Biocides and REACH Regulatory overview: September 2026

Dive into our team’s expertise on the Biocides and REACH markets.

Once a month, our experts will gather all the news and updates in Biocides and REACH markets. They will select major news to help you navigate in the regulations framework.

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BIOCIDES

1- Latest Consolidated Version of the Biocidal Products Regulation (BPR)

On August 19, 2026, the European Commission released an updated consolidated text of Regulation (EU) No 528/2012, incorporating at Article 95(5) and Annex I the latest changes under Regulations (EU) 2026/1165 and (EU) 2026/447.

Key takeaways for industry stakeholders include:

Extended Data Protection (Regulation 2026/1165)

  • Extended Deadlines: For active substance/product-type combinations currently in the review programme, data protection periods are now extended until December 31, 2030.
  • Operational Impact: This adjustment strengthens data exclusivity for existing substances. Practically, it may delay the free re-use of study data by alternative suppliers and increase data-sharing cost exposure for companies relying on third-party dossiers. It is time to re-evaluate your data rights, Letters of Access (LoA), and Article 95 supplier strategies.
  • Data Compensation: Data owners are now permitted to claim compensation for access to their data during the “gap” period of January 1 to June 15, 2026, from suppliers who benefited from the temporary absence of protection.

Revised Conditions for Carbon Dioxide (Annex I, Category 6)

  • New Exposure-Based Approach: Delegated Regulation (EU) 2026/447 updates Annex I, Category 6. The previous, narrower restrictions for carbon dioxide (EC 204-696-9) have been replaced with exposure-based conditions that now apply at the product authorisation level.

If you are affected by these updates, feel free to contact our team Aviron-Violet Sophie, Hélène Detrimont, Benjamin Heal and we’ll get back to you!

#BPR #Article95 #DataProtection #CO2 #ECHA

2- Key Agreements & Discussion Points from CG-71

  • Interpretation and possible amendment of PT8 Risk Mitigation Measures (Top Coats): Addressed ambiguous wording (“cannot contain a film or wood preservative”) that risks banning non-biocidal top coats treated with preservatives. Denmark proposed clarifications to focus restrictions on multiple biocidal products. CG-71 agreed to update standard references to EN 927-1, but core wording is referred to the Environment (ENV) Working Group for further review.
  • Harmonized Approach for products containing Active Chlorine Generated from KMPS + NaCl: Reached a consensus framework for products containing KMPS and NaCl that generate unapproved active chlorine when mixed with water:

For further advice from Staphyt’s experts on how these points could affect your products in the future.

#BPR #RMM #ECHA #TopCoat #ActiveChlorineGeneration


REACH

1- ECHA receives notice to inform on the update of the European Categorisation System (EuPCS) to support PCN

The request asks for ECHA to prepare an update of the EuPCS as referred to in Annex VIII (Part A, Section 3.4) of the CLP regulation. This update is considered necessary to support stakeholders and Member State appointed bodies when submitting Poison Centre Notifications (PCN)  in accordance with Article 45 of the CLP.

The EuPCS is a system which describes the main intended uses of products/mixtures under Annex VIII and is embedded in both REACH IT and IUCLID to assist with preparation and submission of notifications. It can also be used to support member states with statistical analysis. This update would see the inclusion of “PC-NDP-1” which covers Nicotine and Nicotine analogue delivery products (such as pouches, pods, patches and toothpicks).

The agreed changes to the EuPCS entries would be available on ECHA’s poison centre website by December 2026 and technically implemented in the next scheduled notification format update (April 2027)

2- EU Publishes an update to its REACH Restrictions Roadmap

The updated 2026 roadmap makes clear which measures have already been adopted, which cases are nearing a decision and which dossiers are currently under review with a risk of potential future restrictions. This roadmap does not create any new legal obligations itself, there is no new work generated for companies with substances listed on the roadmap.

Instead companies should consider it an early warning system to help with identifying future risks to their portfolio and which substances may require tighter controls and measures. Where possible companies should review their inventories and consider alternatives to substances present on the road map and how it might impact their business should the need to change to these alternatives arise.

Contact our team to discuss your projects: Elena Campagnoli George Leathley Benjamin Heal


CROSS DISCIPLINE

DWD

ECHA updates Guidance documents in preparation for Drinking Water Directive submission period

ECHA has updated their guidance documents to help companies prepare notifications and applications under the Drinking Water Directive ahead of the January 2027 submission period.

Key changes include updates to Volume 1 (which covers Guidance on testing starting substances, compositions and constituents) and Volume 2 (which covers Guidance on accepting starting substances, compositions and constituents).

As a reminder, 2026 Drinking Water Directive Stakeholders’ Workshop organised by ECHA will take place on 21-22 October 2026 in hybrid format.

PPWR

UK updates guidance on Extended Producer Responsibility (EPR) compliance

DEFRA has updated its guidance on complying with EPR for packaging and waste regulations. The guidance now confirms that packaging data must be reported every 6 months for large producers and annually for small producers.

This step now aligns with the EU’s guidance on EPR reporting, creating closer alignment between the two regulations. Large companies based in the UK should take steps to ensure they are prepared to submit data within the new shorter deadline.

ECHA QSAR Toolbox Upgrade

Co-developed by ECHA and the OECD, QSAR Toolbox helps you carry out chemical hazard assessments and reduce the need for animal testing.

  • Enhanced Hazard Assessments: The July release of the QSAR Toolbox expands non-animal testing capabilities for chemical hazard evaluations.
  • What’s New: Features updated prediction tools, expanded databases, enhanced metabolism capabilities, and additional standardized workflows.

Staphyt offers QSAR testing services for all hazard prediction scenarios – please get in touch for a discussion Aviron-Violet Sophie, Hélène Detrimont, Benjamin Heal.

#BPR #QSAR #ECHA #OECD


Next events

  • Congrès Biocides – Lyon: Our team will be there presenting a conference “Risk Assessment in the MA dossier: Feedback from various Member States” (Evaluation du risque dans le dossier AMM : Retour d’expérience des différents Etats-Membre).
  • CIR Barcelona: Our experts Asha Hoque and Benjamin Heal will attend. Contact them to plan a meeting

Whether you need assistance about compliance, product registration or any other regulatory issue, our experts are here to provide support: Aviron-Violet Sophie, Elena Campagnoli, Benjamin Heal, Mélanie JEAN-JEAN Hélène Detrimont, George Leathley

Contact us contact@staphyt.com or visit our website : staphyt.com

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