Biocidal products are used in numerous sectors and very diverse places: they improve hygiene in hospitals; help control organisms that can become a pest, such as rats or certain insects; attack fungi; protect products and materials from spoilage; etc. At the same time, the use of chemical pesticides poses risks to our health and the environment.
The Federal Public Service for Public Health wants to reduce those risks to health and the environment, so it has developed a reduction plan for biocidal products.
The continuous evaluation and the reduction of the risks of biocidal products are already incorporated in the national legislation (Royal Decree of 4 April 2019) and the European Biocidal Products Regulation (BPR) as a result of the European programme for the evaluation of active substances and biocidal products. ECHA's website provides more information on the review programme for active substances and the evaluation of products.
In addition to this existing review programme, a federal reduction programme for biocidal products is in place from 2023 on, with actions aimed at raising awareness, training and information, knowledge on health effects, monitoring specific, potentially problematic uses of biocidal products, providing data on the Belgian market of biocidal products, and market surveillance.
How did the reduction plan for biocidal products come about?
A Belgian reduction programme for chemical pesticides -plant protection products and biocidal products- is already in effect since 2005 (see NAPAN). However, this plan is more focused on plant protection products. To better address the importance and characteristics of the market for biocidal products, a specific federal reduction plan for biocidal products (FRPB) was created.
The legal basis of this plan is Art. 5(1) of the Belgian Law on Product Standards of 21 December 1998. As foreseen in this law, the necessary opinions were sought and a public consultation was organised. The joint opinion of the Central Business Council, the National Labour Council, the Special Advisory Committee on Consumption and the Federal Council on Sustainable Development can be read at this link. The Superior Health Council and the Advisory Committee on Biocidal Products (CAB - 1/12/2023) were also consulted. You can read the results of the public consultation and the adjustments to the draft plan via this link (report available in NL, FR, DE).
The Council of Ministers approved the plan on 3 March 2023. The reduction plan was then submitted to the Council of State and revised. The final plan (Dutch or French) was published in the official journal (Moniteur/Belgisch Staatsblad) on 14 December 2023.
The Belgian market for biocidal products
The FPS Health closely monitors the market for biocidal products, based on figures submitted annually by the companies that hold the autorisations. The annual report provides a detailed view of the Belgian figures via an interactive application.
Since 2018, the number of authorised biocidal products has been on the rise. This increase has two reasons:
- the increasing use of biocidal products, with a noticeable increase due to the coronavirus pandemic;
- the regularisation of biocidal products previously sold without authorisation or registration. Some of the temporary authorisations issued during the pandemic became new authorisations through the normal procedure.
In 2022, there were 3,394 approved authorisations for biocidal products. In a number of cases, the products in question are not placed on the Belgian market.
The quantity of products sold (tonnes) reached a maximum of 103,198 tonnes in 2020 and was slightly lower in the following years.
Disinfectants (Group 1) constitute the largest group: they account for 62% of authorisations and 59% of the quantities sold in 2022. Pest control products (Group 3) represent 21% of authorisations, but only 2% of the quantities sold in 2022.
Share of the different main groups (%) in the number of authorised products and the quantities of biocidal products placed on the market in 2022 (group 1: Disinfectants; group 2: Preservatives; group 3: Pest Control; group 4: Other Biocidal Products).
The goals of the reduction plan
Article 1 of the Royal Decree of 26 October 2023 establishing the federal reduction plan for biocides describes the general objective of the reduction plan:
'to reduce the risks, based on the precautionary principle, in order to ensure a high level of protection of human and animal health and the environment, with particular attention to the protection of vulnerable groups.'
The plan aims to reduce risks from biocidal products through qualitative objectives in different areas:
- raising awareness among the general public and professionals about the risks to health and environment from the use of biocidal products
- improving the knowledge and skills of users
- reducing the quantities and types of unauthorised products on the market
- combating the emergence of antimicrobial resistance due to the use of biocidal products
- reducing the risks associated with specific substances: endocrine disruptors and neonicotinoids
- protecting vulnerable groups
- monitoring of the biocidal products market (vendor to end user) and specific monitoring of hazardous products
- improving knowledge about exposure to and impact of biocidal products on health.
