Restricted Substances in Biocide Treated Articles
LASRA has been made aware of a document that has been circulating in the industry from Europe over the past couple of weeks, which sets out requirements for biocides applied to part-processed materials being shipped to Europe. This document discusses the transition from the Biological Products Directive (BPD) to the Biological Products Regulation (BPR, Regulation EU 528/2012), and how only a few substances have been given approval, none of which are included in Product Type 9 (PT9) which is the category for leather and part-processed leather materials.
During the transitional period there are two possible scenarios for biocide acceptance:
- Either they are active substances identified in Annex I of the BPD, and can continue to be placed on the market, or
- The product was notified for the relevant product type (PT9) but a decision on Annex I inclusion is still pending, the product can still be used but should it become unapproved must be removed from use 180 days after the decision or by September 1st 2016, whichever comes later.
The document recommends that a declaration be sought from the supplier stipulating compliance with BPR, at least identifying the active ingredient applied as “allowed”. However, since no active ingredient has so far been added to the ECHA list for PT9, it is impossible to currently state that any particular biocide is either “approved”, or “authorised”.
For NZ companies this could severely impact the ability to supply part-processed/ salted material which contains dichlorophen in the salt mixture to Europe, since it is one of the materials specifically identified in the accompanying information for non-inclusion in Annex I or Ia, and removal from the market. In the case of dichlorophen this decision was made in 2010, and the product phased out on 9th February 2011. Carbendazim is identified as one of the biocides on the list of substances for which dossiers have been supplied and it can continue to be used pending any decision, which whatever the outcome will allow its use until September 2016.
A list of chemical substances currently under evaluation can be provided on request from LASRA, along with the exclusion list. Dichlorophen was one of the restricted substances identified in a presentation at the Annual Conference in Palmerston North in 2011. Subsequently, LASRA carried out a number of salting trials in 2012-13 on lambskin, hide and calfskin to identify alternatives, and has provided the results of this research to members through the ITAG committee.