Type 19 Biocides with cis-Tricos-9-ene: What Manufacturers and Distributors Must Do Now

Key data

If your company manufactures, distributes or professionally uses type 19 biocidal products containing cis-tricos-9-ene as an active substance, this decision directly affects you. Implementing Decision (EU) 2026/2252, published on 13 October 2026, repeals Decision 2024/1283, which had granted an extension to the expiry date of the approval of this substance. By removing that extension, the clock starts running again from the original expiry date.

The framework that regulates all this is Regulation (EU) No 528/2012, which establishes the conditions for approval of active substances in biocides throughout the European Union. When a substance loses its approval, products containing it no longer have regulatory coverage and cannot be legally marketed.

What does this regulation establish?

Decision 2026/2252 has a concrete and direct effect: it eliminates the extension that Decision 2024/1283 had granted to the approval of cis-tricos-9-ene for use in type 19 product biocides.

To understand the scope, it is useful to know what each element is:

• Cis-tricos-9-ene: active substance used as a repellent and insecticide in biocidal products not intended for direct human use.
• Product type 19: category under Regulation (EU) 528/2012 that groups repellents and insecticides that are not applied directly to people (for example, products to protect materials, spaces or animals).
• Decision 2024/1283: regulation that had delayed the expiry date of approval, giving the sector more time to adapt or renew authorization.

Economic and operational impact

The repeal of an active substance approval extension is not a minor formality. For companies in the sector, it implies direct operational and economic consequences:

• Product reformulation: manufacturers using cis-tricos-9-ene as an active substance in type 19 biocides will need to assess whether to reformulate their products with an approved alternative substance, which entails R&D costs, new tests and new authorizations.
• Product withdrawal from the market: if the product authorization is no longer supported by an approved active substance, the product cannot be marketed. Withdrawal involves logistical costs and possible stock losses.
• Authorization review: distributors must verify that the products they have in their catalog or warehouse have valid authorizations under the new regulatory situation.
• Professional users: those who use these biocides in the exercise of their activity (pest control companies, facility managers, livestock sector, etc.) must confirm that the products they use remain legal.

Who does it affect?

• Type 19 biocide manufacturers that include cis-tricos-9-ene as an active substance in their formulations.
• Distributors and marketers of these products in any EU Member State.
• Professional users of type 19 biocides: pest control companies, livestock farms, industrial or agricultural facility managers, among others.
• Regulatory compliance and regulatory affairs managers in chemical sector companies and crop or material protection.
• Legal advisors and consultants serving companies in the biocides sector in the EU.

Practical example

A Spanish company manufacturing insect repellents for use in livestock facilities (type 19 biocide) had planned its regulatory roadmap counting on the extension granted by Decision 2024/1283. That extension gave it time to complete the process of renewing the approval of cis-tricos-9-ene or to reformulate its product.

With the entry into force of Decision 2026/2252, that extension disappears. The company must now:

1. Verify what is the original expiry date of the approval of cis-tricos-9-ene under Regulation (EU) 528/2012.
2. Assess whether its authorized products can still be marketed or whether they must be withdrawn from the market.
3. Decide between initiating a reformulation process (with a new approved active substance) or ceasing the marketing of the affected products.

The same applies to its distributors, who must review warehouse stock and the validity of authorizations for products in their portfolio.

What should companies do now?

1. Identify affected products: review your own catalog and determine which type 19 biocidal products contain cis-tricos-9-ene as an active substance.
2. Verify the original expiry date: consult the expiry date of the approval of cis-tricos-9-ene foreseen in Regulation (EU) 528/2012, without counting on the extension already repealed.
3. Review product authorizations: check whether the national authorizations of the affected products remain valid or whether they are left without regulatory coverage.
4. Evaluate options: reformulation or withdrawal: decide whether to initiate a reformulation process with an approved alternative active substance, or whether to proceed with the withdrawal of the product from the market.
5. Communicate to the distribution chain: inform distributors and professional customers about the regulatory situation of the affected products to prevent illegal marketing.
6. Consult with the competent authority: in Spain, the Ministry for Ecological Transition manages biocide authorizations. Contact them to obtain guidance on applicable timelines and procedures.

Official source

Consult full 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_202602252