The last two objectives are aimed at increasing available knowledge so that the reduction plan can be properly substantiated and evaluated.
Structure of the reduction plan
The reduction plan includes six axes that directly or indirectly aim to reduce risks to health and the environment, which may involve a reduction in product use, especially for very specific uses of biocidal products.
The campaigns and training for professional users in the chapter Information and awareness are aimed at a safer use to reduce the risks of biocidal products. The considered use of biocidal products and the alternatives are also discussed.
Under the chapter Knowledge about exposure and impact on public health, information is gathered to determine the highest risks and the most vulnerable groups. This knowledge is used, for example, to guide the content of campaigns and to inform and raise awareness among the sectors involved.
The chapter on specific substances and uses seeks to reduce the risks and/or uses of biocidal products with a negative impact on health or the environment: products with endocrine-disrupting active substances, uses that pose a risk of developing antimicrobial resistance, and products with neonicotinoids.
The knowledge of the biocidal products market supports the other measures, for example through a more precise picture of the closed-circuit sectors, which comprise the more dangerous products (products that are toxic, corrosive, carcinogenic or harmful to reproduction).
The earlier introduction of the closed circuit can also be seen as a risk-reducing action: the products are mostly restricted to professional use, and there is often an obligation to wear personal protective equipment.
Market surveillance helps reduce risks, since non-compliant an potentially dangerous products are taken off the market. The goal is a Belgian market with only the authorised biocidal products, which are assessed for their safety before being placed on the market.
Periodic review and final reporting should ensure a reduction plan that remains feasible and leads to the desired results.
Implemention and follow-up
The working group on sustainable use, with representatives of the Regions and the Biocidal Products Service, ensures the follow-up of the plan.
Stakeholders are also consulted in the preparation, implementation and updating of the plan through an advisory group. Stakeholders include: the sectors of production of biocidal products, pest control and agriculture; environmental organisations; water quality companies and prevention advisors. The Biocidal Products Service aims to bring the relevant parties together at least once a year.
The reduction plan will be updated every 2.5 years, as foreseen in the Product Standards Act of 21 December 1998. After 5 years, the Biocidal Products Service will also present the final report to the working group on sustainable use and the stakeholders.
A subsequent reduction plan will be developed in the same way, with consultation with the public and advisory councils, an update after 2.5 years and a final report after 5 years.
The actions of the plan
The plan with the various actions and indicators is included in the Annex to the Royal Decree on the reduction plan (Dutch or French).
Information and awareness-raising
6 actions are aimed at informing the general public and professionals, and at training of the professionals. This includes active campaigns to raise awareness among the general public and professionals.
Professionals and interested parties should be able to rely on current and accurate information on biocidal products and regulations concerning biocidal products. This is mainly achieved through information provision on websites (Action 1.1 of the reduction plan):
- the web pages on biocidal products for the general public on the FPS portal, which explain what biocidal products are and what their risks are, and provide handy tips;
- this website biocide.be, with information for professionals;
- the helpdesk for professionals, with a knowledge base and a contact form;
- the search engine for authorised biocidal products (Belgian market).
The Biocidal Products Service also provides information on legislation and current issues through the annual forum for professionals (Action 1.3). The animal agriculture industry wants an up-to-date list of products effective against animal pathogens. The Biocidal Products Service provides this list to the Federal Agency for the Safety of the Food Chain for further distribution to the sectors concerned (Action 1.2).
Raising awareness among professional users is a key instrument to promote the safe and considered use of biocidal products (Action 1.4). Different forms are used, such as targeted campaigns through the sector organisations, supported by an FAQ (frequently asked questions and answers) section. The users of closed-circuit biocidal products are a specific target audience in this regard, for which targeted communications can be developed. One of the topics to be brought to attention is the risk of antimicrobial resistance.
Awareness-raising campaigns are also developed for the general public (Action 1.5). The long-running campaign https://lireavantutilisation.be/ (read before use) aims to promote safer use of chemical products through a campaign website, videos, brochures and educational materials for young people, an emoji game and a podcast. A specific campaign for safer use of biocidal products will also be launched. The web page for the general public supports this with information on the risks of biocidal products and good practices.
