Treated articles are substances, mixtures or articles that have been treated with a biocide or into which a biocide has been intentionally incorporated (impregnated wood, paint that is formulated with a preservative, anti-odour socks, antibacterial carpet, etc.). Treated articles whose primary function is biocidal are classified as biocidal products.
The Regulation contains provisions which apply both to biocidal products and to any articles that have been treated with or incorporate a biocidal product. In particular, articles can only be treated with active substances that have been approved in the EU for that purpose. This is a significant change to the previous scheme, where articles imported from non-EU countries were permitted to have been treated with substances that are not allowed in the EU.
Treated articles have been regulated since 1 September 2013. The European 'Note for Guidance' (see ECHA) contains a great deal of information about how these treated objects will be regulated.
An important aspect is that treated articles must be appropriately labelled. If the manufacturer of the treated article includes a claim related to the biocidal properties of the article or if instructions are included related to hazards for humans or the environment, then appropriate labelling is obligatory.
Further detailed information about the practical approach for the implementation of the concept of treated articles based on the updated provisions of the Biocidal products Regulation is described in the CA-document CA-Sept13-Doc.5.1.e(Rev1) - treated articles guidance doc and CA-May15-Doc.6.1 – Final – Labelling of TAs.docx. The CA documents CA-Sept13-Doc5.1g and CA-Jul13-Doc.5.1.g contains some background and Q&A on this issue. These CA documents are available on the public part of the CIRCABC.
If you are unsure whether a particular article is classified as a biocidal product or a treated article, you can submit this question to the service desk of the Ctgb. For other questions and information about treated articles, consult the website of the RIVM.