Have you already confirmed whether the biocidal active substance you use is already approved or under evaluation for the relevant product-type? Are your products labelled correctly?
According to the Biocidal Products Regulation (BPR), articles can be treated with, or intentionally incorporating during manufacturing, one or more biocidal products as long as the active substance/s are either approved or under evaluation in the EU. In addition, manufacturers, importers or others who place treated articles on the market may also have to comply with the specific labelling requirements when a claim regarding the biocidal properties of the treated article is made, or when the approval conditions of the active substance require it.
For active substances that are not yet in the approval process, there is a transition period until 1 September 2016 to submit a complete application dossier on that active substance for the relevant product-type. However, this transitional period does not affect the labelling requirements that already applied from 1 September 2013.
If your company is not able to comply with this deadline, after 1 March 2017 you will not be allowed to place on the EU market articles treated with a biocidal product containing an active substance which is either not already approved or under evaluation in the EU.
Please also remember that you should regularly monitor the EU assessment progress of the relevant active substances in order to be aware of upcoming decisions concerning them. In the case of a non-approval decision, a strict deadline of 180 days from the decision of non-approval applies after which the treated article can no longer be placed on the market. In addition, in the case of an approval decision, the approval conditions may prescribe certain use restrictions or labelling obligations for treated articles that you should take into account.
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