Renewal of active substances under GB BPR: a major regulatory challenge for the UK market
Since the United Kingdom left the European Union, biocidal products placed on the market in Great Britain (England, Scotland and Wales) are regulated under the GB Biocidal Products Regulation (GB BPR). Although largely aligned with the EU BPR, GB BPR now operates as an independent regulatory framework, with its own timelines, procedures and legal implications.
One of the most critical aspects of GB BPR concerns the renewal of active substances. Any active substance approved under GB BPR will automatically lose its approval if a renewal application is not submitted no later than 550 days before the approval expiry date.
Several major renewal deadlines under GB BPR are approaching as early as 2026 and 2027. Companies concerned must anticipate these timelines in order to avoid market disruptions, withdrawal of biocidal products, or bans on placing treated articles on the GB market.
Understanding the renewal of active substances under GB BPR
What is an active substance renewal under GB BPR?
Under GB BPR, active substances are approved for a limited period of time and only for specific Product Types (PTs). Before the approval expires, a renewal application must be submitted to the UK competent authority, the Health and Safety Executive (HSE).
A renewal dossier typically includes:
- updated technical and scientific data,
- risk assessments for human health, animal health and the environment,
- consideration of new toxicological or ecotoxicological knowledge,
- confirmation of compliance with current GB BPR requirements.
The 550-day deadline is mandatory, with no flexibility. Any late submission automatically results in the expiry of the active substance approval.
Who can support the renewal of an active substance under GB BPR?
Contrary to common assumptions, renewal of an active substance under GB BPR is not limited to the original approval holder. Any person, company, task force or consortium may support an active substance/product type combination, provided they have access rights to the required data.
Existing supporters can be identified via the GB Article 95 list, which specifies recognised active substance suppliers and dossier holders accepted by the UK authority.
2026 deadlines: first critical renewal dates under GB BPR
Deadline of 29 March 2026
The first GB BPR renewal deadlines notably concern peracetic acid:
- Peracetic acid (CAS 79-21-0, EC 201-186-8)
Product Types: PT 1, 2, 3, 4, 5 and 6
This substance is widely used for disinfection, human, veterinary and industrial hygiene, and is strategic for many sectors, including food processing and healthcare.
Deadline of 29 June 2026: a broad portfolio of substances concerned
The 29 June 2026 deadline represents a major milestone under GB BPR, covering several key active substances:
- DBDCB – 2-bromo-2-(bromomethyl)pentanedinitrile
(CAS 35691-65-7, EC 252-681-0) – PT 6
- OIT – 2-octyl-2H-isothiazol-3-one
(CAS 26530-20-1, EC 247-761-7) – PT 8
- Ampholyt 20 (amines, N-C10-16-alkyltrimethylenedi-, reaction products with chloroacetic acid)
(CAS 139734-65-9, EC 701-317-3) – PT 2, 3 and 4
- Bacillus amyloliquefaciens strain ISB06
(CAS N/A, EC N/A) – PT 3
- Biphenyl-2-ol
(CAS 90-43-7, EC 201-993-5) – PT 3
- Cyromazine
(CAS 66215-27-8, EC 266-257-8) – PT 18
- Bardap 26
(CAS 94667-33-1, EC 619-057-3) – PT 8
- Tolylfluanid
(CAS 731-27-1, EC 211-986-9) – PT 7
These substances are essential for sectors such as paints and coatings, construction materials, disinfectants, wood preservation and pest control.
December 2026 deadlines: additional GB BPR renewal obligations
Deadline of 28 December 2026
By the end of 2026, additional strategic substances will require renewal under GB BPR:
- Piperonyl butoxide (PBO)
(CAS 51-03-6, EC 200-076-7) – PT 18
- MBIT – 2-methyl-1,2-benzothiazol-3(2H)-one
(CAS 2527-66-4, EC 695-989-4) – PT 6
- Peracetic acid
(CAS 79-21-0, EC 201-186-8) – PT 11 and 12
These deadlines mainly affect insecticides, preservatives and industrial fluid protection products.
