1. The use of disinfectant products on inert surfaces falls within the scope of biocidal product legislation.
  2. Application to the skin of humans and animals
  • Application to skin that is intact and remains intact of humans or animals: this is a biocidal product. A product which is applied to skin that is intact and remains intact, for the purpose of disinfection of the surgeon/surgical personnel, preceding a medical intervention (on a patient), is also a biocidal product.
  • Application to non-intact skin (wound disinfection) or to intact skin that will subsequently be opened (causing a wound): In these cases, the product is defined as a veterinary/medicinal product. Because it is likely that the product will come into contact with a wound after the skin is opened, products for disinfecting the skin with the intention of opening the skin immediately afterwards are subject to the statutory regulations for medicinal products/veterinary pharmaceuticals. It is irrelevant whether the skin is opened for a medical purpose, such as surgery or injection, or for another purpose such as tattooing, piercing or applying permanent makeup.