The difference between a biocidal product and a treated article lies in the purpose and function of the product.

A biocidal product is defined as:

• a substance or mixture;
• consisting of, containing or generating one or more active substances or generated from precursors which themselves are not considered as active substances;
• with the intention of destroying, deterring, rendering harmless, preventing the action of, or otherwise exerting a controlling effect on, any harmful organism by any means other than mere physical or mechanical action.

Treated articles are defined as:

• substances, mixtures or articles;
• which have been treated with, or intentionally incorporate, one or more biocidal products.

Articles with a primary biocidal function are not considered as treated articles, but rather as biocidal products. Since 1 March 2017 articles may only be treated with active substances which were previously approved.

As a manufacturers or importer of treated articles, you must label your products in accordance to CLP. You must additionally label your treated articles in accordance to the BPR if this is required in the conditions of active substance approval or if you make a claim that the treated article has biocidal properties. Further, if a consumer requests information about the biocidal treatment of your article, you must provide this free of charge within 45 days.

The Chemical Compliance Coach can assist you in checking whether your treated articles are BPR-compliant. Further, we offer assistance in CLP and BPR product labelling and the authoring of product SDSs.