12. December 2018 | Position
With the Biocidal Products Regulation, several products can be recorded in a single application as a product family. ECHA is currently discussing whether a limitation on the formation of product families is required. From the industrial point of view, the product family concept must not be compromised. The VCI addresses the issues that are of particular importance to the industry and calls for a practical implementation of the concept.
Content of VCI's position paper
With the Biocidal Products Regulation (EU) No. 528/2012 (BPR), several products can be included in a single application as a product family.
After initial experience with applications for approval of product families, ECHA discusses the extent to which it is necessary to limit the formation of product families.
From the industrial point of view, the product family concept must not be compromised. In this position, the VCI addresses the issues that are of particular importance to the industry and calls for an implementation of the product family concept that meets the practical requirements of the companies.
The Biocidal Products Regulation describes the possibility of allowing several products as a product family in one application. A biocidal product family is a group of biocidal products
- for the same purpose,
- with the same active ingredients,
- of similar composition with specified deviations,
- with similar risk potential and similarly strong efficacy.
Essential cross-product approaches
The types of products subject to the same rules in the BPR are very different. For this reason, the approaches and priorities of the individual applicants are different. The following two general approaches and family concepts were found to be significant across product types:
- variations in the application
- variations in the composition
Currently, there are products on the market for different applications that can be meaningfully recorded in a product family. In the case of niche products for applications with a very small market, approval within a product family is often the only way to obtain these products.
In order to reduce the effort involved and to meaningfully implement the approval of certain products that are available on the market at the same time, which differ in individual recipe components, it is necessary to combine them into one product family. Examples are products with different colors.
Please find the complete position paper of VCI (size: 4 pages) in the download section at the top of this page (so-called "Langfassung").
For questions or suggestions, please feel free to contact us.