On 25 November 2025, the European Chemicals Agency (ECHA) announced the launch of a public consultation to gather information on potential Candidates for Substitution (CfS) and the conditions for derogations concerning two active substances.
Please refer to the table below for details:
| Substance name | EC Number | CAS Number | Product type | Consultation start date | Consultation end date |
|
formaldehyde released from the reactionproducts of paraformaldehyde andbenzyl alcohol ((benzyloxy)methanol) |
- | - | PT06 | 25/11/2025 | 26/01/2026 |
| Silver nitrate | 231-853-9 | 7761-88-8 | 1, 4, 5, 9 | 24/11/2025 | 23/01/202 |
BPR Framework: Substitution and Approval of Active Substances
Under the Biocidal Products Regulation (BPR), the approval of active substances follows a more rigorous assessment process. When an active substance is found to have safer or more environmentally benign alternatives, ECHA identifies it as a Candidate for Substitution (CfS). A public consultation is then initiated to collect insights and data on possible alternatives before ECHA forwards its approval or renewal recommendation to the European Commission.
In cases where an active substance meets the exclusion criteria—such as being classified as carcinogenic, mutagenic, reprotoxic (CMR), or possessing PBT (persistent, bioaccumulative, and toxic) or vPvB (very persistent and very bioaccumulative) characteristics—the substance is typically not approved for use. However, exemptions may be granted under specific circumstances, such as when the substance is used in a closed system, is essential to address significant public health or environmental risks, and when no suitable alternative exists.
For substances that receive such derogations, the approval conditions are highly restrictive:
· Approval is granted for a maximum of five years
· Use is strictly limited to essential applications
· Each EU Member State must ensure all conditions are fully met before authorizing the use of the biocidal product in its territory
