Hello and welcome to our BPR series!
Whether you're developing a cleaning product and trying to avoid unintended biocidal claims—or you're formulating something with a genuine biocidal function—you're in the right place. This article is part of a series designed to bring you up to speed on the Biocidal Products Regulation (BPR) and what it means for you.
We’ll keep things practical, plain-English, and free of unnecessary jargon—so let’s get stuck in.
What is BPR?
The Biocidal Products Regulation (BPR) is a regulatory framework that ensures biocidal products—like disinfectants, preservatives, and pest control agents—are safe for people, animals, and the environment. Any product placed on the EU or GB market that makes a biocidal claim must comply with these rules.
Our series will help you understand your obligations, whether you're aiming for full BPR approval or simply need to avoid accidental classification.
What is a Biocide?
BPR defines a biocide as:
“Any substance or mixture, in the form in which it is supplied to the user, consisting of, containing or generating one or more active substances, with the intention of destroying, deterring, rendering harmless, preventing the action of, or otherwise exerting a controlling effect on any harmful organism by any means other than mere physical or mechanical action.”
In short: if your product kills, repels, or controls bacteria, fungi, mould, insects or similar organisms—on purpose—then it could be classified as a biocide.
Biocidal Products and Active Ingredients
Biocidal products can be simple or complex—some use a single active substance, while others rely on a combination (or even on-site generation from two components). What matters most is the presence of at least one approved or registered active substance.
This active must be:
- Approved for the intended use; or
- Under official review via the BPR process.
If you’re making claims but using an unapproved or unauthorised active, your product may be considered non-compliant—even if you have your own test data.
Understanding EU BPR vs GB BPR
BPR originated as an EU regulation, replacing the earlier Biocidal Products Directive (BPD). Following Brexit, GB introduced its own version of BPR on 1st January 2020, overseen by the Health and Safety Executive (HSE).
At first, the two systems were virtually identical. However, divergence is growing in:
- Substance approval timelines,
- Data requirements,
- Evaluation procedures.
If you sell into both markets, you must now follow both frameworks independently.
What is a Competent Authority?
The Competent Authority (CA) is the body responsible for regulating biocides in each region.
- In the EU, each Member State has its own CA (e.g. PRCD in Ireland), with the European Chemicals Agency (ECHA) providing central oversight.
- In GB, the CA is the Health and Safety Executive (HSE).
They handle product and substance approvals, evaluate risks, and provide enforcement.
What is Article 95?
Article 95 lists approved suppliers of active substances for specific biocidal uses.
There are two versions:
- EU Article 95 (on the ECHA website),
- GB Article 95 (on the HSE website).
If you’re using an active from a supplier not listed under Article 95 for your product’s specific use case, your product may be considered non-compliant—even if the substance itself is approved.
Always check Article 95 for your chosen PT (product type)!
Understanding BPR Product Types
The BPR breaks biocides into 22 product types (PTs), grouped into 4 main categories:
- Disinfectants and General Biocides (PT 1–5)
e.g. human hygiene (PT1), veterinary disinfectants (PT3), surface cleaners (PT2). - Preservatives (PT 6–13)
e.g. wood preservatives (PT8), film preservatives (PT7). - Pest Control (PT 14–20)
e.g. insecticides (PT18), repellents (PT19). - Other (PT 21–22)
e.g. antifouling paints (PT21), embalming fluids (PT22).
Checking the approved PT for your active substance is essential for compliance and claim justification.
Using PT Groups: An Example (PT 2)
Say you’re making a general-purpose surface spray for retail sale—not a medical disinfectant, just something antibacterial for household use.
This likely falls under PT 2: Disinfectants and algaecides not intended for direct application to humans or animals.
If you’re placing this product on both the GB and Irish markets, you’ll need to:
- Check Article 95 for PT 2 in both GB and EU,
- Ensure the active ingredient is approved or under review in both jurisdictions,
- Confirm your supplier is listed under Article 95 in both.
This ensures your claims are valid and that you’re legally covered in both regions.
