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Home  > Publications  > Blog  > Biocides: Do we now have a final regulation?

Sunday, 26 May 2019

Biocides: Do we now have a final regulation?

Thursday, 28 August 2014 | Posted by: Sonja Schulte, European Coatings Journal

Since I work as an editor for European Coatings JOURNAL I have been followed by the biocide directive. For years we tried to publish a book on current biocide technology for paints and coatings. But there was no chance since the direction was steadily under change. Now it seems to me, that we got to a kind of final regulation harmonizing the market at EU level, simplifying the approval of active substances and so on. It is in place since September 2013. However, it seems to be quite complicated and needs a lot of paper work.

I am a chemist not a lawyer and to be honest I hardly understand this regulation. Despite the fact that the ECHA site ( offers an explanation ("understanding BPR”), I was not shiftier after reading. I rather though that approval and authorization of active substances must be a very hard task for small and medium sized companies.

Active substances: not always easy to identify

Obviously, it is not always clear to the producer of substances if his substance is an active substance or not. While scrolling through the page I found one point named "BPC opinions on other requests” (By the way BPC stands for Biocidal Products Committee). Here I found an "Opinion on a request according to Article so and so on Polymeric binder”

The request for the opinion and background

A company is placing AM Polymers (antimicrobial polymers based on quaternary ammonium compounds) / polymeric binder on the market for use in paints to confer anti-microbial properties to finished and dried paint surfaces. The company is claiming that the modified surface of the paint is responsible for mechanically destroying bacteria or fungi touching it and would therefore not meet the definition of a biocidal product as provided in Article 3(1)(a) of the BPR.The Netherlands requested a decision from the Commission as to whether AM Polymers are biocidal products or not.

Polymeric binder is an active substance!

Overall conclusion of the BPC opinion:

  1. The cross-linked AM polymers contribute to the biocidal properties of antimicrobial paints as the mode of action of the polymers is biocidal and not only physical or mechanical. Consequently the antimicrobial paint is considered a biocidal product as it is a mixture and is intended to have an antimicrobial effect (that is to kill harmful and pathogenic microorganisms on the paint surface)
  2. The AM polymer fulfills the definition of an active substance as provided in Article 3(1)(c) of the BPR as a polymer is a substance which in case of the cross-linked AM polymer has a biocidal effect.
  3. The active substance is the cross-linked polymer formed in-situ by the reaction of the AM polymer, the hardener and the second polymer. The specification of a definite identity of the active substance will be a matter of the active substance approval.

European Coatings CONFERENCE on Novel Biocide Technologies

To come back to my first point. As the regulation seems to be final the editorial team of European Coatings JOURNAL now offers in-depth information on biocides. We start with a 2-day conference in Düsseldorf, Germany with the following program: 

Monday, 29 September 2014
Day one
09.00 h Conference registration
09.50 h Welcome address and conference introduction
10.00 h Short course: Biocides basics
 Melinda Wales, Texas A&M University, USA
12.00 h Lunch
13.30 h Technical workshops
14.30 h Coffee Break
15.00 h Presentation of technical workshop results
15.30 h Market trends for biocides in antifouling paints in the shipping industry
 Darren Broderick, Safinah, GBR
16.00 h How to preserve waterborne formulations in the context of changing legislation
 Sandra Carstens, Schülke & Mayr, GER
16.30 h Coffee break
17.00 h Biobased biocides: Coming soon to a coating (very) near you
 Steve McDaniel, Reactive Surfaces, USA
17.30 h Experimental design and evaluation of biocide release from microcapsules
 Jonatan Bergek, Chalmers University of Technology, SWE
18.00 h End of day I
19.00 h Networking dinner
Tuesday, 30 September 2014
Day two
08.00 h Meet the speakers
09.00 h The new European Biocidal Products Regulation and its implications for the coatings industry - a practical review
 Linda Jones, Annex3 Consulting, NED
09.30 h Long-lasting antimicrobial protection for coating applications 
 Maria Toscan, Sanitized, SUI
10.00 h Audience poll
10.30 h Foam coating and atomic layer deposition as antimicrobial surface treatments
 Jari Vartiainen, VTT Technical Research Center Finland, FIN
11.00 h Coffee break
11.30 h  High performance film protection for architectural coatings
 Helmut Peters, Lonza Cologne, GER
12.00 h How to minimise the usage of biocides by optimising raw materials
 Andreas Götz, Ziegler & Co., GER
12.30 h Lunch
13.30 h Biocides in the present EU-regulation: General aspects and scientific considerations
 Annette Bitsch, Fraunhofer ITEM, GER
14.00 h Protecting the quality of raw materials, intermediate products or final products thanks to real-time microbiological monitoring by ATP G2
 Jasper Stegeman, Aqua-Tools, FRA
14.30 h Strategies for improved resistance against microorganism
 Christian Schaller, Sto, GER
15.00 h End of conference
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Sonja Schulte
European Coatings Journal
Sonja Schulte
Editor-in-Chief, Science & Technology
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