In accordance with Article 2 of the Biocidal Products Regulation (BPR), products which are covered by "other relevant regulations" are not within the scope of the BPR. The MHRA have confirmed that product type (PT) 1 products will be in scope of medicines regulations where they make claims against mycobacteria, and hence for this use they will be out of scope for the BPR. PT1 products are disinfectants for human hygeine, for example hand sanitisers and hand washes.
Applications for BPR product authorisations to the HSE for GB and NI will not be able to include claims against mycobacteria for PT 1. Instead these products will need to comply with medical regulations for these claims.
https://content.govdelivery.com/accounts/UKHSE/bulletins/3bcd57b
