2026 Update to Technical Agreements for Biocides 'Efficacy'

On the 13th March, ECHA published the first update to the Technical Agreement on Biocides ‘Efficacy’ for 2026, following their previous update in December 2025.

The topics they have covered in this update include:

• PT1-5: Efficacy testing of stored disinfection products during shelf life (update)
• Efficacy requirements for the authorisation of products against Asian hornets (new entry)

The first entry will be of interest to every applicant who is planning a submission of a PT1-5 dossier, as it has potential to impact plans for how these submissions will be supported.

The second entry delivers important information for applicants looking to submit PT19 dossiers, who look to make claims against Asian Hornets.

PT1-5: Efficacy Testing of Stored Disinfection Products During Shelf Life (Update)

In this update, entry 12 of the Efficacy TAB has been amended, which concerns the requirement for additional efficacy testing when the measured Active Substance concentration reduces by more than 10% over the life of a stability Study.

With this change, requirements for using aged samples have been made stricter, with the key recommendation now being that a batch of the product used in the long-term storage test should be used for the aged product efficacy testing.

The updated guidance now includes specific requirements when using products that were not part of the stability study as the tested samples.
Alongside these stricter requirements, is additional clarity. The required tests have been defined, with opportunities to forgo re-performing every relevant efficacy test – so long as the justifications are in place.

Efficacy Requirements for the Authorisation of Products Against Asian Hornets (New Entry)

A new entry (35) has also been included in this update specifying the efficacy requirements for products to be used against Asian hornets.

This entry details specific modifications and details on the requirements for the performance of efficacy testing, given the specific nature of Asian Hornets. This includes details for: laboratory, simulated-use and field trials.

Both of these updates will be applicable to submissions from:

• 13/9/26 for Active Substances
• 13/3/28 for Biocidal Products

However, it is always important to note that an eCA may apply new guidance, even if this was not the requirement at the time of the dossier submission.

At this time, it is also important to note the upcoming applicability of TAB entries from December’s update, for Active substances from 10th June 2026:

• PT3 hard surface disinfection and differentiation of virucidal claim (30)
• PT 2 (Healthcare) Sporicidal activity against Clostridiodies difficile/Clostridum difficile (31)
• PT 12 Test organisms for products used in oil and gas extraction (33)
• Efficacy evaluation for disinfection of wastewater (34)

If you're a manufacturer or supplier of biocidal products impacted by this update and are concerned about how they may impact your portfolio, Blue Frog Scientific can support you to understand what plans could be put in place and what actions you may need to take. Call or email and speak directly with one of our Biocide regulation consultants.