The European Chemicals Agency (ECHA) has updated the list of active substances and product-type (PT) combinations that can be used in treated articles under the Biocidal Products Regulation (BPR). The list is for information only. It does not have legal effect, and ECHA does not guarantee its accuracy. Companies are responsible for verifying compliance.

• The list is divided into three parts:
  • Part I: Approved or under review – treated articles containing these substances are legally on the EU market.
  • Part II: Withdrawn/non-approved – articles with these substances can no longer be placed on the market after a 180-day grace period.
  • Part III: Notified for inclusion – legally on the market while formal approval is pending.

This update could be relevant for you, particularly those involved in textiles, footwear, and equipment marketed with antimicrobial or insect-repellent claims. As I am not a chemicals expert myself, I invite you to check the attached list. (In the list PT stands for Product Type under BPR – list below)  

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Key points for our sector:

• Antimicrobial & odour-control finishes
  
  • Silver compounds, PHMB (polyhexamethylene biguanide), copper compounds, and isothiazolinones (MIT, OIT, CMIT/MIT) remain important for antimicrobial treatments in textiles and footwear.
  • Some substances (e.g. BIT, zinc pyrithione) face restrictions or withdrawal in certain product types.
• Insect-repellent & insecticidal treatments
  
  • Permethrin continues to be approved and widely used for outdoor clothing and mosquito nets.
  • Other approved options include deltamethrin, lambda-cyhalothrin, imidacloprid, margosa (neem) extract, citronella, eucalyptus citriodora oil, and IR3535.
• Compliance requirements
  
  • Only treated articles containing substances listed as approved (or in some cases “in progress”) for the relevant PT can be legally placed on the EU market.
  • Products containing substances under withdrawal or non-approval decisions must be phased out in line with ECHA deadlines.

Members can:

1. Review product portfolio for treated articles (e.g. antimicrobial textiles, insect-repellent clothing, outdoor gear).
2. Check the updated ECHA list to confirm that the active substances used are approved for the intended product type.
3. Prepare for substitution if treatments rely on substances that are being phased out.

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Main product types to lookout for:

• PT 9 (textiles, footwear, polymers)
• PT 18 (insecticidal clothing, nets)
• PT 19 (repellent finishes/sprays)
• PT 2 / PT 6 (disinfectant/antimicrobial treatments during storage or for surfaces in retail/gyms)

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The updated list can be downloaded below.

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