In many ways nothing has changed. The regulations are still stumbling towards some distant conclusion like a Leicester City supporter trying to find their way home from the pub after winning the premier league (well done Leicester).
There are still plenty of unanswered questions but there is now a faint whiff of agreement in the air.
There seems to be little hope of a sensible charging system or a less onerous and expensive registration system but at least the requirements for registration are becoming more defined.
All actives used in biocidal products must now be manufactured by a producer that has registered their active (or actives) for use within the EU. Products also have to be registered for the relevant product types. This means that if an active hasn’t been registered for human hygiene (PT1 hand sanitizer or bactericidal hand wash) it cannot be used in that application.
Use outside the EU remains less restricted but I am sure that will all change as the world becomes informed and aware of potential trade restrictions for non registered products.
ASL has been looking to Active manufacturers to supply registered Frame formulations. This will enable us to continue supplying biocidal products, although the range may be reduced and flexibility of formula limited to colour and possibly perfume. Bespoke development will sadly be history. There will still be some cost involved as we will have to ‘piggyback’ register the frame formulations under our name but these costs should be more manageable. (But we can’t guarantee that this will not affect our prices sorry!)
The other issue that appears to be not totally clear is whether we will be able to supply the biocidal products as own label, or if they will have to be supplied under the ASL name with a sub-label ‘distributed by’.
ASL will continue to work with suppliers to ensure that the effect of these horrendous regulations does not impact too harshly on our customers.