Revision of GB Biocidal Products Regulation Annexes II and III 

Closed 14 Mar 2023

Opened 17 Jan 2023

Results updated 18 Mar 2024

This consultation is now closed. You can read the response report below.



Revision of GB Biocidal Products Regulation Annexes II and III

Purpose of this consultation

This consultation relates to the Great Britain Biocidal Products Regulation (GB BPR) (Regulation EU No 528/2012). GB BPR applies to the supply and use of biocidal products. Biocidal products are products that control harmful organisms, and include insecticides, rodenticides, wood preservatives, anti-fouling coatings on ships, disinfectants, and hand sanitisers. Biocides are essential to society to protect human health and infrastructure but can also cause risks to human and animal health and the environment if used incorrectly. GB BPR therefore aims to ensure a high level of protection for both human and animal health and the environment.

We are consulting on proposed revisions to Annexes II and III of GB BPR, which deal with the following:

Annex II – information requirements for biocidal active substances.  The Annex details the information that must be submitted by applicants who wish to apply for a biocidal active substance to be approved.

Annex III – information requirements for biocidal products.  This Annex details the information that must be submitted by applicants who wish to apply for biocidal products to be approved.

HSE is proposing to make technical updates to these Annexes which will:

  1. Introduce and place emphasis on In Vitro studies rather than In Vivo studies.
  2. Make new tests for endocrine disruptors part of the legal data requirements in GB BPR, rather than only being done on an ad hoc basis.
  3. Change mutagenicity requirements to reflect new information.
  4. Change requirements in relation to reproductive toxicity and generational studies.
  5. Change the requirements to include developmental neurotoxicity studies if certain triggers are met.
  6. Change the requirements to include efficacy data to support the innate activity of the active substance for the intended use.

These changes would enable:

  • A reduction in animal testing
  • Alignment with current guidance, and Organisation for Economic Co-operation and Development (OECD) validated tests
  • Keeping up with new developments and scientific progress

The proposed reduction in animal testing will not reduce the quality of testing or safety of products, as reliable non-animal-based tests are now available to provide information which was previously only available through testing using live animals.

The changes are similar to updates made recently to data requirements in the European Union’s Biocidal Products Regulation (EU) No 528/2012.  However, there are some minor differences which HSE believes will make the requirements more proportionate for GB needs.

Invitation to comment

HSE is seeking the views of interested parties on its proposed revisions to BPR Annexes II and III. HSE believes that effective consultation is one element in its open and transparent approach to decision-making. The responses to this consultation exercise will be considered by HSE before the proposals are finalised.

Please make sure you read all the accompanying consultation documents before completing the survey. You will find them in the Related section below. You may also need or wish to refer to the documents when completing your response.

The consultation is available online. Please use the link below in the box titled 'Submit your comments'. If possible, we would prefer to receive responses via the online survey, but if you would prefer to respond in writing please contact us using the details below to arrange.

HSE – BPR Annex II/III consultation
Biocides Policy Team
Health and Safety Executive
Redgrave Court
Merton Road
L20 7HS


We will fully acknowledge and consider all responses. We may contact you again if, for example, we have a query in respect of your response.

How to submit comments

Please submit your comments via the online survey below. A summary and analysis of responses will be published after the consultation has closed

The consultation lasts for 8 weeks (unless otherwise specified) and closes at 23:59 London time (BST).


  • Biocidal Products Regulations (BPR)


  • Biocides