Biocidal product dossier

Prepare the dossier to authorise your biocidal product in the EU, section by section against Annex III.

ProjectsBiocidal product dossier

  • Marit Kessler
  • Tomasz Wierzba
  • Leah Fairbairn
Corvane’s hydrogen peroxide disinfectant, for product types 2 and 4, against BPR Annex III.
SectionEvidenceStatus
Route and authority50%In progress
Active substance100%Complete
Identity and composition100%Complete
Properties and methods80%In progress
Efficacy60%Gap
Exposure and toxicology100%Review
Environment100%Review
SPC and label0%Not started

Efficacy PT 2

Status: Gap

Hospital wipe-down lacks a test

Passed
Suspension and surface tests, without wiping
Missing
A surface test with mechanical action
Contact
5 minutes at most on frequently touched surfaces

Your expert signs off both product types

You get the readiness view, the route agreed before any drafting starts, and each section drafted in IUCLID’s format for R4BP 3.

Approval

Illustrative project

Marit Kessler

Status: Approved

Head of Regulatory Affairs, after checking every section for both product types against Annex III

  • Product type 2, hospital surfaces

  • Product type 4, food and feed areas

Foresight does the research

Your team brings what only it knows, and your expert makes the call at each checkpoint.

Tasks

Illustrative project

3 of 5 tasks done.

  1. Share your product

    Your team

    Status: Done
  2. Compare the routes

    Foresight

    Status: Done
  3. Agree the route

    Checkpoint

    Marit Kessler

    Status: Approved
  4. Draft the dossier

    Foresight

    Status: In progress
  5. Approve the dossier

    Checkpoint

    Marit Kessler

    Status: Not started

Kept current once it’s approved

Monitoring watches the measures behind your dossier. When one moves, Foresight rechecks the sections it affects, and your expert reviews the change.

Monitoring

Illustrative project

Watching 3 measures behind the dossier

  • Hydrogen peroxide approval for PT 2 and 4

    The Commission postponed the expiry from 31 January 2027 to 31 July 2029, from 15 October 2026. Rechecked, still approved for both product types.

    Status: To review
  • BPR Article 95 list for hydrogen peroxide

  • CLP label formatting, Regulation (EU) 2024/2865

What we need from you

Four things, shared at setup before the project starts.

  1. Your product

    Its composition, how it’s applied and the claims you want on the label.

  2. Your data

    The study reports you hold and your active substance supplier’s letter of access.

  3. Your markets

    The countries you want to sell in, which decide between national and Union authorisation.

  4. Your approver

    The person who agrees the route and approves the dossier.

What teams ask about this project

Should we apply for national or Union authorisation?

It depends on where you sell. Union authorisation is one authorisation valid across the EU for products with similar conditions of use everywhere, and product types 2 and 4 are both eligible. You apply to ECHA with written agreement from the authority that will evaluate it. National authorisation starts in one country, and mutual recognition, in sequence or in parallel, extends it to others. The simplified procedure isn’t open to hydrogen peroxide products, because the substance isn’t listed in Annex I.

How do you build the dossier?

Foresight maps your data to each Annex III requirement for a chemical product and marks what’s complete, what can be waived with a justification and what still needs testing. Then it drafts each section in IUCLID’s format, with the summary of product characteristics. Annex III also requires a documented pre-submission consultation with the evaluating authority, so Foresight prepares the papers for it.

Where does the evidence come from?

From the Biocidal Products Regulation and its Annex III, the active substance’s approval, ECHA’s guidance, such as its efficacy guidance for disinfectants, and your own study reports. Every requirement and every gap links to its source, so your team can check the wording directly.

Who checks the dossier before it’s submitted?

The person you name. They agree the route and the gap list before drafting starts, and check every section against its data at the end. Nothing goes into R4BP 3 until they approve it. These checks reduce the risk of error without removing it.

What happens when a rule changes?

Foresight rechecks the sections it affects, such as those that rest on the active substance’s approval. In September 2026, for example, the Commission postponed the expiry of hydrogen peroxide’s approval for product types 2 and 4 to 31 July 2029. The dossier your expert approved stays as it is until they accept the change.

What does it cost?

The price follows the dossier’s size: your product’s claims, the gaps in the data you hold and the route. You see it with the scope, before any drafting starts. Fees to ECHA and the evaluating authority are separate.

Bring your biocidal product to a demo

Tell us its claims, the data you hold and where you want to sell it. You’ll see the scope and the price before any drafting starts.