When biocidal products are notified, the concentration of the active substance has to be indicated in accordance with the ChemBiozidDV. What concentration has to be indicated for active substances produced in situ?
For biocidal products that are made available on the market to be used for the production of active substances on site (in situ), the concentrations of the active substances produced are to be indicated. However, the concentrations of the active substances produced vary depending on the application intended for the biocidal product.
For technical reasons, it is only possible to specify a concentration and not a concentration range when notifying a biocidal product of this kind. Therefore, please specify the minimum concentration of the active substance produced in g/kg that will be reached if the biocidal product is used in accordance with the instructions for its use.
ChemBiozidDV FAQ 20
How do biocidal products have to be notified under the ChemBiozidDV when they consist of two components used for the in situ production of active substances?
Should the two components (to be used to produce an active substance at the site of application/in situ) be made available on the market as a bundle or in one package, they must be notified together as a biocidal product.
If two components are made available separately on the market, they should also be notified as one biocidal product under the Biocide Law Implementation Ordinance (Biozidrechts-Durchführungsverordnung, ChemBiozidDV). However, technical adjustments are necessary when they are notified:
Where applicable, please indicate the different suffixes added to the name for the respective components (e.g. "A" and "B") in brackets after the trade name in the combined notification.
ChemBiozidDV FAQ 21
Does the precursor substance have to be notified if it constitutes the biocidal product subject to authorisation? Or can equipment manufacturers who rent or sell their equipment to customers notify the substance produced in situ? And if so, how?
The mandatory notification of products under the transitional measures laid down in Section 3(1) of the ChemBiozidDV is exclusively linked to "making available on the market". This means that only substances and mixtures made available on the market are relevant for the notification requirements under the ChemBiozidDV. Consequently, the precursor substance must be notified if it constitutes the biocidal product subject to authorisation.
Equipment manufacturers who only sell or rent the equipment for the production of the in situ active substance to customers are not required to notify. Mandatory notification only applies if the precursor substance is also made available on the market in addition to the equipment. Equipment manufacturers may carry out the notification as representatives for the suppliers of the precursor substances, where applicable.
ChemBiozidDV FAQ 22