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MARKET BIOCIDES REGULATION

::: European legislation on BIOCIDES
    regulations by Francesca Di Renzo
-----------------------------------------------------------
Safety and efficacy of products for everyday use.

How can we be sure that a common disinfectant is effective against bacteria and harmful organisms? The question is not limited to disinfectants, but also to all those everyday products whose efficacy and safety we take for granted. Usually, the guarantee that a substance has the properties described on the label, is as a result of the existence of regulations governing the marketing of so-called “Surgical Medical Aids” (“Presidi Medico Chirurgici”). This class of products includes disinfectants, insecticides and rodenticides, which need to be nationally authorised by the Ministry of Health in order to be marketed.
The authorisation is released only after a careful analysis of all documentation and studies concerning the single products. This, in addition to providing the end user more security and peace of mind, also ensures that a careful assessment of individual products is carried out at national level.
However, the Italian legislation regulating the marketing of surgical medical aids will soon be replaced by European legislation on "Biocides", whose aim will be to introduce a single legislation to standardize the behaviour of individual European countries, while continuing to ensure a high level of control, security and efficacy.
The Directive 98/8/EC, which regulates the marketing authorisation of Biocides, introduced a ten-year revision programme (subsequently extended to the 14th of May 2014) of all active ingredients on the market before May 14th 2000, in order to identify those substances whose use for the preparation of biocides may be deemed suitable and safe.
The substances thus selected are included in Annexes I and IA of Directive 98/8/EC, while those still under revision are included in Annex II of the Directive. Obviously, this careful assessment and identification of "acceptable" active ingredients assures the consumer that the product they purchased actually possesses these characteristics and properties stated on the label and, at the same time, guarantees the absence of highly toxic substances or harmful.
Thus, on the one hand, the consumer’s fears and doubts decrease, on the other hand the responsibility and the amount of work of companies producing biocidal products increase considerably. The Directive 98/8/EC introduces further compulsory analysis (toxicological and ecotoxicological studies) which must be carried out, in addition to the bactericidal and fungicidal studies that have already been introduced by the legislation on Presidi Medico Chirurgici. This results in a more complicated and controlled procedure for the marketing authorisation of disinfectants and insecticides.
In Italy the situation is even more complex, as both the Italian legislation on Presidi Medico Chirurgici and the European legislation on Biocides, needs to be taken into consideration for the marketing of disinfectants.
Thus, while some active substances are being reviewed at EU level, and therefore their use for the preparation of biocidal products is not allowed, their registration as Surgical Medical Aids/ Presidi Medico Chirurgici is however still possible in Italy. If one enters further into the maze of the difficult regulations of biocides, one notes that the assessment of individual active ingredients also takes place by considering the possible intended uses, or, as described in the legislation, according to the "product type (PT).

Biocidal products have been subdivided into 23 types of products, for which each active substance is analysed. At this stage, the only categories under revision are:
• wood preservatives
• rodenticides
• insecticides, acaricides and products to control
other arthropods
• repellents and attractants.

At this point, it is reasonable to pose the question of how Italian companies can untangle the difficult path that goes from Presidi Medico Chirurgici to Biocides, and to develop and prepare the necessary documentation to apply for marketing authorisation, while ensuring the maximum safety of their products.






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