End of the derogatory order for hydralcoholic gels

From the 1st of April 2021, hydroalcoholic gels and products will have to comply with the biocide regulation, as the derogation regulation under the decree of March the 13th of 2020 will end on March the 31st of 2021. Non-compliant products will have to be withdrawn from the market.

The deadline for disposing of inventories initially scheduled for December the 31st 2020 has been postponed (see the decree of September the 8th of 2020 and we have updated our article by adapting the information).

You produce hydroalcoholic gels and products under the derogatory regulation?

Please note that a transition phase has been put in place from October the 1st 2020 to March the 31st 2021 to allow you to gradually bring yourself back into conformity with the regime provided for by the biocide regulation (EU) n°528/2012 and national regulations and thus avoid the withdrawal of your gels from the market. From October the 1st 2020 all GHA and PHA must be declared (SIMMBAD and SYNAPSE) before selling or if remaining on the market.

To anticipate the necessary changes, here are the measures to be taken: 

  1. Declare the placing on the market of your product: 
  1. Declare the composition of your product to the Poison Control Centre on SYNAPSE
  2. Adapt the labelling of your product : 
  • In accordance with the derogation regulation of March the 13th of 2020 for hydroalcoholic gels and products manufactured before October the 1st 2020
  • According to the Biocidal Regulation (EU) No 528/2012 (Article 69) for hydroalcoholic gels and products manufactured after October the 1st 2020 

To help you in the compliance of your products, we offer you our analytical services for the verification of the alcohol content of your hydroalcoholic products but also their bactericidal and fungicidal effectiveness. If you wish, we can evaluate the virucidal efficiency through one of our partners.