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
| Section | Evidence | Status |
|---|---|---|
| Route and authority | 50% | In progress |
| Active substance | 100% | Complete |
| Identity and composition | 100% | Complete |
| Properties and methods | 80% | In progress |
| Efficacy | 60% | Gap |
| Exposure and toxicology | 100% | Review |
| Environment | 100% | Review |
| SPC and label | 0% | Not started |
Efficacy PT 2
Status: GapHospital 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 projectMarit Kessler
Status: ApprovedHead 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
Status: In progressIllustrative project3 of 5 tasks done.
Share your product
Your team
Status: DoneCompare the routes
Foresight
Status: DoneAgree the route
CheckpointStatus: ApprovedMarit Kessler
Draft the dossier
Foresight
Status: In progressApprove the dossier
CheckpointStatus: Not startedMarit Kessler
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 projectWatching 3 measures behind the dossier
- Status: To review
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.
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.
Your product
Its composition, how it’s applied and the claims you want on the label.
Your data
The study reports you hold and your active substance supplier’s letter of access.
Your markets
The countries you want to sell in, which decide between national and Union authorisation.
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.
More ways to meet an obligation
Each runs the same way, with your expert approving the result.
- PPWR compliance programmePackaging requirements, milestones, and evidence in one plan.
- EPR reportingPackaging and product data prepared for each country’s EPR scheme and deadline.
- REACH registration dossiersEU and UK REACH registrations, from data gap analysis to a dossier ready to submit.
- CLP classification and labellingMixture classifications under CLP, and the label elements that follow.
- Poison centre notificationsCLP Annex VIII notifications, with a UFI for each mixture.
- SCIP notificationsArticles with Candidate List substances above 0.1%, prepared for ECHA’s SCIP database.
- TSCA reportingInventory status, CDR and PFAS reports for substances you make in or import into the US.
- Plant protection product dossierDossier evidence, ownership, and review status in one place.
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.
