Documentation discussed in the context of the BPF WP is available to the public on CIRCABC. The Commission, the Authority (ECHA), Member States Competent Authorities and accredited stakeholder organisations have formed this BPF WP in order to discuss and revise the presently valid criteria on the implementation of the concept of BPF as laid down in the CA document „CA-Nov14-Doc.5.8 – Final.rev3“. Just very recently, a revised CA document on the implementation of the BPF concept, CA-May19-Doc4.8, has been uploaded in CIRCABC and it is scheduled for discussion in the next CA meeting on 16-17 May 2019.
The following criteria form the basis for the similarity check performed by the evaluating Competent Authorities (eCA):
The definition of the similarity criteria will be interpreted more strictly in the future, leading to less flexibility with regards to uses of the biocidal products accommodated in a BPF. Following limitations have been suggested with respect to similarity of uses:
These numbers were arbitrarily defined and are not based on regulatory/scientific-technical aspects. The recommendations of the BPF WP presently available suggest that previously submitted BPF applications will have to be modified in order to comply with the revised similarity criteria.
The final decision of the eCAs on implementing of the BPF WP recommendation will determine the consequences for currently running BPF applications. Regardless of whatever the eCA feedback is, the knoell biocides team with its long-standing regulatory and technical expertise in the biocides area can assist you with the regulatory and technical hurdles this development may bring.