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Biocides Directive update

Former BIE president Adrian Haler has been working closely with the NAFD on the impact of the Biocides Directive regarding the use of Formaldehyde for embalming and reports that it will be some time before the fate of Formaldehyde is determined.

Following the remittance of the filing fee for the Formaldehyde Dossier to the German authorities, there will now be continued examination of the Dossier, first by Germany and then by other EU states.  If Formaldehyde is placed on the Annex One List, manufacturers will have up to a further two years to register their products. 

Since there does not appear to be any protocol for testing Product Type 22 products, the UK funeral/embalming industry will need to research and propose an agreed method, after which companies will be able to approach other EU member states to make their products available in those countries.

It has become apparent that Paraformaldehyde and biocidal products containing it will not be covered by the present Dossier and it is unlikely this Active will remain on the market.

The Biocides Directive is currently being rewritten as it goes through the European Parliament and will then be repealed and replaced by a direct acting regulation, which is scheduled to be in place by 1 January 2013.  The advantage of this, is that EU member states will be obliged to accept the regulations as they stand, since they do not have to be transposed into national legislation, although with some 500 amendments already tabled it is difficult to forecast what changes will eventually take place.

“The task of defending Formaldehyde is far from over.  It seems that many of the people involved do not understand the implications of the wholesale banning of biocidal Actives and products, so it is important that we continue to lobby our MEPs because by this route we have a very real chance of influencing the outcomes,” says Mr Haler.


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