Active substances produced in situ: the case of active chlorine generated by electrolysis
An active substance is said to be produced in situ when it is produced from one or more precursors at the place of use. Active chlorine generated by electrolysis of sodium chloride is one such substance: it will be approved in July 2022, as will active chlorine released from hypochlorous acid, for product types 2, 3, 4 and 5.
Manufacturers of electrolytically generated active chlorine often think they are exempt from obligation. This is not the case! Their approval is more complex as it requires both the assessment of the active substance itself, but also of the precursor(s) from which it has been generated, for each product type (PT).
The obligations for electrolysers are therefore the same as for other products: to market biocidal products in full compliance, a marketing authorisation (MA) dossier must be completed before July 2022. It should also be noted that, in order to continue marketing between July 2022 and the validation of the MA dossier, companies must already comply with the transitional measures.
Reducing MA costs: joining a consortium
Preparing a marketing authorisation (MA) dossier for biocidal products is not easy: it is a long and costly process that requires specialised expertise! Companies manufacturing biocidal products based on active chlorine, such as products intended for swimming pool water treatment, livestock farming (milking sleeves), or disinfection in a more general way, are not always familiar with the regulatory compliance that results from the approval of an active substance.
To make life easier for companies in these different sectors, EcoMundo has created the Active Chlorine Product Authorisation Consortium (ACPAC). A consortium dedicated to active chlorine that allows the pooling of dossiers and therefore the costs and resources required.
ACPAC's aim is to share the costs of testing with companies, which can sometimes amount to tens of thousands of euros. As a neutral intermediary within the consortium, EcoMundo guarantees the security and confidentiality of everyone's data.
Registration is still open! You still have until 30th June to join ACPAC. Contact our experts for more information on how our active chlorine consortium works.
Wish to know more about the biocidal products regulation?
For more information, do not hesitate to contact Cornelia Garaudel or one of our experts!
