The European Chemicals Agency (ECHA) is currently holding a consultation period for Ethanol, with a deadline for input by 28 April 2025. ECHA has invited stakeholders to submit information on potential alternatives for the use of ethanol in biocidal products. This consultation is a critical component of the regulatory process under the new BPR guidelines and offers an opportunity for industry leaders to influence decision-making.
Engagement in Ethanol Consultation is Essential
Past precedents have shown that substances can be restricted or removed from certain product categories due to insufficient sector support. This situation raises questions about the availability of viable alternatives and the adequacy of regulatory guidance for manufacturers, not to mention potential overreach from regulators themselves. Ethanol for use in human hygiene is well documented as an effective substance used to safeguard public health, to restrict or remove the use of it could potentially have counterproductive effects.
Stakeholders are encouraged to participate actively in the consultation, while they still can do so, to ensure that their interests are represented and to help shape the future regulatory landscape for Ethanol.
If Ethanol is confirmed to meet the exclusion criteria, this consultation will likely be the first of many steps requiring strong industry support to ensure the substance, and associated products, remain on the market.
Have Ethanol's Regulatory Goalposts Moved?
For ethanol, the recent regulatory changes may appear to represent a shift in the goalposts. Initially included and submitted under the BPR review programme, ethanol is now subject to new guidelines that have only been in effect for the past two years. As the Biocidal Products Committee reviews ethanol’s classification as a CMR substance, it remains to be seen whether any challenge will be raised regarding the application of these new guidelines – particularly given that they were not in place at the time of the original submission. This is especially relevant considering that other CMR substances within the review programme have already received BPR approval without being required to meet these updated requirements. It raises important questions of parity and how evolving regulations, and guidance should be applied to substances that have experienced significant delays due to the ongoing review process.
The consultation will be published on ECHA’s website, and stakeholders can stay informed by subscribing to ECHA’s Weekly Bulletin for updates on Ethanol’s regulatory status and upcoming consultations.
If you’d like support with any aspect of this consultation, our biocide regulatory compliance specialists are ready to help. Call and speak with a member of our biocides team today.