CO₂ as biocide: new EU restrictions for pest control companies and manufacturers

Key data

If your company manufactures, distributes or uses biocidal products containing carbon dioxide for rodent control or other vertebrate control, this regulation affects you directly. The Commission Delegated Regulation (EU) 2026/447, published on 30 July 2026, amends Regulation (EU) No 528/2012 and introduces specific restrictions on how CO₂ can be used in category 6 of its Annex I.

This is not a total ban: CO₂ remains a permitted active substance, but its use is conditional on compliance with new conditions approved at European level. Anyone who fails to adapt their products and procedures risks losing marketing authorization in EU markets.

What does this regulation establish?

Regulation 528/2012 regulates the marketing and use of biocidal products in the European Union. Its Annex I lists active substances of low risk or suitable for simplified inclusion. Category 6 of that Annex covers products for vertebrate control, including rodenticides and other biocides targeting mammals considered pests.

Delegated Regulation 2026/447 introduces a specific restriction on the use of CO₂ in that category. In practice, this means:

• Products containing CO₂ for vertebrate control must comply with new conditions of use approved at European level.
• Existing product authorizations must be reviewed and adapted to reflect those conditions.
• The measure responds to risk assessments on the safe and effective use of CO₂ in this specific context.

Economic and operational impact

The main impact is not a direct economic penalty, but a risk of loss of market access. For companies in the sector, this translates into concrete operational and administrative costs:

• Biocide manufacturers and distributors: will incur costs for legal and technical review of their product authorization files, as well as possible reformulations or changes in declared conditions of use.
• Pest control companies: must audit their operational protocols to verify that CO₂ methods they apply are covered by current authorizations and compliant with the new conditions.
• Risk of business interruption: if a product authorization is not adapted in time, the product cannot be marketed or legally used in EU Member States, with the resulting impact on revenue and service contracts.

The cost of inaction—losing a marketing authorization—far exceeds the cost of proactive adaptation. Companies operating in multiple Member States must also coordinate the review with the competent authorities of each country.

Who does it affect?

• Manufacturers of biocidal products containing CO₂ as an active substance for vertebrate control (rodents and other mammal pests).
• Distributors and marketers of these products in the European market.
• Pest control companies (rodent control, urban wildlife control) that use CO₂ as a method for eliminating vertebrates.
• Competent authorities of EU Member States, responsible for managing and updating biocide marketing authorizations in their territories.

Practical example

A Spanish pest control company that provides rodent control services in food facilities uses CO₂ equipment for rodent elimination. Until now, it operated under a current product authorization in accordance with Regulation 528/2012.

With the entry into force of Regulation 2026/447, the manufacturer of the biocidal product with CO₂ used by that company must review its authorization and adapt it to the new conditions of use approved at European level. If the manufacturer does not do so, the authorization may be withdrawn by the competent authority of the Member State.

In that scenario, the pest control company could not continue using that product legally, which would force it to seek an alternative product with current authorization or wait for the manufacturer to complete the adaptation. This can directly affect ongoing service contracts and operational continuity.

Recommended preventive action: contact the manufacturer or distributor of the product now to confirm the status of its authorization and the adaptation timeline.

What should companies do now?

1. Identify if you use or market biocidal products with CO₂ for vertebrate control. If so, this regulation affects you directly and you must act.
2. Review current product authorizations. Manufacturers and distributors must check whether their current authorizations comply with the new conditions of use established in Regulation 2026/447.
3. Adapt authorization files. If current conditions are not compliant, initiate the modification process with the competent authority of the corresponding Member State.
4. Verify operational protocols. Pest control companies must audit their CO₂ procedures and confirm that the products they use have current authorization adapted to the new requirements.
5. Coordinate with suppliers. If you are an end user (pest control company), contact your biocide supplier to learn about the status of their authorizations and adaptation timeline.
6. Consult competent authorities. In Spain, the competent authority on biocides is the Ministry for Ecological Transition and Demographic Challenge. If you have doubts about the status of a specific authorization, contact them directly.

Official source

View complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202600447