HSE Sunset Another Batch of Biocidal Active Substances
Earlier this year, the HSE published a decision (Reference 2026-001) regarding the non-approval of biocidal active substances in GB.
The active substances covered in this decision are:
From Appendix 1 – Part 1 (Reference 2026-001)
Active Substance Name | CAS Number / EC Number | Product Type(s) |
Active bromine generated from bromine chloride | n/a | 11 |
Active bromine generated from hypobromous acid and urea and bromourea | n/a | 11 and 12 |
Active bromine generated from sodium bromide and calcium Hypochlorite | n/a | 2 |
Active bromine generated from sodium bromide and chlorine | n/a | 2 |
Active bromine generated from sodium bromide and sodium Hypochlorite | n/a | 2 |
Active bromine generated from sodium bromide by electrolysis | n/a | 2 |
Active bromine generated from sodium hypobromite and N- bromosulfamate and sulfamic acid | n/a | 11 |
Monolinuron | 1746-81-2 / 217-129-5 | 2 |
Chrysanthemum cinerariaefolium, extract from open and mature flowers of Tanacetum cinerariifolium obtained with hydrocarbon solvents (redefined from pyrethrins and pyrethroids and Chrysanthemum cinerariaefolium, ext.) | 89997-63-7 / 289-699-3 | 18 and 19 |
From Appendix 1 – Part 2 (Reference 2026-001)
Active Substance Name | CAS Number / EC Number | Product Type(s) |
2,2-dibromo-2-cyanoacetamide (DBNPA) | 10222-01-2 / 233-539-7 | 2 |
Silver nitrate | 7761-88-8 / 231-853-9 | 1 |
Peanut butter | n/a | 19 |
Reaction products of 5,5-dimethylhydantoin, 5-ethyl-5-methylhydantoin with bromine and chlorine (DCDMH) | n/a | 11 |
Reaction products of 5,5-dimethylhydantoin, 5-ethyl-5-methylhydantoin with chlorine (DCEMH) | 89415-87-2 / 401-570-7 | 11 |
Active Substance Non-Approval Key Dates
In line with the decision, the following dates were set:
Non-approval date: 1st April 2026, which has now passed.
In line with Article 89 (Existing Transitional Measures), paragraph 8 - biocidal products may continue to be made available on the market up to 12 months after the date of non-approval, and their use may continue for up to 18 months. This led to the following dates being provided:
Making available on the market end date: 1st April 2027.
Use end date: 1st October 2027.
Treated articles placing on the market end date: 28th September 2026.
The decisions for these substances were made for the following reasons:
Failure to resubmit application to HSE, despite application in the EU still ongoing, following the end of the Brexit transition period.
Withdrawal of application by applicant.
No notifications, or subsequent dossiers, received by the HSE following an open invitation.
Notifications & Concerns
Following the open invitation process, notifications of new applicants wishing to take up the application were received for monolinuron (PT2) and chrysanthemum cinerariaefolium (PT18 and PT19). Deadlines set for the submission of a dossier for each of these substances have since gone by, and no dossiers were received by the HSE.
With the publication of the non-approval of ‘active bromine generated from certain precursors’ (PTs 2 and 11), there were some concerns that there would be a knock-on impact on stakeholder industries. HSE have confirmed that they believe there are effective alternate active substances available for use.
The active substances which did not have any re-submissions to GB are listed in Appendix 1 (Part 1) of the Active Substance Decision Reference 2026-001.
Participant Withdrawal
As part of this decision, the HSE also present five active substances for which there was originally a submission, but the participant withdrew support.
No dossiers were received by the HSE following an open invitation to take over support for these substances leading to their non-approval.
These substances were listed in Appendix 1 (Part 2) of the Active Substance Decision Reference 2026-001.
Impact to Industry
Now that the approval date has passed, manufacturers and distributors must wind down their use of the Biocidal Products containing any of these Active Substances in order to meet the deadlines under the Regulation.
Any consumers of these products must look into alternatives which suit their requirements, as the products should not be used by the end of Q3 2027.
If you're a manufacturer and would like to explore the requirements behind bringing one of these active substances to the GB Market, or any other Active Substance, call or email to speak with one of our biocide regulatory experts, who will be happy to talk you through the process.