Highlights of the Biocides Congress: news not to be missed
The conference of the French Environment Ministry
Among various presentations, we had the opportunity to listen to the French Environment Ministry. Some information should be retained from this first presentation.
The French PNSE4, or National Health and Environment Plan 4 was a major part of this. The PNSE4 was published in May 2021. It is composed of 4 axes: inform/train, reduce exposure, territorialize actions, improve knowledge. It impacts many products and types of products and several actions will concern biocidal products. Among them, the following are under study: the implementation of a score/colour code for household products, the revision of the biocidal certificate, the promotion of "low impact" biocidal products or communication actions with animal owners, etc.
The 2020 results of the French Directorate for Competition and Fraud Control (DGCCRF)
The DGCCRF (Direction Générale de la Concurrence, de la Consommation et de la Répression des Fraudes) has also presented a 2020 assessment of its controls on chemicals, biocides and detergents. Of the 320 products checked in 2020, only 26% were compliant. A total of 41% of products were non-compliant, as well as 29% of non-compliant and dangerous products. Among these non-compliant products, there were many products with an expiry date that had passed, products with danger labeling that did not comply with labeling rules for biocides, products with missing or insufficient proof of effectiveness, etc.
If you have any doubts about the compliance of your biocidal products , do not hesitate to contact our teams who will be able to guide you!
Finally, the issue of biocidal claims was also addressed by the DGCCRF. Certain positions taken by the French authority were clarified with regard to prohibited claims on biocidal products. Among these positions (subject to the sovereign appreciation of the courts), the prohibition, in theory, of the mention "plant-based" (because it can be considered as similar to the claim "natural"), of the mention "ecological" (in application of the CLP regulation), or even "sensitive skin"/"dermatologically tested".
The presentation of Afise (French Association of Detergent Industries)
Another presentation to note is that of the Afise (the French Association of Detergent Industries), which presented the Chemical Strategy for Sustainability (CSS) and its impact on biocidal products. Indeed, the CSS foresees a revision of the REACH, CLP, and even cosmetic regulations, but not of the biocides regulation.
However, biocidal products will still be affected by these regulation changes. Indeed, one of the principles of this strategy is “One substance, one assessment”. The idea is to slow down the multiplication of substance assessments under several different regulations. This could therefore have an impact on the evaluation of biocidal active substances. In addition, the "safe by design" characteristic of chemical products wanted by this new strategy may also impact biocidal products. Finally, the revision of the CLP Regulation will inevitably have an impact on biocidal products because it will mean some substances will suffer a change in classification.
EcoMundo's intervention: overview of transitional regimes in Europe
The intervention of our expert Gwenaëlle Julien dealt with the transitional regimes existing in the European Union. As long as an active substance/product type (AS/PT) combination is in the process of being approved in the European Union, companies marketing these products do not have to submit a marketing authorisation application (MA). Instead, these companies must go through national procedures known as transitional arrangements. These measures, their complexity and cost, differ depending on the country of commercialisation.
For more explanations on the transitional period, please visit our dedicated page.
After the approval of an active substance, companies must start making their MA dossier. In order to reduce the costs of this MA, EcoMundo offers companies the possibility to form a consortium. Recently, the ADBAC/BKC & DDAC consortium has been launched. To learn more, please register for our webinar, which will be held on November 10th.
Wish to know more about the biocidal products regulation?
For more information, do not hesitate to contact Cornelia Garaudel or one of our experts!