Action 1.6 provides mandatory training for professionals who work with rodent and insect control products and fumigation products. The training will cover health and environmental risks of the products, proper and safe use, as well as alternatives. New legislation will be drafted for this purpose, and an IT application will be created for the registration of professional training.
- Health effects: increasing knowledge and appropriate measures
Specific attention is accorded to the vulnerable groups, in the studies and in the communications (Action 2.1). In line with the federal government's intention to promote gender equality (federal plan for Gender mainstreaming), communication actions are also given a gender-specific slant where appropriate (Action 2.2). Gender is also among the factors considered in various studies, such as the follow-up of acute poisonings by the Poison Centre (Action 2.3).
Long-term exposure to biocidal products and its effects on health are also a point of interest. Therefore, Action 2.4 was added to the reduction plan to explore whether biomonitoring of biocidal active substances can be carried out. Such biomonitoring requires considerable time and resources, so the possibility of acquiring knowledge through existing European and regional chemical biomonitoring studies (PARC link https://www.eu-parc.eu/) is being explored.
The Poison Centre responds to and records the cases of acute poisonings by biocidal products (Action 2.3). The experts of the Poison Centre prepare a detailed report of the incidents (see annual reports on toxicovigilance in the publications section (studies). Among other things, these reports are used to (re)direct awareness campaigns, but they are also valuable in reflections on the safety of products and packaging.
Specific products and uses
Three actions focus on reducing known risks from specific product uses: the development of antimicrobial resistance as a result of the use of biocidal products (Action 3.1), endocrine disruptors (Action 3.2) and neonicotinoids (various insecticides) (Action 3.3).
Antimicrobial resistance (Action 3.1) is combatted in accordance with the national action plan on the fight against antimicrobial resistance (AMR). The Biocidal Products Service is working to raise awareness in the relevant sectors (see, for example, the literature review), and aims to develop guidelines for packaging and labelling of biocidal products in consultation with producers. Indeed, proper use and dosing are important to reduce the risk of emerging antimicrobial resistance.
The battle against endocrine disruptors is not limited to biocidal products or to national borders. Action 3.2 is therefore part of the National Action Plan on endocrine disruptors NAPED and the initiatives at the European level to identify and progressively remove the harmful substances from the market. The Biocidal Products Service contributes to the assessments of biocidal active substances with (suspected) endocrine-disrupting properties. Biocidal products containing endocrine disruptors are banned for the general public, and authorisations for professional use will be reviewed.
Neonicotinoids are a group of active substances belonging to the same chemical family, used in insect control. They are used in plant protection products in the agricultural sector (plant protection products) and in biocidal products (control of ants and cockroaches). The use of the plant protection products has been restricted at the European level because of risks to bees. Action 3.3 assesses the current risks of biocidal products containing neonicotinoids on the Belgian market, and whether additional measures are necessary for biocidal products. This action has a clear link to the national strategy to protect pollinators).
Monitoring of the biocidal products market
The FPS Health publishes data on the Belgian biocidal products market in the annual report (Action 4.1). The companies that hold the authorisations are obliged to declare the quantities of biocidal products they brought to market, every year. The data provide a view of which active substances and products are used, and how these figures evolve over time.
More detailed data are recorded for the closed-circuit biocidal products. In order to exploit these data on the closed circuit and for targeted communications, a new IT application is being developed (Action 4.2).
Surveillance of the market for biocidal products
Action 5.1 comprises the inspection of biocidal products and companies, which ensures better compliance with the rules, and reduces the risks of illegal products. In the process, non-compliant products are removed from the market.
Sometimes, the appropriate status of a product is not clear; the product is in a 'grey area' between medicine, medical device, biocidal product, or cosmetic product. An uncertain or erroneous status should not lead to the omission of the safety evaluation of products with biocidal activity. Action 5.2 therefore provides for the follow-up of products with a questionable status.
Plan update and final report
Every 2.5 years, the reduction plan is evaluated and adjusted, if necessary (Action 6.1). A final report will be prepared after 5 years (Action 6.2), which will also support the development of the next plan.
The table below shows other policies with links to (specific actions of) the reduction plan for biocidal products.
You can contact the Biocidal Products Service via email@example.com.