Interview: “’None of the usual active ingredients are likely to be ´deleted`
The uniform, EU-wide regulation of biocidal products is dragging on. Gabi Büttner, head of global chemicals management at the consultancy Umco, talks about the approval process and likely restrictions on active ingredients, especially for façade paints.
What is the current status of EU-wide regulation of biocides?Gabi Büttner: The question of an EU-wide regulation of biocides always goes hand in hand with the question of the status of the so-called “review program”, the review program of existing active substances. Uniform authorisation obligations for biocidal products under the Biocides Regulation only come into force once the used biocidal active substance has been approved – and the question of when all the active substances have been approved is the crucial question.
The review program is to be completed by 31 December 2024. As a reminder: started in 2004 (!), the program has already been extended for another ten years in 2014, until 2024, because the reviews by the authorities could not be completed in time. As of today, only about 440 of the nearly 780 existing active substances in their various product types have been evaluated in 16 years. This means that for 44 % of the active ingredients, a decision on approval or non-approval will have to be made in the next four years. Even without getting deeply into the matter, it is easy to calculate that 2024 – and thus a uniform regulation of biocidal products – will not be sustainable. However, this is not being discussed by legislators and authorities – not yet.——————————————————
—————————————————— What is the situation for film protection agents for façade paints in particular?Büttner: In order to keep façade paints attractive and free of algae or fungal stains for as long as possible, film protection agents are often used that are classified as product type 7. In this product type, the ECHA list of active substances contains 35 active substances, of which 20 are still in the approval process and 6 are approved. This means that most of the biocide products currently on the market that are used as film protection agents are not yet subject to the strict and expensive approval procedures according to the Biocidal Product Regulation. The transitional arrangements vary greatly from one Member State to another, and at least for Germany it can be said that – to put it mildly – they are very lax. I know that “35 active substances” sounds a lot in view of the constantly emerging discussion about the scarcity of active substances. It is important to note that most of the active ingredients are not suitable for façade paints for a variety of reasons. Essentially, there are eight active ingredients, and these have to be divided into the categories “algicide” and “fungicide” in terms of their spectrum of activity. A combination of at least one algicide and one fungicidal substance is always required. And that ultimately greatly limits the number of possible combinations of active ingredients. Incidentally, none of these eight active substances is currently approved.In your opinion, which active ingredients will be eliminated, which ones will remain?Büttner: None of the usual active ingredients will probably be “deleted”, but some of them will have to face restrictions in their use – especially when used in façade paints. This will be tantamount to a “ban” on their use.None of the active ingredients has a really harmless hazard profile, which is not surprising. Film protection agents do not throw absorbent cotton balls at algae or fungi. However, there are some particularly dubious properties that are viewed with suspicious eyes by legislators and authorities. The previous evaluation of active ingredients, especially of the related container preservatives in product type 6, has shown that authorities tend to take a hazard-based rather than a risk-based approach.Diuron, Isoproturon, Carbendazim and Terbutryn will presumably only be used to a limited extent (if at all), as they are problematic precisely because of their poor degradability and/or because of their carcinogenic, mutagenic or teratogenic hazard potential and become either substitution or exclusion candidates.Despite sensitising properties or high toxicity, it is likely that OIT, DCOIT, IBPC and zinc pyrithione will remain as active ingredients. However, it remains to be seen what conditions of use will be attached to these substances.
The review program is to be completed by 31 December 2024. As a reminder: started in 2004 (!), the program has already been extended for another ten years in 2014, until 2024, because the reviews by the authorities could not be completed in time. As of today, only about 440 of the nearly 780 existing active substances in their various product types have been evaluated in 16 years. This means that for 44 % of the active ingredients, a decision on approval or non-approval will have to be made in the next four years. Even without getting deeply into the matter, it is easy to calculate that 2024 – and thus a uniform regulation of biocidal products – will not be sustainable. However, this is not being discussed by legislators and authorities – not yet.At the European Coatings Webforum Preservation – with and without biocides Gabi Büttner will hold a lecture about preservatives in the crosshairs of regulation. The two day online-conference will take place at 28-29 April 2021.
What effects does this have on manufacturers of façade paints?
Büttner: Manufacturers of facade paints always use a combination of algicidal and fungicidal substances. OIT, DCOIT, IBPC and zinc pyrithione are good fungicides. All the substances just mentioned that are under discussion for exclusion or substitution are algicides. It can be assumed that the possibilities of suitable and effective combinations of both active ingredients in a façade paint will decrease significantly. In addition, it is to be firmly expected that there will be restrictions with regard to the circle of users or a tightening of the protective measures to be taken due to the hazard-based assessment of the active ingredients.Has the Corona pandemic already had an impact on the availability of biocides?
Büttner: Of course, there are still bottlenecks in the supply of raw materials due to Corona. This will not exclude manufacturers of façade paints. In addition, however, film protection agents are rather less subject to further peculiarities of the pandemic than the biocide group of disinfectants, for example.However, what will affect all active ingredients is that the existing active substances review program was certainly not accelerated, but rather slowed down due to the events and limitations of Corona.Do you believe that in the future, facade paints can be produced with biocide-free alternatives?
Büttner: Even now, encapsulation technology already reduces washout and environmental pollution, in the case of biocide-containing products. In contrast, water-repellent coatings and alkaline silicate paints or lime plasters are biocide-free alternatives. Whether these and similar biocide-free technologies are the future in the long term and across the board is difficult to judge, but a rethink is emerging, which has been accelerated in recent years due to increased environmental and sustainability considerations.
