It should be noted that placing on the market and use of biocidal products are governed by the Ordinance on Biocidal Products (OBP), meaning that use of a product that has not been authorised is not permitted.
Under the terms of the the new European regulations on biocidal products (BPR; EU nr. 538/2012) and the Swiss Federal Ordinance on Biocidal Products (OBP, 813.12), active substances generated in situ, and the associated precursors, are considered to be biocidal products and are thus subject to approval.
The present document takes stock of the situation in November 2015 and provides clarification on the duties of companies marketing biocidal products in Switzerland.
Under the terms of the BPR and OBP, an active substance is authorised for specific applications known as product types (OBP, Annex 10). For this reason we talk of precursor/active substance/product type combinations.
It is important to note that any precursor substances that are marketed for non-biocidal purposes (for example sodium chloride used as softening salt) are not subject to this regulation and therefore do not require approval under the terms of the OBP.
Summary of actions taken by ECHA:
The EU has taken the following actions to clarify the situation regarding active substances generated in situ.
- It asked companies to specify the in situ applications on the market (precursor/active substance/product type combinations).
- It published a list of active substances generated in situ and adapted the nomenclature of active substances contained in the review programme. The document can be found on the Internet.
- It published a new deadline for notifying precursor/active substance/product type combinations not yet under evaluation. The document can be found on the Internet.
See all the information and links in the document below: