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Product Authorisation Workshop on REACH and EU Biocidal Product Legislation in practice (Experiences from EU Industry) INT MARKT 48493 Belgrade, Serbia Raf Bruyndonckx 1 June 2012 Procedures and Requirements
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Outline General principles Procedures Application Data requirements Fees Role of industry associations 2
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Cefic 3 Cefic – European Chemical Industry Council Membership 28 national chemical federations > 600 companies > 20 affiliated sector associations Horizontal - vertical EU Policy Centre: REACH, International trade, energy and climate change, HSE, logistics, R&I … 104 Sector Groups
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EBPF 4 European Biocidal Products Forum Sector group of Cefic Regulatory developments of EU biocides legislation AS producers & BP formulators 70 members: companies, associations, federations Recognised stakeholder & observer Implementation BPD: AS evaluation – BP authorisation New Regulation
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EBPF – European Biocidal Products Forum General Assembly Management Committee General Issues Advocacy Team Communication Issues Team Data Sharing WG Product Authorisation WG Sustainable Use WG Dietary RA ISG Sector-Specific Issues Disinfectants WG Insecticides WG Rodenticides WG RDDG Best Practice WG
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BPR - New era starting Sep 2013 Updated EU biocides law applicable 1 Sep 2013 Regulation – directly applicable to all EU Same principles, improved procedures – mutual recognition, changes to products New concepts – EU authorisation, product family Extended scope – treated articles European Chemicals Agency 6
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Abbreviations BPDBiocidal Product Directive 98/8/EC BPRBiocidal Product Regulation ASactive substance BPbiocidal product PTproduct type PAproduct authorisation MRmutual recognition LoAletter of access MSmember state(s) 7
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Product Authorisation General Principles 8
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General principles 9 Authorisation is required before placing on the market Authorisation is granted for max. 10 years Authorisation can be granted if all conditions are fulfilled: AS is approved for relevant PT + AS source is on positive list The product is effective No unacceptable effects on target organism (resistance) No unacceptable effects on HH, ENV or animal health Chemical identity is known (impurities/residues) Phys-chem properties acceptable for transport and use
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General principles 10 A BP cannot be authorised for use by general public if: It is classified acute tox. (dermal, oral, inhalation); It is classified CMR 1 or 2; It has PBT properties; It has endocrine disrupting properties or It has developmental neurotoxic or immunotoxic effects
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General principles 11 Dossier elements: AS data: LoA or complete dossier BP data: complete dossier (or LoA) Assessment of hazard, risk (through relevant exposure) and efficacy Draft Summary of the biocidal Product Characteristics (SPC)
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SPC – the ID card of a BP 12 Trade name Authorisation holder – authorisation number Date of authorisation & expiry date Manufacturer of BP and AS Qualitative and quantitative composition Type of formulation – categories of users Instructions for use and safe disposal
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Product Authorisation Procedures 13
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Different procedures 14 (National) authorisation – provisional authorisation Mutual recognition (in parallel or in sequence) BPR: Union authorisation Coordination by ECHA, evaluation by MS, decision by COM Simplified authorisation procedure Parallel trade authorisation “Same product” authorisation
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Timelines 15 2 years to submit dossier 2 years to grant, amend or withdraw authorisations 3 months for completeness check 12 months for first authorisation 2 months to apply for mutual recognition 4 months to recognise first authorisation 3 months to resolve diverging opinions
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31/12/10 1/01/07 1/01/09 8/09/06 3 months completeness check (01/01 to 31/03/09) 2 months application for mutual recognition (01/04 to 31/05/10) 12 months 1 st evaluation and authorisation (01/04/09 to 31/03/10) 4 months recognition of 1 st authorisation (01/06 to 30/09/10) 3 months (01/10 to 31/12/10) † † No application/notification (30/06/09) Failed completeness check (30/09/09) Timelines 16
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Union authorisation - scope 17 Valid across all MS at once Similar conditions of use across the Union - guidance Excluded: Art 5 – PTs 14, 15, 17, 20 and 21 Sep 2013: new AS - PTs 1, 3, 4, 5, 18 and 19 Jan 2017: PTs 2, 6 and 13 Jan 2020: all categories Assessment report by 31 Dec 2017
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18 Conditions: AS in Annex I (BPR), no SoC, no nano, no PPE, sufficiently efficient No requirement for a LoA to AS dossier Submission to the Agency Evaluation by a MS within 90 days Once authorised, notification to other MS is sufficient – no MR Simplified authorisation procedure
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“Same product” authorisations 19 Identical products Existing practice (NL, FI, CH, SE, DK, PT, BE, IT...) Mutual recognition within a MS between companies Faster procedures Principle in BPR, follow-up regulation
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Product Authorisation Application 20
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R4BP 21 Register for Biocidal Products Electronic database – “EU catalogue of products” Application form – Applicant & product Decision and assessment report BPR: Electronic submissions – no more paper Central communication and process management tool Covers both AS and BP
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R4BP 22
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Product Authorisation Data requirements 23
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General outline 24 Data on the active substance(s) – LoA to Annex I dossier Substances of concern Data on the biocidal product Use description – exposure assessment Analytical methods Properties/Effect/hazard assessment (PC, TOX, ENV) Risk assessment Efficacy
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Data waiving 26 A data requirement is not relevant to the product and/or the intended use A study cannot be performed because the test is not feasible The outcome of a study can be accurately predicted based on a scientific argumentation The outcome of the study is in no way relevant to the risk assessment, classification and labelling or intended use
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Principle approach 27 Collate info on components - AS and SoC Start with detailed use description Derive possible exposure (exclude specific routes) Properties/Effect/hazard assessment Risk assessment – Risk reduction measures Efficacy
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Availability of data 28 Active substance dossier (LoA required) Co-formulants: REACH – MSDS Public literature
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Product Authorisation Fees 29
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Fees 30 Broad variation across MS First authorisation: 10.000 – 50.000 Euro Changes: 500 – 25.000 Euro Renewal: 500 – 50% of original fee Annual fee: fixed or related to sales
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Role of industry associations 31
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Role of industry associations 32 General representation of industry Endeavour to be recognised stakeholder Consensus driven position taking Competition law considerations No specific role regarding data sharing
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Useful sources of information 33 Note for guidance to applicants for PA and MR - linklink EU Evaluation Manual - linklink TNsG on data requirements – linklink TNsG on product evaluation – linklink Joint Research Centre – biocides section - linklink
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Raf Bruyndonckx +32 2 676 7366 rbr@cefic.be
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