The competent authority has recently published a note (CA-March25-Doc.4.9) aimed at clarifying the application of Article 19(4) of the BPR to products classified as endocrine disruptors (ED) Category 1 and Category 2.
According to Article 19(4), biocidal products with ED properties shall not be authorised for use by the general public. However, the note specifies that a product is considered as having endocrine disrupting properties when it contains a substance that meets the criteria set out in Delegated Regulation (EU) 2017/2100 and is above the concentration limits established by the CLP Regulation for known or presumed EDs.
In practise, the regulatory consequences of Article 19(4) apply only to products classified as ED Category 1 (known or presumed), while Category 2 (suspected ED) are excluded.
This interpretation is in line with other regulatory provisions under the BPR, such as those concerning CMR properties, which apply only to Category 1A and 1B.
