Biocides

Biocides need to comply with CLP, and also with the Biocidal Product Regulation from the EU.

As well as having BPR information on the product label, there is the requirement to only use approved biocides in your biocidal products, and also to register your biocidal products.

This means that there are two separate registration duties for biocides: for biocide manufacturers, to register their substance as a biocide; and for biocidal formulators, to register their formulations as biocidal products.

Biocidal formulations are those which make biocidal claims, such as “kills 99 % of germs” or “kills bacteria”, and generally refers to cleaning products, or products sold as preservatives.

The use of small amounts of biocides in formulations as preservatives does not trigger the requirement to register as a biocidal product (although you do have to make sure that you are using a biocide which is approved in the EU, or going through the approval process).

There is also a third possible duty, which is when a biocidal substance is used as a general chemical, without any claims for biocidal activity made for it.  In this circumstance, REACH registration would be required, for the non-biocide tonnage per annum.

For further details on this complex area of regulation, see http://www.hse.gov.uk/biocides/index.htm ; and https://echa.europa.eu/regulations/biocidal-products-regulation .