: Do I have to label my product if it contains a biocide?
Under Article 58 of the Biocidal Products Regulation, which comes into force on 1st September 2013 all articles which use biocides (a treated article is pretty much everything that uses a biocide) are required to be labelled. This assumes the article itself is not considered a biocide in its own right and applies to products sold in the EU, whether made in the EU or not.
This labelling requires: (a) a statement that the treated article incorporates biocidal products; (b) where substantiated, the biocidal property attributed to the treated article; (c) the name of all active substances contained in the biocidal products; (d) any relevant instructions for use, including any precautions to be taken because of the biocidal products with which a treated article was treated or which it incorporates. Please note dry treated articles are not mixtures and do not come under the scope of CLP.
Labelling is required on the product or where this is impractical such information is required to be available to the consumer as detailed in article 58 (6).For actives not yet listed on Annex I of the BPR (most of them) then derogation under Article 94 allows for continued use of the actives. Non supported actives are not permitted from September 2016 or 180 days thereafter if they do not achieve Annex I listing. This derogation is not derogation from the labelling requirements and any interpretation for this was not intended in the original text (CA document March 2013).
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