1. How to indicate that biocidal product is for children?

The provisions of Regulation (EU) No 528/2012, especially those in Art. 1(1), Art. 3(1)(ad) and Art. 69(2) are aimed to protect human health and particularly health of children. 

The use of biocidal product - when it may be used also for children - should be precisely described (including minimal effective dose/concentration and other specific conditions for children) in the use instruction.

Mentioning „Kids“, „Children“ and similar words in the biocidal product name, that is most prominent part of the label, clearly violates Regulation provisions mentioned above and is not allowed.

2. How to relabel in accordance with CLP regulation biocidal products authorised under transitional measures of Article 89.2 of Regulation (EU) No 528/2012?

Authorisation holder should apply to Vilnius Public Health Centre for modification of authorisation certificate and provide labelling data in accordance with CLP regulation (Regulation (EC) No 1272/2008) – draft label, safety data sheets of product and its ingredients. Vilnius Public Health Centre will inform the applicant about payable tax (31 LTL (8,98 EUR)). After tax payment the annex to authorisation certificate (label) will be modified and start of validity date of updated version will be indicated. The number of certificate will not change. 

3. Syllable ECO or BIO in the product name.  Is it allowed product name with syllable ECO or BIO?

The Art. 69(2) of Regulation (EU) No 528/2012 prohibits any indication on the biocidal product label meaning that this product is natural, environmentally friendly and similar.

Syllabies ECO (EKO in Lithuanian) and BIO in the biocidal product name, that is most prominent part of the label, clearly violates Regulation provisions mentioned above and is not allowed.

4. Do moth monitoring traps fall under the scope of Regulation (EU) No 528/2012?

Moth traps that contain attractants to capture moths might be seen as biocidal products and, therefore, treated as such, or as traps with the purpose only to detect the presence of the moths (harmful organisms) that it is not covered by Biocidal Products Regulation. It is therefore essential to establish the purpose of such traps. According to Biocidal Products Regulation‘s article 3(1) definition, a biocidal product is a substance or a mixture, in the form in which it is supplied to the user, containing one or more active substances, with the intention of deterring preventing the action of, or otherwise exerting a controlling effect on any harmful organism by any means other than mere physical or mechanical action. A treated article that has a primary biocidal function is also considered to be a biocidal product. If the moth traps have a purpose of attracting and exerting the controlling effect (e.g. killing, disrupting the mating process), this shall be considered as a biocidal product in accordance with Article 3(1)(a) of Regulation (EU) No 528/2012 and shall fall within product-type 19 as defined in Annex V to that Regulation. Nevertheless, in cases when products’ label claims that this product is for monitoring purpose only and it does not have any controlling effects on moths, such traps would be out of Regulation (EU) No 528/2012 scope. Two examples are given below: 1. Information given on products’ A label: “Moth monitoring traps containing pheromones: attracts and instantly kills male moths” indicates that this product is a biocidal product. 2. Information given on products’ B label: “Moth traps containing attractants detects the presence of moths. The acquired information shall be used for further infestation treatment accordingly” shows that these traps are only for monitoring purposes and they are out of BPR scope.

Atnaujinimo data: 2023-11-20