Automotive sector finds unclassifiable biocide uses

According to guidelines, issued by the taskforce last year, most biocidal products that can be found in automotive products or processes fall under product-type two, six, seven, eight, nine, 11, or 13. But they also list examples of products that could fall under several of these. An example is the core of a vehicle’s air conditioning system. Its metal housing intentionally incorporates a biocidal active substance on the outer surface, to prevent the build-up of odorous micro-organisms. When the taskforce members could not agree on a product type for this case, it turned to the EU’s national competent authorities (CAs) for biocides for help, says taskforce chair Jonathan Swindell. “We were forced to come to some kind of conclusion,” he says, “because we can’t comply with the BPR unless we can prove a substance is approved for the product type [it is used for].” The group asked several CAs for advice but only the UK and French responded. Both said the product should fall under product-type two, which mentions air conditioning systems in its description in the BPR legal text. But the taskforce argues that this use applies to short-term treatment of existing micro-organisms, and not to long-term prevention. “It applies to disinfectants you would spray into the air conditioning system for a one-off treatment. It is less clear if [product-type two] applies to something that acts as a preservative,” says Mr Swindell. Some suppliers told the taskforce the product falls under product-type seven, which describes those meant to prevent microbial and algal growth on films. Others opted for product-type nine, which refers to biocidal products that prevent the settlement of micro-organisms on material surfaces to prevent odour. The taskforce has told its members to follow the CAs’ advice, says Mr Swindell, but is unhappy with their “unsatisfactory answer”. The problem, he says, is that “we have product types mostly carried over from the biocidal products Directive (BPD), which did not include the treated articles concept. And now that we try to apply them to treated articles, they are not always appropriate.” The taskforce hopes to find a more efficient way to solve future cases. “Ideally,” he says, “this would be in the form of a mechanism we could go through to get legal interpretations.” In want of a better solution, the taskforce will continue to ask member state CAs for their opinions in borderline cases. It hopes to collect more examples from industry and use its guidelines as a living document listing more and more cases, to create a bigger picture of gaps in the product-type picture. Further Information is available at: Guidelines

Chemical Watch, 18 May 2017 ; ;