BPR Article 95: Confusion about active substance approval

The BPR requirements for inclusion of suppliers in the Article 95 list are often confused with those for approval of a biocidal active substance. We try to clarify the difference.

In the EU’s Biocidal Products Regulation (BPR) it is a requirement that suppliers of biocidal active substances or other legal entities in the chain of supply are included in the Article 95 list of active substance suppliers. Any active substance used in the formulation of biocidal products must be purchased from a supplier or legal entity listed under Article 95 to be compliant with the BPR provisions.

Not all active substances in Article 95 are approved

However, a biocidal active substance that appears in the Article 95 list is not necessarily approved yet. The substance might still be under review for approval by the EU authorities as an active substance. This means that the article 95 list contains a mix of biocidal active substances that are either “approved” or “under review”.

To ascertain the status of a biocidal active substance you must consult ECHA - or contact us for more information:

Ilaria de Rosa Carstensen  
Tel +45 4516 9369