Use of biocidal products in agriculture
New biocidal products, and authorised biocidal products after renewal, may be used in agriculture only if they are authorised for general hygiene. Therefore, a biocidal product that is specifically intended for protecting plants or plant products is no longer possible. For example a product for general disinfection of empty greenhouses is not a biocidal product because greenhouses are intended to grow crops. For such uses, authorisation as a plant protection product is required.
For implementation in practice, the table below has been provided. Because the modified policy is especially important for disinfection, the table focuses on the use of disinfectants.
Plant protection product*
to control specific plant pathogens
protection of plants or plant products
it is not clear in advance whether this involves the protection of plants or of humans, animals or objects
Use in agriculture
if at least one of the above conditions (organism or aim) is met
if both of the above conditions (organism or aim) are met
* If a product has a claim that concerns a plant protection product, then it is not a biocidal product (Article 2.2i BPR).
The extent to which biocidal products can still be used in agriculture depends on the specific arrangements between authorisation holders and the Ctgb. The above table will be used for this purpose.
What does this mean for authorisation holders of biocidal products?
Authorisation holders are advised to screen their authorised disinfectants for unacceptable claims in accordance with the modified policy. In consultation with users and their industry organisations, the Ctgb will publish a list of uses that will no longer be authorised. For these uses, an application for authorisation as a plant protection product can be submitted (possibly via mutual recognition).
What does this mean for users?
Users are advised, in consultation with their professional association, to contact suppliers and authorisation holders and indicate which uses are essential. Users are responsible for their choices of disinfection products. After the modified policy goes into force, if an authorised biocidal product is used to deal with a hygiene problem that is actually a crop protection problem, then this is incorrect use of the authorised product; in that case the safe and effective use of the product cannot be guaranteed.
What can the Ctgb do?
The Ctgb can answer questions from authorisation holders about which claims for authorised biocidal products are acceptable under the modified policy and which claims are not. It can also provide information about the possibilities for converting a biocidal dossier to a crop protection dossier and the costs for doing so. This can be done on the basis of actual dossiers and specific questions.
For more information, refer to:
- the policy memorandum on biocidal products with uses in plant protection (in Dutch). The appendix of the memorandum includes examples of regulatory requirements for the corresponding active substances, which have been previously established by the Ctgb. For each requirement, based on the above table, it is indicated whether the requirement concerns a biocidal claim or a plant protection claim, and whether the claim will still be possible as part of a biocidal product authorisation.