The Commission Implementing Regulation (EU) 2026/577 of 17 March 2026, published in the Official Journal of the European Union on 18 March 2026, approves the substance 2,2-dibromo-2-cyanoacetamide (DBNPA) as an existing active substance for use in biocidal products of product-type 11. This category covers critical applications in industrial environments, such as cooling systems, cooling towers and process water circuits. If your company manufactures, distributes or uses this type of biocide, this regulation directly affects you and it is important to understand its implications now.
What does this regulation establish?
Implementing Regulation 2026/577 is adopted under Regulation (EU) No 528/2012 of the European Parliament and of the Council, which governs the making available on the market and use of biocidal products in the European Union. Its objective is to establish a harmonised framework ensuring that active substances used in these products are safe and effective.
In this context, the European Commission has decided to approve DBNPA as an existing active substance for biocidal products classified as product-type 11. This category specifically includes:
- Industrial cooling systems
- Cooling towers
- Industrial process water circuits
The approval of an active substance does not mean that all products containing it may be placed on the market automatically. On the contrary, it means that manufacturers must follow a formal authorisation process for each biocidal product incorporating DBNPA, in accordance with the procedures laid down in Regulation (EU) 528/2012.
Who is affected and how?
This regulation has a direct impact on two main groups of companies and professionals:
1. Manufacturers and distributors of biocides containing DBNPA
If your company produces or markets biocidal products containing DBNPA for use in cooling systems or industrial water circuits, you must verify the authorisation status of your products. The approval of the active substance opens the door to applying for or updating such authorisations with the competent authorities, but it also means that products lacking the corresponding authorisation may be withdrawn from the market.
2. Companies using industrial cooling systems
Companies operating installations with cooling towers, industrial cooling systems or process water circuits that use biocides for maintenance purposes must ensure that the products they use are duly authorised in accordance with this new approval. It is not sufficient for the active substance to be approved; the specific biocidal product must hold its own valid authorisation.
Failure to comply with these obligations may result, according to the regulation, in the withdrawal from the market of unauthorised products and the imposition of administrative penalties. For the exact details of the applicable consequences, it is recommended to consult the original regulation.
What should you do to comply?
Below are the most relevant action steps arising from this regulation:
- Identify whether your company manufactures, distributes or uses biocides containing DBNPA intended for cooling systems or industrial process water circuits.
- Review the authorisation status of your biocidal products with the competent authorities. Approval of the active substance is not equivalent to authorisation of the final product.
- Apply for or update product authorisations if you are a manufacturer or distributor, following the procedures established in Regulation (EU) 528/2012.
- Verify that the biocides you use in your facilities are properly authorised under this new approval, especially if you manage cooling towers or industrial water systems.
- Consult a specialist in biocide regulations or the competent authorities in your region to find out the specific deadlines and requirements applicable to your situation.
- Stay informed about potential national regulatory developments that may arise from this European approval, as Member States will be required to apply this regulation within their territory.
Since the regulation entered into force on 17 March 2026, it is important to act promptly to avoid non-compliance situations that could lead to administrative consequences or the inability to market or use certain products.
Official source
You can consult the full text of Commission Implementing Regulation (EU) 2026/577 in the Official Journal of the European Union via the following link: View full regulation at the official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For decisions specific to your situation, please consult a qualified professional. Original source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202600577
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