Stocks of relevant products must be fully removed from supply chains on the Northern Irish market due to the latest active substance list update – will your inventory be impacted?

Last month, the European Commission announced the non-approval of 14 active substance/product type combinations. These combinations must be phased off the European market. Importantly, this also applies to the Northern Irish market.

The official announcement can be found here.

Regulation (EU) No 528/2012 of the European Parliament and of the Council (BPR) requires all active substances in a biocidal product must be approved for that specific product type, for it to be allowed to be made available on the market. The list for all approved active substance combinations, also referred to as Article 95, can be found here.

Following the Commission Implementing Decision (EU) 2021/1283 of 2 August 2021 on the non-approval of certain active substances in biocidal products pursuant to Regulation (EU) No 528/2012 of the European Parliament and of the Council, the following active substance/product type combinations are not approved

• Bronopol / product type 9 (CAS 52-51-7 EC 200-143-0)
• Thiram / product type 9 (CAS 137-26-8 EC 205-286-2)
• Metam-sodium / product type 9 and 11 (CAS 137-42-8 EC 205-293-0)
• Silver, as a nanomaterial / product types 2, 4 and 9 (CAS 7440-22-4 EC 231-131-3)
• 2,2-dibromo-2-cyanoacetamide (DBNPA) / product type 13 (CAS 10222-01-2 EC 233-539-7)
• Eucalyptus citriodora oil and citronellal, hydrated, cyclized / product type 19 (CAS n/a EC n/a)
• 2-Hydroxy-α,α,4-trimethylcyclohexanemethanol / product type 19 (CAS 42822-86-6 EC 255-953-7)
• Peroxyoctanoic acid / product types 2, 3 and 4 (CAS 33734-57-5 EC n/a)
• Chlorine dioxide generated from sodium chlorite and sodium persulfate / product types 2, 3, 4, 5 and 11 (CAS n/a EC n/a)
• Malt, ext. (Extractives and their physically modified derivatives such as tinctures, concretes, absolutes, essential oils, oleoresins, terpenes, terpene-free fractions, distillates, residues, etc., obtained from Hordeum, Gramineae) / product type 19 (CAS 8002-48-0 EC 232-310-9)
• Amines, C10-16-alkyldimethyl, N-oxides / product type 4 (CAS 70592-80-2 EC 274-687-2)
• Capsicum annuum, ext. (Extractives and their physically modified derivatives such as tinctures, concretes, absolutes, essential oils, oleoresins, terpenes, terpene-free fractions, distillates, residues, etc., obtained from Capsicum annuum, Solanaceae) / product type 19 (CAS 84625-29-6 EC 283-403-6)
• Capsicum oleoresin (Extractives and their physically modified derivatives. It is a product which may contain resin acids and their esters, terpenes, and oxidation or polymerisation products of these terpenes. (Capsicum frutescens, Solanaceae) / product type 19 (CAS 8023-77-6 EC n/a)
• Reaction mass of (6E)-N-(4-hydroxy-3-methoxy-2-methylphenyl)-8-methylnon-6-enamide and N-(4-hydroxy-3-methoxy-2-methylphenyl)-8-methylnonanamide / product type 19 (CAS n/a EC n/a)

Any biocidal product containing these combinations on the market currently under transitional measures must be phased off the market. Specifically, by the following dates:

• Supply of these products by the 23^rd of August 2022
• Use of these products by the 23^rd of February 2023

Moreover, stocks of the relevant products must be fully removed from supply chains by the 23^rd of August 2022.

Finally, the cut-off deadline for placing the affected products on the market is the 19^th of February 2022.

Northern Irish entities must be compliant with EU Biocidal Products Regulation (BPR) if you wish to market your biocidal products in the Northern Irish market. Concurrently, if you wish to supply biocidal products to Great Britain, you must also implement GB legislation compliance. Navigating the Northern Irish biocidal market requires in-depth knowledge of both EU and GB legislation which Deenamic Ltd can provide. To see more about the work we do, check out the Services section of our website.

These deadlines and non-approvals must be observed to ensure your company is regulatory compliant in the Northern Irish market. If you think your products are affected, Deenamic Ltd’s extensive expertise in biocidal regulation can advise you on your next steps. You can find more on our website or contact us for a preliminary consultation at info@deenamicltd.com.