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EU Biocides Authorities Prioritise Risk Guidance and Market Restrictions at 109th CA Meeting

BPR
3
October 2025
•
450
Dr Steven Brennan
At the 109th CA meeting, EU authorities prioritised new guidance, addressed microplastics restrictions, and warned of delays in the biocides review programme.
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Summarise this article

EU authorities gathered at the 109th CA meeting to advance regulatory guidance, enforce microplastics restrictions, and address ongoing delays in the review of active substances. With key deadlines approaching, companies in the biocides sector must prepare for tighter compliance and updated risk assessment frameworks from 2026 onward.

What was agreed at the 109th CA meeting on substances of concern?

Authorities supported the development of scientific criteria for identifying and evaluating non-active substances that may pose health or environmental risks. Interim approaches will be used until more comprehensive guidance is in place.

How will the microplastics ban affect biocidal products after 2031?

Products containing synthetic polymer microparticles will no longer be permitted on the EU market. There will be no transitional provisions after the deadline, so companies must act now to reformulate or seek alternatives.

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At the 109th meeting of Member States’ Competent Authorities for Biocidal Products, held on 25–26 September 2025, authorities across the EU gathered to set strategic priorities for the implementation of the Biocidal Products Regulation (BPR). The agenda focused on improving regulatory coherence, managing delays in the review programme, and preparing the industry for upcoming restrictions that will reshape the biocides landscape.

The discussions reflected mounting pressure to streamline authorisations, ensure consistent risk assessments, and enforce environmental safety obligations—particularly in light of evolving scientific, legal and societal expectations.

New Guidance Projects for 2026–2027

National authorities endorsed a set of new guidance priorities aimed at closing regulatory gaps and ensuring better alignment across Member States. These include:

  • Developing a scientific framework for identifying substances of concern, with a focus on co-formulants and synergists that pose toxicological or environmental risks.
  • Extending dietary risk assessment methodologies to cover processed foods and livestock exposure scenarios, improving the basis for residue evaluations.
  • Updating procedural guidance to reflect changes to the BPR Annexes and better support applications for active substance approval and product authorisation.

Several Member States expressed support for jointly advancing these efforts, particularly where harmonisation would reduce duplication and uncertainty for applicants.

Market Ban on Microplastics in Biocidal Products by 2031

One of the most urgent topics was the approaching deadline under the REACH regulation that will ban synthetic polymer microparticles in biocidal products from 17 October 2031. Authorities confirmed that:

  • Biocidal products containing microplastics will need to be withdrawn from the market by the deadline—no derogations or grace periods will apply.
  • Future applications for product authorisation or substance renewal must avoid nominating microplastic-containing formulations as representative products.
  • Applicants should act now to reformulate or substitute affected products to ensure compliance well before the market cut-off.

This restriction is expected to particularly affect encapsulated technologies, often used for controlled-release biocidal applications.

Review Programme Progress Still Lagging

Despite previous action plans, progress in evaluating existing active substances remains slow. As of September 2025:

  • Just 51% of substances in the review programme have been finalised.
  • Substantial gaps remain in the 4th, 5th, and 6th priority lists, with dozens of reports still outstanding.

Delays continue to place pressure on national authorities and risk overwhelming product authorisation workflows once multiple substances are approved simultaneously.

Additional Policy Signals

  • Authorities reached agreement on a new interim approach to the risk assessment of substances of concern, providing clarity ahead of more formal guidance.
  • Belgium presented a proposal to develop voluntary icons for product labels, aimed at improving the safe and effective use of disinfectants by professionals and the public.
  • Member States exchanged views on the renewal process for active substances, with several products now at risk of market removal due to missed application deadlines.
  • Updates were provided on the planned revision of the biocides fee regulation, which will increase costs for applicants while maintaining SME discounts.
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