Assessment backlog due to more complex biocidal product applications

At the end of October, the Directorate-General for Health and Food Safety of the European Commission (DG Santé) published a report on the implementation of the European Biocidal Products Regulation in the Netherlands. The report concerns the assessment and authorisation of biocidal products.

In its introduction to the report, the Commission stated that an effective system for the authorisation and control of biocidal products has been in place in the Netherlands since the 1960s. This has provided a solid basis for the biocidal products sector. The Commission also noted that the Dutch Board for the Authorisation of Plant Protection Products and Biocides (Ctgb) has incurred a backlog in the assessment of biocidal products since 2017. The report does not give an opinion on this backlog, but refers to the argumentation by the Ctgb. The Ctgb acknowledges the conclusions of the report. The coordination between Member States, as stipulated by the European Biocidal Products Regulation of 2013, has required considerably more time than expected. All applications under the Regulation must go through an European procedure. Discussions about assessment issues have become more frequent, also because biocidal product assessment is new for some Member States. In addition, the Regulation provides for the possibility of grouping various biocidal products into a single 'biocidal product family’, which is then assessed in its entirety. For producers of biocidal products this ‘family option’ is attractive for various reasons. For example, the Ctgb has received an application for assessment of a biocidal product family with 160 different uses. Due to the size and complexity of these families, the time required for the assessment can more than double. The Netherlands is not the only country that has identified these problems with the new Regulation.

The Ctgb has accepted applications for biocidal products and families in accordance with its own multi-year planning. However, the time required to assess these applications has turned out to be considerably longer than expected, causing backlogs. To meet this challenge, the Ctgb has assigned experienced employees from elsewhere in the organisation to assess biocidal product applications. New employees have also been recruited, but they have to be trained and are not immediately productive. With these measures, the Ctgb plans to eliminate the backlog by the end of 2021. At the same time, the Ctgb (together with competent authorities in other Member States) has requested the EU to use appropriate regulations to counteract the formation of excessively large biocidal product families, which take much longer to assess. This combination of measures should provide a practical approach for businesses and Ctgb to reduce the backlog.