After having listed the most significant changes implemented through this regulation, lets focus on the main points that make it a challenge for industrials who wish to comply.
Article 95 and the free rider issue
Article 95 of the BPR specifies the provisions of the “transitory” period, in which an active substance is being evaluated for approval. During this time, any manufacturer can place a biocidal product containing this substance on the market, without any type of restriction, this person is called a “free rider”.
However, from 1 September 2015, a list of approved suppliers will be published and free riders won’t have the right to place a biocidal product of the market. The approved suppliers will be those which have submitted an authorisation request for their product as well as those with a Letter of Access.
Treated articles inclusion
One of the changes from the old directive is the obligation to also allow treated articles with, or intentionally incorporating biocides. The extremely broad definition of treated articles implicates many more industries than the directive did, as most manufactured articles are, at some stage of their production, treated with one or more biocidal products.
This has also led to new issues concerning article labelling and classification. It is a challenge not only for industrials but also for competent authorities.
Being compliant is a challenge in itself but the real difficulty for industrials is in maintaining continued supply. Actions must be taken before 1 September 2015 to ensure this continued supply.
Read the article from Speciality Chemicals Magazine (p.12-15)
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