2027 deadlines: anticipating active substance renewals under GB BPR
Deadline of 30 June 2027
Several major substances will reach their renewal deadlines in 2027:
- MIT – 2-methyl-2H-isothiazol-3-one
(CAS 2682-20-4, EC 220-239-6) – PT 11
- Active chlorine released from calcium hypochlorite
(CAS 7778-54-3, EC 231-908-7) – PT 2, 3, 4 and 5
- Active chlorine released from chlorine
(CAS 7782-50-5, EC 231-959-5) – PT 2 and 5
- Active chlorine released from sodium hypochlorite
(CAS 7681-52-9, EC 231-668-3) – PT 1, 2, 3, 4 and 5
- Peracetic acid generated from TAED and sodium percarbonate
(CAS 79-21-0, EC N/A) – PT 2, 3 and 4
These substances are central to disinfection strategies in the water, healthcare and public hygiene sectors.
Consequences of non-renewal under GB BPR
Impact on biocidal products and treated articles
If no renewal application is submitted within the required timeframe:
- the approval of the active substance automatically expires;
- affected biocidal products can no longer be placed on the GB market;
- treated articles containing these products can no longer be marketed in Great Britain.
The economic and operational consequences can be significant, particularly for international supply chains.
Best practices to anticipate active substance renewals under GB BPR
Companies concerned should already:
- identify critical active substances in their GB portfolio,
- verify existing supporters via the GB Article 95 list,
- engage with suppliers or data owners,
- consider joining or forming a renewal consortium,
- plan the required costs, timelines and internal resources.
Conclusion: active substance renewal under GB BPR as a strategic priority
Renewal of active substances under GB BPR represents a major regulatory and strategic challenge for any company active on the UK biocides market. With key deadlines in 2026 and 2027 approaching rapidly, early anticipation is essential to secure continued market access.
Proactive action today helps prevent regulatory and commercial disruptions tomorrow.
EcoMundo offers support on this topic. Contact us to discuss your situation or explore our Biocides services.
Renewal of active substances under GB BPR: a major regulatory challenge for the UK market
Since the United Kingdom left the European Union, biocidal products placed on the market in Great Britain (England, Scotland and Wales) are regulated under the GB Biocidal Products Regulation (GB BPR). Although largely aligned with the EU BPR, GB BPR now operates as an independent regulatory framework, with its own timelines, procedures and legal implications.
One of the most critical aspects of GB BPR concerns the renewal of active substances. Any active substance approved under GB BPR will automatically lose its approval if a renewal application is not submitted no later than 550 days before the approval expiry date.
Several major renewal deadlines under GB BPR are approaching as early as 2026 and 2027. Companies concerned must anticipate these timelines in order to avoid market disruptions, withdrawal of biocidal products, or bans on placing treated articles on the GB market.
Understanding the renewal of active substances under GB BPR
What is an active substance renewal under GB BPR?
Under GB BPR, active substances are approved for a limited period of time and only for specific Product Types (PTs). Before the approval expires, a renewal application must be submitted to the UK competent authority, the Health and Safety Executive (HSE).
A renewal dossier typically includes:
- updated technical and scientific data,
- risk assessments for human health, animal health and the environment,
- consideration of new toxicological or ecotoxicological knowledge,
- confirmation of compliance with current GB BPR requirements.
The 550-day deadline is mandatory, with no flexibility. Any late submission automatically results in the expiry of the active substance approval.
Who can support the renewal of an active substance under GB BPR?
Contrary to common assumptions, renewal of an active substance under GB BPR is not limited to the original approval holder. Any person, company, task force or consortium may support an active substance/product type combination, provided they have access rights to the required data.
Existing supporters can be identified via the GB Article 95 list, which specifies recognised active substance suppliers and dossier holders accepted by the UK authority.
2026 deadlines: first critical renewal dates under GB BPR
Deadline of 29 March 2026
The first GB BPR renewal deadlines notably concern peracetic acid:
- Peracetic acid (CAS 79-21-0, EC 201-186-8)
Product Types: PT 1, 2, 3, 4, 5 and 6
This substance is widely used for disinfection, human, veterinary and industrial hygiene, and is strategic for many sectors, including food processing and healthcare.
