Over a period of many years discussions regarding if a product was in scope or out of scope on the old BPD (98/8/EC) were captured in the Manual of Decisions (MoD). With the implementation of the BPR (Regulation (EU) No 528/2012) many of these decisions no longer apply and the MoD has recently been repealed.
It is important that companies who, on the basis of the MoD, considered that their product was excluded from the scope of the former biocides legislation, or was covered by a different product-type, check with their national helpdesk whether their product could now fall within the scope of the BPR.
If a product now falls under the new Biocidal Products Regulation, companies can submit a declaration of interest to notify to ECHA until 03 October 2016. The Commission will then assess the received declarations of interest and provide ECHA with a list of notifiable active substance/product-type combinations. Once the list is published by ECHA, companies will have six months to notify their intention to submit an application to get their active substance/product-type combination in the Review Programme. If an active substance/product-type combination is notified successfully, the full application for approval must be submitted within two years.
Failure to do this will mean that products may have to be withdrawn from the market.
For further information on how this may impact on your business or any other enquiries on the BPR, please contact JSC on +44 (0)1423 520245, email@example.com
ERM Regulatory Services Limited
The Exchange, Station Parade
Harrogate, North Yorkshire
The Exchange is a ten storey building next to Harrogate train station (we are on the 5th floor).
Parking is available at Station Parade car park (HG1 1TT) or the Victoria Multi Storey (HG1 5LQ) car park on East Parade.