Biocide compliance under scrutiny: what you need to know for 2025

A recent European Union report revealed significant issues with the labelling compliance of biocidal products, initiating new enforcement checks and potential penalties for any products on the EU market found to be non-compliant.

A biocidal chemical is a substance or product that is designed to control, destroy, or deter harmful organisms such as bacteria, viruses, fungi, insects, or rodents. These chemicals are used in a wide range of applications, including disinfectants, preservatives, pest control, and antifouling agents. Biocidal products are regulated under the EU Biocidal Products Regulation (BPR, Regulation (EU) 528/2012) to ensure they are safe for human health and the environment while remaining effective.  

Examples of biocidal products include:

• disinfectants, such as hand sanitizers, surface cleaners, and hospital-grade disinfectants;
• preservatives used in paints, textiles, wood, and cosmetics to prevent microbial growth;
• pest control, including rodenticides, insect repellents, and anti-mosquito sprays; and,
• antifouling agents – used on ships to prevent the buildup of algae and barnacles.  

In 2019, the European Chemicals Agency (ECHA) coordinated an enforcement project (BEF-1) across 22 EU Member States, inspecting nearly 1,200 companies and over 1,800 treated articles such as clothing, paints, bedding, and chemical mixtures. The findings were concerning as 36% of biocidal products lacked proper labelling. Common issues included missing information about active substances, with 23% of mixtures and 42% of articles non-compliant. Labelling also varied by language, with products in some Member States not meeting language requirements.

This next project, called BEF-3 is run by the ECHA Enforcement Forum’s BPR Subgroup and is titled “BPR Enforcement project on controlling the Summary of Product Characteristics for biocides and elements of the Safety Data Sheet”. The aim of the project is to harmonise the enforcement of biocidal products available on the EU market in a twofold action:

• Labelling Verification: Inspectors will assess whether the information on biocidal product labels aligns with the authorized details in the Summary of Product Characteristics (SPC).
• Safety Data Sheets (SDS) Review: The accuracy and completeness of information in SDS will be evaluated to ensure they meet regulatory requirements.

Once inspections are complete training will be prepared and delivered to national inspectors for the enforcement of the BPR which will mean that enforcement is expected to increase in future years.

Take action to minimise impact

Finding reliable, informed and experienced support is essential to maintain regulatory compliance and effectively manage the associated burden.

Biocide label and SDS reviews

Our team can check your labels and SDS against the requirements of BPR and the SPC, as well as the requirements of CLP and REACH, providing reassurance that your documentation meets the required standards. We will provide you with a report outlining whether these documents are compliant and highlighting any areas for improvements.

We also have a team of expert SDS authors who can provide bespoke support, from authoring to consultancy.

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Biocide report

Ricardo’s biocide report provides companies with an overview of:

• general requirements for Biocidal Product Authorisation
• active Substance Approval Process – Stage 1
• biocidal Product Authorisation – Stage 2
• differences between EU BPR and GB BPR
• member-state analysis for National Registration 

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Chemical Compliance Monitor

Our Chemical Compliance Monitor tool can  support you with managing the regulatory burdens of compliance by carrying out regular and comprehensive inventory checks against regulatory lists of interest, including EU and UK lists such as the active substance list, Article 95 list, as well as other lists of concern including current and developing entries for the Candidate List of Substances of Very High Concern, current and developing harmonised classifications, endocrine disruptors, PBT assessment list and many others. 

The tool can also provide coverage of relevant biocidal substance lists in North America, Asia and other regions. 

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 For expert insight to the potential impact compliance reviews could have on your organisation, contact our team today.