2023-10-30 23:00:00
Before embarking on the Biocid declaration of biocidal products (PB), if you have not carried out it, it is important to take stock of your product inventory to determine which product should be considered as a biocidal product. For this two major actions are necessary.
Determine whether the products are indeed biocidal products
Biocidal products are products intended to destroy, repel or render harmless harmful organisms, to prevent their action or to combat them, through chemical or biological action. You must therefore identify your products meeting this definition.
Please note: you should not only rely on the product claim. If your product is not claimed as a biocidal product on its label, but the desired action makes it a biocidal product, it is.
Determine if biocidal products are still authorized
And this, according to the status of the active substance(s) (SA) according to the steps indicated in the sheet Biocidal products: regulatory obligations.
At the end of this step, you have all the biocidal products in your inventory and these biocidal products can have different statuses:
be prohibited from being placed on the market, because the SA/TP couple is no longer authorized in Europe (status 1); be in a permanent phase, because the SA/TP couple has been authorized in Europe and the registration date has been exceeded (status 2); be in a transitional phase, because the SA/TP couple has still not been authorized in Europe (status 3).
You must declare under the Biocid inventory those whose statuses correspond to statuses 2 and 3 and which you are going to place on the market, that is to say those which you supply to a third party or which you import into France.
For those corresponding to status 1, declaration will not be possible. Indeed, the commission’s decision specifies the date on which biocidal products containing SA, for the given TP (product type), must no longer be placed on the market (generally six months after the date of the decision). A national decision is taken to indicate the date on which PB is prohibited from use. In France, this is a decree and the date of ban on use is generally the date of ban on marketing plus six months (see section Errors to avoid).
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