Deadline of 29 June 2026: a broad portfolio of substances concerned
The 29 June 2026 deadline represents a major milestone under GB BPR, covering several key active substances:
- DBDCB – 2-bromo-2-(bromomethyl)pentanedinitrile
(CAS 35691-65-7, EC 252-681-0) – PT 6
- OIT – 2-octyl-2H-isothiazol-3-one
(CAS 26530-20-1, EC 247-761-7) – PT 8
- Ampholyt 20 (amines, N-C10-16-alkyltrimethylenedi-, reaction products with chloroacetic acid)
(CAS 139734-65-9, EC 701-317-3) – PT 2, 3 and 4
- Bacillus amyloliquefaciens strain ISB06
(CAS N/A, EC N/A) – PT 3
- Biphenyl-2-ol
(CAS 90-43-7, EC 201-993-5) – PT 3
- Cyromazine
(CAS 66215-27-8, EC 266-257-8) – PT 18
- Bardap 26
(CAS 94667-33-1, EC 619-057-3) – PT 8
- Tolylfluanid
(CAS 731-27-1, EC 211-986-9) – PT 7
These substances are essential for sectors such as paints and coatings, construction materials, disinfectants, wood preservation and pest control.
December 2026 deadlines: additional GB BPR renewal obligations
Deadline of 28 December 2026
By the end of 2026, additional strategic substances will require renewal under GB BPR:
- Piperonyl butoxide (PBO)
(CAS 51-03-6, EC 200-076-7) – PT 18
- MBIT – 2-methyl-1,2-benzothiazol-3(2H)-one
(CAS 2527-66-4, EC 695-989-4) – PT 6
- Peracetic acid
(CAS 79-21-0, EC 201-186-8) – PT 11 and 12
These deadlines mainly affect insecticides, preservatives and industrial fluid protection products.
2027 deadlines: anticipating active substance renewals under GB BPR
Deadline of 30 June 2027
Several major substances will reach their renewal deadlines in 2027:
- MIT – 2-methyl-2H-isothiazol-3-one
(CAS 2682-20-4, EC 220-239-6) – PT 11
- Active chlorine released from calcium hypochlorite
(CAS 7778-54-3, EC 231-908-7) – PT 2, 3, 4 and 5
- Active chlorine released from chlorine
(CAS 7782-50-5, EC 231-959-5) – PT 2 and 5
- Active chlorine released from sodium hypochlorite
(CAS 7681-52-9, EC 231-668-3) – PT 1, 2, 3, 4 and 5
- Peracetic acid generated from TAED and sodium percarbonate
(CAS 79-21-0, EC N/A) – PT 2, 3 and 4
These substances are central to disinfection strategies in the water, healthcare and public hygiene sectors.
Consequences of non-renewal under GB BPR
Impact on biocidal products and treated articles
If no renewal application is submitted within the required timeframe:
- the approval of the active substance automatically expires;
- affected biocidal products can no longer be placed on the GB market;
- treated articles containing these products can no longer be marketed in Great Britain.
The economic and operational consequences can be significant, particularly for international supply chains.
Best practices to anticipate active substance renewals under GB BPR
Companies concerned should already:
- identify critical active substances in their GB portfolio,
- verify existing supporters via the GB Article 95 list,
- engage with suppliers or data owners,
- consider joining or forming a renewal consortium,
- plan the required costs, timelines and internal resources.
Conclusion: active substance renewal under GB BPR as a strategic priority
Renewal of active substances under GB BPR represents a major regulatory and strategic challenge for any company active on the UK biocides market. With key deadlines in 2026 and 2027 approaching rapidly, early anticipation is essential to secure continued market access.
Proactive action today helps prevent regulatory and commercial disruptions tomorrow.
EcoMundo offers support on this topic. Contact us to discuss your situation or explore our Biocides services.
