Notification Period for Substances Manufactured in situ Expires on April 27, 2016

In situ substances are active substances that are manufactured directly at the point of use from one or more precursor substances. Up to April 27, 2016, a postdated notification can be submitted for combinations of active substances and precursors that are not currently assessed in the context of the existing active substance process. See the in situ list for an overview of the combinations and types of products with ongoing applications and which require postdated notification. The list was approved at the meeting of the member states in March 2015. It is found in the appendix of CA-March15-Doc.5.1, which you can download from the REACH-CLP Biocide Help Desk.

The chlorine/sodium chloride system is a good example of a combination of active ingredient and precursor. Active chlorine is the active ingredient produced through electrolysis with sodium chloride, the precursor. Applications have already been submitted for specific products and uses of this combination of active substance and precursor. But no applications yet cover other uses and types of products. Accordingly, the active substance of “active chlorine, generated from sodium chloride through electrolysis” can be a postdated notification until April 27, 2016.

Feel free to take advantage of our expertise. We will submit your registration for you or advise and work with you through the entire process. Please contact us at biocides@kft.de. You might also want to consider our seminar on the new European biocide law (German only) on April 20, 2016.