The marketing and use of biocidal products and treated articles within the European automotive industry are covered by the Biocidal Products Regulation (BPR). It is vital for BPR compliance that the whole supply chain first identifies the applicable obligations, and then communicates relevant information along the chain.
The BPR (Regulation (EU) No 528/2012) came into force in the EU in 2013, and is managed by the European Chemical Agency (ECHA). The BPR sets rules in the EU for approval of active substances (ASs), authorisation of biocidal products (BPs), and placing treated articles (TAs) on the market, and has applied since 1 September 2013. The BPR replaces the previous Biocidal Products Directive (BPD), and includes transitional measures to enable continued supply.
As the automotive industry is made up of vehicle manufacturers and many tiers of the supply chain, it has several roles under BPR which are all linked to different obligations. The biggest impact of the BPR on automotive OEMs and higher tier suppliers is likely to be a result of the new requirements for TAs, which are those substances, mixtures or articles that are treated with, or that intentionally incorporate, BPs (for example paint treated with an in-can preservative, or an anti-bacterial seat cover). TAs are allowed on the market only if all the ASs concerned are approved for the relevant product-type, and if the BPR labelling requirements are met.
It is essential for compliance that information on biocides is passed between all levels of the supply chain, in order to confirm the identity of biocidal products and treated articles, product- types, transition status, substitution plans, labelling, etc.
- Automotive Task Force on Biocides
Leading automotive suppliers and vehicle manufacturers have together formed the Task Force – Biocides, in order to respond collectively to the challenges, set by the BPR. The Task Force represents the position of the global automotive industry. Automotive suppliers and vehicle manufacturers are encouraged to send any examples of automotive BPs and TAs to your relevant trade association, or to firstname.lastname@example.org.
- Automotive Industry Guideline (AIG)
The Task Force has created the AIG-BPR as a standardised approach to BPR compliance. It is a practical guide that includes clear step-by-step compliance actions. The AIG is highly recommended; it is easy to follow and brings clear benefits when implemented across industry. AIG-BPR version 1.0 was released in September 2016.