ECHA Launches Public Consultation on Potential Candidates for Substitution and on Derogation Conditions

On November 25, 2025, the European Chemicals Agency (ECHA)  announced the launch of a public consultation to solicit information regarding candidates for substitution (CfS) and derogation conditions for two active substances. Please refer to the table below for details:

BPR Process for Substitution and Approval of Active Substances

Under the Biocidal Products Regulation (BPR), the approval process for the use of active substances is more stringent. If an active substance is considered to have safer and more environmentally friendly alternatives, then ECHA will list it as a CfS, and conduct a public consultation to collect information about the alternatives before submitting a recommendation for approval or renewal to the European Commission.

Additionally, if the active substance meets the exclusion criteria, such as being identified as carcinogenic, mutagenic, toxic for reproduction, or having persistent, bioaccumulative, and toxic (PBT) or very persistent and very bioaccumulative (vPvB) properties, it is generally not approved for use. However, in special cases, such as when the substance is used in a closed system or is essential for controlling serious health or environmental threats, and there is no suitable alternative, approval may still be considered.

For substances that are granted exemptions, the conditions for approval are extremely stringent, the approval period is usually no longer than five years, and the scope of use is strictly limited. Each member state must ensure that all conditions are met before approving the use of the biocidal product within its territory.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Further Information

ECHA