Biocidal Products Regulation
| Biocidal Products Regulation | |
| Instrument | Regulation (EU) No 528/2012, as it applies in Great Britain |
|---|---|
| Common name | GB BPR |
| Regulator | Health and Safety Executive |
| Two decisions | Approval of an active substance; authorisation of a product |
| Scope | Making available on the market, and use |
The Biocidal Products Regulation governs the supply and use of biocidal products in Great Britain. It is Regulation (EU) No 528/2012, concerning the making available on the market and use of biocidal products, as it applies here.[1] A biocidal product is one intended to destroy, deter, render harmless, prevent the action of, or otherwise exert a controlling effect on a harmful organism by any means other than mere physical or mechanical action.[1] Products applied to a roof to kill moss, lichen or algae fall within that definition. The Health and Safety Executive is the regulator.[2]
Two decisions, not one[edit]
The Regulation operates through two separate decisions, and conflating them is the single most common error in trade and consumer material on roof treatments.
The first is **approval of an active substance**: the chemical that does the work is assessed and, if approved, is listed for particular product types.[1] The second is **authorisation of a biocidal product**: a specific formulation, sold under a specific name, with a specific label and specific permitted uses, is authorised.[1]
An approved active substance does not make every product containing it lawful. A product containing an approved active substance still requires its own authorisation, and that authorisation is what defines the uses, concentrations and conditions under which it may lawfully be applied.[1]
Product types[edit]
The Regulation divides biocidal products into product types by intended use.[1] A product authorised for one product type is not thereby authorised for another, so an active substance approved for a use unrelated to construction says nothing about a roof treatment.
This is why a claim that an ingredient is "approved" is not, on its own, information. The questions that carry meaning are which product is authorised, for what product type, and on what terms.
Use as well as supply[edit]
The Regulation covers both the making available on the market and the USE of biocidal products.[1] A user is therefore not free to apply an authorised product however they choose: the authorisation carries the conditions of use, and departing from them — a concentration other than the authorised one, or an application the authorisation does not cover — is not made lawful by the product itself being authorised.
Label conditions are the practical expression of this. They are not manufacturer guidance to be weighed against experience; they are the terms on which the product may be used at all.
What this article does not state[edit]
It does not list which products are currently authorised for roof treatment, or which active substances are currently approved. Those lists change as authorisations are granted, varied, renewed and withdrawn, and a list reproduced here would be a snapshot presented as a standing fact.
The Health and Safety Executive maintains the current position.[2] Its pages render their content in the browser rather than in the page source, so this site cites it for its role as regulator and directs the reader there for anything current, rather than reproducing figures it cannot verify.
See also
- Biocides in roof cleaning
- Control of Substances Hazardous to Health
- Soft washing
- Roof cleaning
- Biological growth on roofs