BPR Compliant Disinfectant
A practical guide to the Great Britain Biocidal Products Regulation - including product authorisation, lawful transitional supply, product types and the evidence buyers should check.
The GB Biocidal Products Regulation (GB BPR) governs the sale, supply and use of biocidal products in Great Britain. A disinfectant must be lawful for its intended use: it may hold a GB product authorisation, or it may be lawfully supplied under applicable transitional arrangements while the relevant active-substance or precursor-route and product-type combination remains in the GB Review Programme. Not every lawful product therefore has an authorisation number or appears on the authorised-products list. This guide explains both routes, the relevant product types, and how duty holders can verify the evidence without confusing Article 95 supply-chain listing with product authorisation.
What Is the Biocidal Products Regulation (BPR)?
The Biocidal Products Regulation - originally EU Regulation 528/2012 and retained in UK law as the GB BPR following Brexit - establishes the rules for placing biocidal products on the market in Great Britain. The regulation is administered by the Health and Safety Executive (HSE) in England, Scotland, and Wales, with separate arrangements in Northern Ireland under the EU BPR.
GB BPR establishes product authorisation as the normal route to market. An authorised product is assessed for efficacy, risks to human and animal health and the environment, and relevant physical and chemical properties, and receives a product authorisation number with conditions of use. Existing active substances that are still being evaluated can also support lawful supply under the applicable transitional arrangements; those products do not necessarily have a product authorisation number.
The regulation covers 22 product types (PTs) grouped into four main areas: disinfectants (PT1–PT5), preservatives (PT6–PT13), pest control (PT14–PT20), and other biocidal products (PT21–PT22). For water treatment and disinfection professionals, the most relevant product types are PT2 (disinfectants for private and public health areas), PT4 (food and feed area disinfection), and PT5 (drinking water disinfection).
Compliance is product-specific and use-specific. A PT4 surface use does not establish a PT5 drinking-water or PT2 pool use. For an authorised product, check the authorisation and its conditions. For a transitionally supplied product, check the precise active substance or precursor route and product type, Article 95 supply chain, applicable transitional requirements and deadlines, and any other national requirements.
Understanding Product Types: PT2, PT4, PT5 and PT11
PT2 covers disinfectants and algaecides not intended for direct application to humans or animals in private, public and industrial areas, including products used for swimming-pool water. Classification follows the claimed purpose; a cooling system is not automatically PT2.
PT4 covers disinfection of equipment, containers, utensils, surfaces and pipework associated with producing, transporting, storing or consuming food or feed, including food-contact and feed-contact areas. It is not a generic category for changing rooms or other non-food surfaces.
PT5 covers disinfection of drinking water for both humans and animals. Drinking-water rules outside GB BPR may also apply, including the DWI Regulation 31 regime for public supplies in England and Wales and equivalent regimes elsewhere.
PT11 covers preservation of water or other liquids used in cooling and processing systems. PT12 covers slimicides used on industrial materials, equipment and structures. The actual claim and treated medium determine the product type, so a competent product-specific assessment is needed rather than a blanket classification of every cooling tower or water system.
Why BPR Compliance Matters for Duty Holders
Under the Health and Safety at Work etc. Act 1974, the Management of Health and Safety at Work Regulations 1999, and specific regulations such as the Control of Substances Hazardous to Health Regulations 2002 (COSHH), duty holders have a legal obligation to ensure that any biocidal products used in their premises are suitable for purpose and compliant with applicable regulations.
Placing an unlawfully supplied biocidal product on the market, or using it outside applicable requirements, can lead to HSE enforcement. A product is not unlawful merely because it lacks an authorisation number: first establish whether applicable GB transitional arrangements permit supply and use.
Contracts and insurance policies may require compliance with applicable law, but consequences depend on their wording and the facts. Procurement records should therefore identify the product's legal route and permitted uses rather than treating 'not on the authorised-products list' as a complete test.
Product authorisation provides a regulatory assessment of the authorised claims and conditions. Transitional supply is a different legal route, not an HSE assessment or endorsement of the finished product; suppliers and users must still support claims, follow labels and safety information, and meet other applicable law.
How to Verify BPR Compliance
Start by asking which legal route the supplier relies on. If the product is authorised, obtain its GB authorisation number and verify the product, product type, users, uses and conditions on HSE's authorised-products list and against the label. An EU authorisation concerns the EU regime, including Northern Ireland, and does not by itself authorise supply in Great Britain.
If the product relies on transitional arrangements, absence from the authorised-products list is not proof of non-compliance. Obtain evidence identifying the active substance or, for an in-situ system, the exact precursor route and relevant product type; check that combination on HSE's GB active-substance and Review Programme information; confirm the applicable transition and deadline; and check compliance with advertising, record-keeping, notification and other national requirements.
In both routes obtain the current label, SDS, technical information and evidence supporting the intended use. For transitional supply, also verify that the relevant active-substance or product supplier is on the GB Article 95 list for the combination. Article 95 listing is a supply-chain condition: it is not product authorisation, an efficacy finding or an HSE endorsement.
Keep a dated verification record because active-substance status, deadlines and authorisation conditions can change. Separate regimes may also apply, including COSHH and drinking-water approvals. If evidence is unclear, ask the supplier to identify the legal basis precisely or seek regulatory advice before use.
Common Compliance Pitfalls to Avoid
A common failure is using a product outside the product type, use or conditions supported by its legal route. The same active substance does not make PT4, PT5, PT2 and PT11 uses interchangeable.
Do not confuse four different matters: active-substance or precursor-route status, Article 95 supply-chain listing, transitional eligibility, and finished-product authorisation. Article 95 listing alone does not authorise a product, while a transitionally lawful product may not yet hold a product authorisation.
