Close deadlines for resubmission of applications
With the end of the transition period in January 2021, the UK has had to organise all regulation of chemicals and substances and put in place a large number of regulations accordingly. In particular, biocidal products are now regulated in the UK by the British equivalent of the Biocidal Products Regulation (BPR): the GB BPR.
New compliance steps have been introduced for companies marketing biocidal products in the UK. Specifically, some companies will have to re-submit their biocidal product marketing authorisation (MA) applications or active substance approval dossiers (including renewals).
There are two deadlines to keep in mind for the compliance of these products:
By 31st March 2021, re-submission will be required for applications where, prior to 1st January 2021, the UK was:
- the evaluating reference Member State for national or Union MA dossiers for biocidal products (including renewals);
- the evaluating competent authority for an active substance approval or renewal dossier.
By 29th June 2021, re-submission will be required for applications where, prior to 1st January 2021, the UK:
- was a Member State concerned for a Union or national MA (including renewals and mutual recognition);
- was a concerned or reference Member State for a MA application for an identical product (National or Union) or for any request for a change in a dossier;
- was not the evaluating competent authority for an application for approval or renewal of an active substance
Applicants will need to provide the full original application, and any data generated or collected since the original submission. This potentially includes biocidal letters of access, and therefore applicants should ensure that data owners submit the data to the Health and Safety Executive. If there are any difficulties, the dossier should be submitted noting any problems or data gaps.
GB BPR: equivalent to the European Biocidal Products Regulation
In 2021, the UK began implementing its new regulations on chemicals and substances to address the end of the transition period following the UK's exit from the European Union.
Various regulations were therefore transposed into British law in the run-up to Brexit in order to facilitate the transition. These include the Cosmetics Regulation, the Biocidal Products Regulation, the REACH Regulation and the CLP Regulation.
This means that companies wishing to market their products in the European Union as well as in the United Kingdom will have to fulfil two different obligations. It is therefore important for companies using external consultants to ensure that they are familiar with these different markets.
Feel free to consult our different blogposts for more information on the different regulations applicable in the UK: UK REACH authorisations, UK REACH registration, le UK cosmetics regulation, etc.
Wish to know more about biocidal products?
For more information, do not hesitate to contact Cornelia Garaudel or one of our experts !
