Transitional measures referred in Art 89 of the BPR apply to authorization of Biocidal Products (BP) that includes one or more active substance, when at least one active substance is not yet included in the Union list of Approved active substances or in the Annex I list. According to this article, EU Member States may continue to apply its current national system for authorization until the date of approval of the last active substance to be approved for the corresponding Product Type (PT).
Once the active substance contained in the BP is proposed for approval, if your company wish to support an authorization/notification made under the transitional measures, the BPR dossier must be submitted no later than the date of approval of the active substance/PT combination (the date of approval of the last active substance/PT in case more than one are present in the formula). This period of time, from the proposal and the deadline, ranges from 1.5-2 years, sufficient time to prepare a BPR dossier.
Therefore, are you regularly checking the status of the active substance/s contained in your biocidal products? Please see below the link where you can check the status of the biocidal active substances that varies from “Initial application for approval in progress (different sub status are possible)” or “Approved”, but also “Cancelled”, “Non longer supported” or “Expired (non-renewed)”.
https://echa.europa.eu/information-on-chemicals/biocidal-active-substances
In case the active substance and its PT combination is not yet approved, as it is still under revision, please check the BP Committe Meetings in the following link to see whether a discussion has been held on your active substance:
As a summary of the upcoming deadlines that may affect your biocidal products authorized/being marketed under the transitional rules, please see below the list and carefully check your active substance and the CAS number where available:
01/07/2024:
- Alkyl (C12-16) dimethylbenzyl ammonium chloride (ADBAC/BKC (C12-16)) (CAS no. 68424-85-1): PT1
- Ozone generated from oxygen: PT2, 4, 5 and 11
01/10/2024:
- Sulfur dioxide generated from sulfur by combustion: PT4
01/11/2024:
- Formic Acid (Cas no. 64-18-6): PT2, 3, 4 and 5
01/02/2025:
- Chrysanthemum cinerariaefolium extract from open and mature flowers of Tanacetum cinerariifolium obtained with supercritical carbondioxide (CAS no. 89997-63-7): PT18
- Chrysanthemum cinerariaefolium, extract from open and mature flowers of Tanacetum cinerariifolium obtained with hydrocarbon solvents (CAS no. 89997-63-7): PT18
- reaction mass of N,N-didecyl-N-(2-hydroxyethyl)-N-methylammonium propionate and N,N-didecyl-N-(2-(2-hydroxyethoxy)ethyl)-N-methylammonium propionate and N,N-didecyl-N-(2-(2-(2-hydroxyethoxy)ethoxy)ethyl)-N-methylammonium propionate: PT2 and 4
01/07/2025:
- Pentapotassium bis(peroxymonosulphate) bis(sulphate): PT2, 3, 4 and 5
- Alkyl (C12-16) dimethylbenzyl ammonium chloride (ADBAC/BKC (C12-16)) (CAS no. 68424-85-1): PT2
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