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EU public consultation potential candidates for substitution

The European Chemicals Agency (ECHA) is consulting on the availability of substitutes and alternatives to:

  • formaldehyde released from the reaction products of paraformaldehyde and 2-hydroxypropylamine (ratio 1:1)

  • formaldehyde released from the reaction products of paraformaldehyde and 2-hydroxypropylamine (ratio 3:2)

The EU BPR applies in NI. Under EU BPR active substances will be considered candidates for substitution if they meet the substitution criteria set out in Article 10 (1).

This means that the supply and use of biocidal products containing candidates for substitution must be prohibited or restricted under EU BPR, unless it can be shown that:

  • for the uses specified for that product, there are no other authorised biocidal products or existing non-chemical control or prevention methods that:
    • present a significantly lower overall risk for human health, animal health and the environment;
    • are sufficiently effective; and
    • present no other significant economic or practical disadvantages

  • the chemical diversity of the available active substances is not adequate to minimise the occurrence of resistance in the target harmful organism

The following active substances have been identified as potential candidates for substitution under EU BPR. ECHA has launched public consultations to collect information on the availability of substitutes and alternatives, running until the stated dates:

  • formaldehyde released from the reaction products of paraformaldehyde and 2-hydroxypropylamine (ratio 1:1) (CAS n/a EC n/a) in product types 2, 6, 11 and 13
    26 May 2023

  • formaldehyde released from the reaction products of paraformaldehyde and 2-hydroxypropylamine (ratio 3:2) (CAS n/a EC n/a) in product types 2, 6, 11, 12 and 13
    26 May 2023

Comments should be submitted to ECHA (not HSE) using the dedicated webforms at the link above.

Please note this consultation and its outcome are not applicable under the GB BPR.


Reminder - upcoming EU active substance open invitation deadline

Submit a notification by the deadline to keep active substances in the EU Review Programme

ECHA has published open invitations to provide an opportunity for a person, company or task force/consortium to notify an intention to take up or take over the role of participant in the EU Review Programme for the following active substance/product type combination.

This affects NI. Anyone wishing to support the active substance/product type combination listed below in the EU will need to submit a notification to ECHA by the following deadline:

  • Poly(oxy-1,2-ethanediyl), .alpha.-[2-(didecylmethylammonio)ethyl]- .omega.- hydroxy-, propanoate (salt) (Bardap 26) other than Reaction mass of N,N-didecyl-N-(2-hydroxyethyl)-N-methylammonium propionate and N,N-didecyl-N-(2-(2-hydroxyethoxy)ethyl)-N-methylammonium propionate and N,N-didecyl-N-(2-(2-(2-hydroxyethoxy)ethoxy)ethyl)-N-methylammonium propionate (CAS 94667-33-1 EC n/a) in product types 2, 4 and 10
    4 October 2023

If a notification to take over the role of participant is not received, these active substance/product type combinations will be subject to an EU non-approval decision.

Biocidal products containing active substances with EU non-approval decisions for the relevant product types will have to be removed from the NI market. HSE will provide separate updates on these where relevant.

If you are aware of any disproportionate negative effects that are likely to arise from the non-approval of any of the active substance/product type combinations listed above, please contact us.

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