News Brief
Recently, the European Commission officially launched a comprehensive evaluation of Regulation (EU) No 528/2012 on biocidal products (BPR). According to the latest announcement, the Commission opened the public consultation and Call for Evidence on its official "Have Your Say" portal on 11 December 2025. This consultation period will remain open until 5 March 2026. The evaluation aims to assess the performance of the BPR over its 12 years of implementation, address issues such as market inefficiencies and approval delays, and lay the foundation for a possible future revision of the Regulation.
Background: Why the European Commission Is Evaluating the BPR Now
The Biocidal Products Regulation (BPR), in force since 1 September 2013, establishes a two-step system for the approval of active substances and the authorisation of biocidal products in the EU, with the aim of improving the functioning of the single market while ensuring a high level of protection for human health and the environment.
However, the Commission’s 2021 implementation report identified major shortcomings, including significant approval delays, limited innovation in new active substances, and a high administrative burden for industry, particularly SMEs.
Against this background, the EU will carry out a comprehensive evaluation of the BPR in 2025 to assess whether it remains fit for purpose.
Key Aspects Assessed in the BPR Evaluation
This evaluation covers the implementation of the BPR from 2013 to September 2025 across all EU Member States and associated countries. According to the published Call for Evidence, the evaluation will focus on the following five criteria:
Effectiveness: Has the Regulation effectively improved the functioning of the EU single market? Has it achieved the objectives of protecting human health, animal health, and the environment? Are there any unexpected or unintended effects?
Efficiency: Analysis of regulatory costs versus benefits. It will assess potential administrative inefficiencies and examine opportunities for simplification and reduction of administrative costs (particularly for SMEs).
Relevance: Whether the objectives of the BPR remain relevant in meeting current and emerging needs and technological progress.
Coherence: Examining the consistency of the BPR with other relevant EU legislation, specifically Regulation (EC) No 1907/2006 (REACH Regulation), Regulation (EC) No 1272/2008 (CLP Regulation), Regulation (EC) No 1107/2009 (Plant Protection Products Regulation), and Regulation (EC) No 1935/2004 (Food Contact Materials Regulation).
EU Added Value: Assessing whether the Regulation has produced results that would not have been achieved by Member States acting alone.
Compliance Recommendations from REACH24H
This evaluation and any subsequent revision of the Regulation may have significant implications for the biocidal products supply chain, including potential simplification of approval procedures to address approval delays, reduced administrative burdens through digitalisation—particularly benefiting SMEs—and increased alignment with related legislation such as REACH and CLP, requiring companies to closely monitor potential changes affecting cross-regulatory compliance.
It is recommended that relevant companies and industry associations take the following actions:
Actively Participate in the Public Consultation: The consultation window is open from 11 December 2025 to 5 March 2026. This is the optimal time for the industry to report practical difficulties (such as economic losses caused by approval backlogs, unreasonable data requirements, etc.) to regulators. Companies should submit comments via the "Have Your Say" platform or consolidate views through industry associations.
Identify Compliance Pain Points: Companies should internally collate specific cases encountered during BPR compliance over the past 12 years, particularly instances involving administrative inefficiencies or conflicts with regulations like REACH, to provide data support for their feedback.
Monitor Subsequent Targeted Consultations: In addition to the public consultation, the European Commission will carry out targeted consultation activities involving Member State competent authorities, companies (including SMEs), the European Chemicals Agency (ECHA), via questionnaires, interviews, and workshops. Companies should stay informed to participate deeply in technical discussions.
This BPR evaluation is a major event in the EU agrochemical and biocides regulatory field. The findings will directly inform the revision of the Regulation, with the revised legislative proposal scheduled for adoption by the Commission in Q1 2027.
For companies committed to long-term development in the EU market, this is not only a period for compliance execution but also a time to participate in rule-making. Please ensure feedback is completed before the deadline of 5 March 2026 to advocate for a more scientific and efficient regulatory environment for the industry.
For more information and inquiries, please feel free to contact us at customer@reach24h.com.
