Biocide: an everyday product
Biocidal products are a group of products intended to destroy, repel or render harmless harmful organisms, to prevent their action or to combat them, by chemical or biological action.
They are classified into four main groups, comprising 22 different types of products:
- Disinfectants
Product types 1-5 (e.g., hand sanitizers, etc.);
- Protective products
Product types 6 to 13 (e.g., wood protection products against insects, etc.) ;
- Pest control products
Product types 14 to 20 (e.g. rodenticides, insecticides, etc.);
- Other products
Product types 21 and 22 (e.g. anti-fouling paints applied to boats, fluids used for embalming and taxidermy)
EGALIM Law: for the balance of commercial relations in the agricultural and food sector and a healthy, sustainable and accessible food for all
Resulting from the Etats généraux de l'alimentation (EGA), the EGALIM law was voted on October 2, 2018 and enacted on November 1, 2018. Its objectives are:
- The payment of fair prices so that producers can live with dignity from their work
- A sanitary, environmental and nutritional quality of products strengthened
- Healthy, safe and sustainable food for all
In 2018, the Environmental Legislation (EGALIM Law No. 2018-938 of October 30, 2018, Article No. 76) included three measures:
Decree No. 2019-642 of June 26, 2019 on prohibited commercial practices for certain categories of biocidal products: Commercial practices concerning the availability on the market and use of these biocidal products such as discounts, rebates and refunds, differentiation of general and special conditions of sale within the meaning of Article L. 441-6 of the Commercial Code or the provision of free units and all equivalent practices are prohibited.
Decree No. 2019-643 of June 26, 2019 on commercial advertising for certain categories of biocidal products: The categories of biocidal products mentioned in Article L. 522-5-3, for which commercial advertising to the general public is prohibited, are products belonging to types 14, 18, as well as types 2 and 4 products.
To identify the biocidal products that have caused human intoxication and to apply the 3rd measure of the EGALIM law, ANSES relied on the analysis of data from Poison Control Centers.
Figure 1: Number of cases of high severity poisonings or accidental deaths with biocidal products recorded by Poison Control Centers (2015-2019) by TP (Source: SICAP)
The opinion of the ANSES
Biocidal products used by the general public were divided into 6 categories:
- Disinfectants/algaecides (TP1 to 5 and TP10);
- Wood treatment products (TP8);
- Rodenticides (TP14);
- Insecticides (TP18);
- Repellents/attractants (TP19);
- Anti-fouling products (TP21).
Thus, 5 identification criteria consistent with the EGALIM law n° 2018-938 of October 30, 2018 are proposed:
- "products containing active substances (AS) for which resistances are identified ("resistance" criterion).
- products containing ASs that fall into categories for which serious intoxications or deaths have been reported ("intoxication" criterion).
- products containing AS that meet the exclusion or substitution criteria defined in the European Regulation (EU) 528/201251 ("substitution" criterion)
- products whose classification as a skin corrosive (H314), causing serious eye effects (H318), skin sensitizer (H317) or respiratory sensitizer (H334) will most likely lead to prohibition of use by the general public during the evaluation of the marketing authorization application ("classification" criterion)
- products containing co-formulants with hazard properties similar to those that justify substitution for SAs: i.e. carcinogenic, mutagenic or reprotoxic category 1, respiratory sensitizer or substance of very high concern (SVHC) under the REACH regulation ("co-formulant of concern" criterion)
Source "OPINION of the National Agency for Food, Environmental and Occupational Health Safety on the prohibition of self-service sales of certain categories of biocidal products", July 2022
What does ANSES recommend?
Regarding these products, ANSES recommends :
- Use them only when necessary
- Strictly respect their conditions and precautions of use
- Store them out of reach of children and adults with cognitive deficits
- Do not decant them into containers other than the original ones or those provided for this purpose
Finally, in order to reduce poisoning, the prohibition of self-service access to certain biocidal products to individuals may contribute to an awareness of the dangers they represent.
In addition, the Anses recommends that all TP14, TP18 and TP21 products that do not benefit from a simplified MA should no longer be available for sale over the counter so that users can benefit, at the time of purchase, from relevant information on the hazards and proper conditions of use of these products.
Relationship with EcoMundo
EcoMundo accompanies you in the submission of a biocide active substance dossier or the creation of Marketing Authorization dossiers for biocides (MA) with its dedicated Biocides service.
EcoMundo also offers you the possibility to join a Biocides consortium.
You want to know more about the approval of biocidal active substances?
For more information, do not hesitate to contact Jeanne Pontisso or one of our other experts!
