Biocidal products in coatings: treated articles or biocides?

Biocidal products in coatings. Biocides in coatings play a crucial role in protection, prevention, and hygiene. Microbial protection is essential preventing the degradation of coatings by microorganisms such as bacteria, fungi, and algae. These organisms can cause discoloration, stains, and deterioration on coated surfaces. The application of biocides helps prevent the growth of these microorganisms, thus extending the lifespan and aesthetic appeal of coated surfaces.

In addition to coating protection, biocides also play a significant role in product preservation and promoting hygiene in various environments. In paints and coatings, biocides can prevent the growth of mold and fungi on walls and ceilings, ensuring a healthy indoor or outdoor environment. In the marine industry, anti-fouling coatings with biocides are applied to ship hulls to prevent the accumulation of barnacles and other marine organisms, which can increase resistance and reduce fuel efficiency.

In environments where hygiene is crucial, such as hospitals, kitchens, and food processing facilities, biocide coatings play a crucial role in preventing the growth of harmful bacteria and other pathogens on surfaces. These coatings not only improve safety but also prevent the spread of diseases.

In addition to their direct benefits in protection and hygiene, coatings containing biocides can generate significant long-term savings. These coatings often require less frequent maintenance, as they are less susceptible to the growth of external organisms. This reduced maintenance need translates into a longer lifespan for coated materials compared to untreated materials, resulting in substantial cost savings over time.

The distinction between a biocidal product and a treated article is crucial to understand the applicable regulatory framework (BPR). We often find significant differences in regulatory requirements for each case.

The distinction between a biocidal product and a treated article is essential to understand the applicable regulatory framework. A biocidal product contains an active substance intended to destroy, deter, or prevent the action of unwanted organisms. It can be a chemical substance, a natural extract, or a microorganism. In contrast, a treated article is any substance, mixture, or article that has been treated with one or more biocidal products.

In the case of a coated surface, the classification as a treated article or biocidal product depends on the primary function of the coating. If the paint is primarily intended to protect the coated surface from degradation caused by harmful organisms, it is considered a treated article. On the other hand, if the paint is formulated with a biocide active substance, and its main purpose is to prevent the growth of microorganisms on the coated surface, it is classified as a biocidal product.

Decision Tree

Understanding whether a surface coated with biocidal paint is a biocidal product or a treated article is crucial because it determines the regulatory framework.

First: Understand whether the article has been treated or intentionally incorporates a biocide.

• No: The article is outside the scope of the BPR.
• Yes: The article could be a treated article or a biocide

Second: Determine whether the treatment/incorporation imparts a biocidal function to the article.

• No: The treatment/incorporation protects the properties or function of an article or extends its durability. The product is a treated article.
• Yes: Is the biocidal function the primary function?

Third: Can we consider its primary function as biocide?

• No: The article is a treated article;
• Yes: The article is a biocide product.

This distinction is crucial in terms of regulatory requirements. Biocidal products require authorisation before they can be marketed, and the active substances contained in them must be previously approved. This process involves an extensive collection of data on the active substance, including physicochemical properties, overall efficacy, and toxicological and ecotoxicological properties. It is a costly process in terms of time and financial resources.

Commercialisation of biocidal products in coatings

Once the active substance is approved, the biocidal products containing it must be authorised before marketing. This process, although faster and less expensive than the approval of the active substance, still requires a complete set of data and a risk assessment for the product. On the other hand, treated articles are regulated by Article 58 of the BPR, and the marketing of these articles is subject to specific restrictions.

The marketing of treated articles involves providing consumers with information about the biocidal treatment of the article. Since March 2017, the marketing in the EU of treated articles with a biocide containing an unapproved active substance, included in Annex I, or under evaluation is prohibited. Companies must be willing to provide information about the biocidal treatment of their articles when consumers request it, and this service must be free and delivered within 45 days.

Additionally, manufacturers and importers of treated articles must label their products in accordance with the Classification, Labelling, and Packaging (CLP) regulation and the additional requirements of the BPR. The label must be easily understandable and visible to consumers, especially if the treated article claims biocidal properties or if it is required in the conditions of approval of the active substance contained in the biocide used to treat the article.

Do you need to comply with the Biocides Regulation applicable to your products? Contact us!

Source: PolymersPainColourJournal