Implement BPR labelling for the EU

[dirk-qualisys]

Biocidal products have additional label requirements which are often reflected in Safety Data Sheets as well. These are:

• Biocide or Treated article?
• Composition information according to Biocidal Products Regulation
• Instructions for use, precautionary measures
• Registration numbers, both national an union wide, both old (biocides directive) and new (BPR)
• Main group
• Product type

Should this be part of SDSs and thus covered? How exactly? Are there additional phrases necessary?

[dirk-qualisys]

Comments from the eSDScom XML meeting, 25 Oct 2023:

• If treated articles should be covered requires discussion with experts.
• Main group and Product type are covered in eSDScom phrases (01.15.01.01.02.6000.).
• Additional labelling is substance (not product!) specific and determined by authorities (see 01.02.02.02.03.).
• ECHA guidance says that for detergents, the additional labelling should be included, so for biocides it should be too (-> to be double-checked).
• Other regions need coverage of their biocides/pesticides acts as well.

[dirk-qualisys]

Implementation:

Precautionary measures should be covered in the Instructions for Use. National registrations numbers, which are valid only until the EU wide authorization becomes mandatory, are not covered in a specific field since they are temporary. They can be covered in the composition information.