Sustainable use of biocidal products

The sustainable use of biocidal products is increasingly gaining in importance, also in respect of Article 18 of the Biocidal Products Regulation. VCH and VCH have looked intensively into this issue. They are urging to examine the benefits of the product group just like the potential influence on the environment. This paper is intended to serve as a basis for argumentation in discussions with the competent authorities, science and professional audiences..

Background

In Article 18 of the Regulation Regulation (EU) No 528/2012, in force since 1 September 2013, the EU-commission is asked to submit to the European Parliament and the Council a report on how this Regulation is contributing to the sustainable use of biocidal products. On basis of that report, the Commission shall, if appropriate, submit a proposal for adoption in accordance with the ordinary legislative procedure.”
Current proposals try to draw analogies to plant protection.

The position of VCI and VCH in a nutshell

The market for biocidal products is highly heterogeneous: There are 22 product-types, very different forms of application well as three categories of users (professional, industrial, non-professional). For these reasons, VCI and VCH take the view that it is not possible to develop just one catalogue of measures for sustainable use of all biocidal products.

Potential measures for sustainable use of biocidal products need to be examined individually on a case-by-case basis, with an orientation to the numerous and different uses. Generally, an assessment of potential measures is possible only in an approach specific to use, product-type and active substance.

The assessment of sustainable use of biocidal products needs to comprise the following points and should consider them on equal standing with each other: environ­mental goals, health aspects, the social component, and the economic component including international competitiveness.

Consequently, political measures and instruments have to be examined not only as to their effects on the environment. Such examinations should also carefully look into the relevant impacts on health and hygiene standards, on the benefits pursued by the use of biocidal products as well as the economic activities and the competitiveness of the companies. Indiscriminate volume reduction targets – without giving due consideration to the benefits of biocidal products – cannot achieve the given aims and even involve risks, e.g. to the necessary compliance with hygiene standards.

The chemical industry and chemical traders and distributors support a responsible and sustainable use of biocidal products, giving consideration to the three components of sustainability and to the benefits of biocides. This is understood to mean that biocidal products are used

• to achieve optimal results and a long-term efficacy of the treatment;
• while reducing potential risks to health and environment to a minimum;
• in a well-targeted manner;
• in their intended field of use.

For the above, it is of central importance to use biocidal products as specified by the manufacturer.

VCI and VCH welcome that under Article 18 of the Biocidal Products Regulation a possible introduction of additional measures should aim to reduce to a minimum the risks posed by biocidal products to health and the environment. Consequently, an intro­duction of additional measures must be preceded by a scientific risk assessment which considers both risk and exposure. Volume reduction targets which ignore the benefits of biocidal products cannot bring the desired effect.

Manufacturers already support use as intended intensively

With the documents attached to this paper, Industry encourages the correct application of the relevant products: in the meaning of sustainable use. These documents are being updated continuously. They highlight the fact that information materials are available for all product groups, in order to support the various users in the correct application of biocidal products. This clearly shows that industry assumes – already now and as a voluntary initiative – a major part of the responsibility for a sustainable use of its products.

You will find the complete position paper of VCI and VCH (7 pages all in) in the download section at at the top of this page. The six annexes mentioned stand ready under the point "Ergänzende Downloads".