The Biocidal Products Regulation - transitional measures

Active substances used in disinfectants are covered by the re-assessment programmme under the Biocidal Products Regulation. While the re-assessment takes place, disinfectants used in the food industry and teat disinfectants are subject to the national rules in each member state. The transitional measures apply until all the active substances in question are approved under the scope of the Biocidal Products Regulation. In Denmark disinfectants used in the food industry and teat disinfectants are regulated by Danish Order No. 8 of 3. January 2023 on authorisation of disinfectants etc. in food establishments etc. This is called the national authorisation scheme. 

Once all active substances in a specific product have been approved under the Biocidal Products Regulation the product itself needs to be authorised in accordance with the Biocidal Products Regulation. The status for the re-assessment of active substances including the date of approval in EU can be seen at the website of the European Chemicals Agency (ECHA). 

This implies that companies whishing to place disinfectants used in the food industry or teat disinfectants on the market shall apply for authorisation of the product before the deadline stated for the active substance in question. If a product contains several active substances it is the deadline for the latest approved active substance that is relevant.

Go to the website of the European Chemicals Agency

The status for approval of active substances can be seen at the website of the European Chemicals Agency (ECHA):

Go to the website of the European Chemcials Agency

Products authorised by the Danish Veterinary and Food Administration may continue to be placed on the market while product authorisation under the Biocidal Products Regulation is ongoing. Note that the application for authorisation under the Biocidal Products Regulation shall be submitted before the applicable deadline for the active substance.

For products not yet authorised by the Danish Veterinary and Food Administration an application for authorisation under the national rules may be submitted to the Danish Veterinary and Food Administration until 6 months before the deadline for application for product authorisation under the Biocidal Products Regulation. 

Application for authorisation under the national authorisation scheme shall be recieved at the latest 6 months before ECHA's date of approval for the active substance. If the product contains more than one active substance, it is the latest approval date that determines the deadline for application for product authorisation under the Biocidal Products Regulation. This applies even though the latest approval date for an active substance concerns product types other than PT3 and PT4.

If no application for product authorisation is submitted before the date of application for the latest assessed active substance, the product may only stay on the market in Denmark for 180 days after that date. Placing the product on the market after this period of time is not allowed and the national authorisation granted by the Danish Veterinary and Food Administration will no longer be valid as the product falls under the scope of the Biocidal Products Regulation. The product can be used until 365 days after the deadline for applying for product authorisation.

Products that are authorised under the Biocidal Products Regulation shall be labelled with an authorisation number. Authorised products can be found on the website of the European Chemicals Agency (ECHA) or in the Danish Environmental Protection Agency Database for biocides and pesticides. 

Find authorised products at ECHA's webpage

Find authorised products in the Danish Environmental Agency database