide Products, companies that participate in a program that systematically inspects all older ingredients are automatically included in the Article 95 List. It does not matter if such companies manufacture or supply a biocidal ingredient or a biocidal product.

Other firms have the option to submit a dossier or a letter of access for a dossier to the European Chemicals Agency (ECHA)

The information is of interest to companies that put biocidal products on the market or use them. It is also interesting to companies that sell treated goods like antimicrobial textiles. If you have any questions, please contact us at You might also consider our seminar on the new European Biocide Law on April 20.

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