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EXPERTISE · BPR

BPR — Biocidal Products Regulation

Regulation governing the placing on the market and use of biocidal products.

Bringing biocidal products to market with confidence.

The Biocidal Products Regulation governs the placing on the market and use of biocidal products such as disinfectants, preservatives and pest control products, requiring active substance approval and product authorisation before a biocidal product can be supplied.
We help organisations understand where BPR applies to their products, and what active substance and product authorisation routes are relevant to their formulation and intended use.
✓BPR applicability screening for products and formulations
✓Active substance approval status reviews
✓Product authorisation route planning
✓Label and claims alignment with authorised uses
PRODUCT TYPES

Twenty-two product types, four groups.

BPR groups its 22 biocidal product types into four broad areas, each requiring separate active substance approval and product authorisation for the relevant product type. Establishing which product types apply to a formulation is one of the first steps in scoping a BPR position.

Disinfectants (PT 1–5)
Human hygiene, private-area and public-health disinfectants, veterinary hygiene products, and disinfectants used on materials and surfaces that come into contact with food and feed.
Preservatives (PT 6–13)
Products that protect other materials from microbial or algal spoilage during storage or use, including preservatives for products in containers, films, construction materials, wood, fibre, leather, and cooling or processing liquids.
Pest Control (PT 14–20)
Rodenticides, avicides and products controlling other vertebrates, insecticides and acaricides, molluscicides, piscicides and products controlling other invertebrates.
Other Biocidal Products (PT 21–22)
Antifouling products, and embalming or taxidermist fluids — covering uses that do not sit within the other three groups.
THE TWO-STAGE PROCESS

Approval, then authorisation — two separate steps.

Before a biocidal product can be placed on the market, every active substance it contains must first be approved for the relevant product type, either at EU level or under the GB BPR run by HSE. Product authorisation for the finished product then follows, through whichever route fits the product and the markets it will be sold into — national authorisation with mutual recognition, Union authorisation, or simplified authorisation for lower-risk products.

For products containing an active substance still going through the EU or GB review programme, transitional arrangements under Article 89 can allow continued supply under national rules while that review is completed — a position that needs to be tracked and evidenced, not assumed.

✓Active substance approval status checks for GB and EU markets
✓Product authorisation route selection: national, mutual recognition, Union or simplified authorisation
✓Article 89 transitional position tracking for substances still under review
✓Renewal and variation management as approvals near expiry
ROLES & RESPONSIBILITIES

Your BPR duties depend on your role in the supply chain.

The same biocidal product can carry different duties depending on whether you supply the active substance, hold the product authorisation, distribute the finished product, or supply an article treated with it. We help establish your role for each product and what it means in practice.

Active substance supplier
You manufacture or import an active substance for use in biocidal products. Under Article 95, you (or your representative) must appear on ECHA’s Article 95 list for the relevant product type before that active substance can be used in products supplied in the EU, and equivalent requirements apply for GB.
Authorisation holder
You hold the product authorisation for a biocidal product and carry the primary duty to ensure the product matches the terms of that authorisation, including its composition, permitted uses and label.
Distributor
You supply an already-authorised biocidal product without altering it. You need to verify that the product is correctly authorised and labelled for the market you are supplying before making it available.
Treated article supplier
You supply an article that has been treated with, or incorporates, a biocidal product. Depending on the claims made and the substances involved, Article 58 can require specific labelling to accompany the article.
HOW WE HELP

Bringing BPR into a workable compliance position.

BPR positions rarely stay static. Active substance approvals move through review programmes on their own timetable, product ranges change, and GB and EU requirements do not always align in the same way at the same time.
We help organisations screen products against BPR scope, work out which product types and authorisation routes apply, keep track of Article 95 and Article 89 positions, and build the evidence trail an authorisation holder or distributor needs to defend their position.
✓BPR applicability and product-type screening
✓Active substance and product authorisation status tracking
✓Article 95 and Article 58 (treated articles) compliance support
✓Alignment across GB and EU BPR requirements
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