Transitional eligibility is not timeless. Check the relevant combination and current HSE deadlines, including the consequences of an approval, non-approval, withdrawal or identity change, rather than relying on an old supplier statement.
Great Britain and EU BPR are separate regimes. An EU or Northern Ireland authorisation does not establish GB status, and GB status does not establish EU or Northern Ireland status.
ChloroKlean's GB BPR Position
ChloroKlean products are supplied in Great Britain for their stated uses under the transitional arrangements that apply while the relevant chlorine dioxide precursor-route and product-type combinations remain in the GB Review Programme, with the applicable GB Article 95 supply chain. This is not a claim that the products hold full GB product authorisation, and no EU or Northern Ireland authorisation is claimed.
Product-specific documentation can identify the stated product types, precursor route, Article 95 supply-chain basis, current SDS, technical information and applicable use instructions. Because Article 95 listing is not product authorisation, these items should be reviewed together with current HSE status and transitional deadlines.
Duty holders should verify the intended application rather than assume coverage from a broad phrase such as 'water treatment'. PT5 concerns human and animal drinking water; PT11 concerns preservation of cooling or process liquids; PT2 and PT4 have different scopes. ChloroKlean can provide its documentation, but the user remains responsible for site-specific COSHH and other applicable requirements.
Key Data & Statistics
2 routes
Product authorisation or applicable lawful transitional supply
22
Product types in the GB BPR framework
PT5
Drinking-water disinfection for humans and animals
PT11
Preservation of liquids used in cooling and processing systems
Authorised and Transitionally Supplied Products
The two lawful GB BPR routes require different verification evidence; Article 95 listing alone establishes neither route.
| Feature | GB-Authorised Product | Lawful Transitional Product |
|---|---|---|
| Legal Basis | GB product authorisation and its conditions | Applicable transition while the relevant combination remains under review |
| Primary HSE Check | Authorised-products list | Active-substance list and Review Programme status for the route and PT |
| Authorisation Number | Expected and checked against HSE records | Not necessarily issued |
| Article 95 | Check where applicable | Relevant supplier must be listed for the combination; listing is not authorisation |
| Uses and Product Types | Must match the authorised uses and conditions | Must match the supported route, product type and transitional requirements |
| Deadlines | Check authorisation validity and amendments | Check current approval, non-approval and application deadlines |
| Product Documentation | Label, SDS, technical data and authorisation details | Label, SDS, technical data, route/PT evidence and transitional basis |
| Separate Requirements | COSHH, water approvals and other national law may also apply | COSHH, water approvals and other national law may also apply |
A product with neither valid authorisation nor applicable transitional status is not lawfully placed on the GB market for that biocidal use. Always check current HSE information.
How to Ensure Your Disinfection Programme Is BPR Compliant
A practical step-by-step guide to verifying and maintaining BPR compliance across your disinfection programme.
Identify All Biocidal Products in Use
Create a complete inventory of every disinfectant, biocide, and antimicrobial product used across your premises. Include water treatment chemicals, surface disinfectants, hand sanitisers, and any other products intended to destroy, deter, or render harmless any harmful organism. Record the product name, manufacturer, supplier, and claimed application.
Determine the Required Product Type for Each Application
For each product, identify the product type from the intended purpose and claim. Pool or spa water is generally PT2; food- or feed-area surfaces and equipment are PT4; human or animal drinking water is PT5; and preservation of cooling or process liquids is PT11. Do not classify every cooling system as PT2 or treat PT4 as a generic surface category.
Identify and Verify the GB Legal Route
Ask whether each product is authorised or relies on transitional arrangements. For an authorised product, verify its GB authorisation number, product type, intended uses and conditions on HSE's authorised-products list. For transitional supply, verify the exact active substance or precursor route and product type in the GB Review Programme, the current status and deadline, the relevant GB Article 95 supply chain, and any other applicable transitional or national requirements. Article 95 listing is not product authorisation.
Obtain Complete Regulatory Documentation
Request the current label, Safety Data Sheet (SDS), Technical Data Sheet (TDS), intended-use evidence and a clear statement of the legal basis from each supplier. Where transitional arrangements are relied on, retain the precursor-route and product-type evidence, Article 95 evidence, applicable deadline and date checked. File current records for inspections, COSHH assessments and procurement reviews.
Resolve Gaps and Keep the Check Current
Do not reject a product solely because it has no authorisation number, but do not accept Article 95 listing alone as proof either. Resolve any missing authorisation conditions or transitional evidence before procurement or use, seek competent advice where needed, and update COSHH assessments, written schemes and records when status, deadlines, labels or uses change.
Expert Insights
About the Reviewer
Gavin Owen
Managing Director, ChloroKlean
Gavin Owen leads ChloroKlean's technical and commercial operations, bringing over 20 years of experience in industrial chemical distribution and water treatment. He oversees product development, regulatory compliance strategy, and the company's BPR compliance programme across PT2, PT4, PT5, and PT11 product types. Gavin works directly with water treatment professionals, facilities managers, and public health engineers across healthcare, leisure, food processing, and industrial sectors.
Related Products
BPR-compliant chlorine dioxide products available from ChloroKlean.
ChloroKlean Plus L20
Regenerative liquid chlorine dioxide supplied in Great Britain for stated PT2, PT4, PT5 and PT11 uses under applicable GB BPR transitional arrangements. Check product-specific documentation and conditions before use.
ChloroKlean Spa 500
Chlorine dioxide solution supplied in Great Britain for stated swimming-pool and spa uses under applicable PT2 transitional arrangements. Check current product documentation and use instructions.
ChloroKlean Surface Disinfectant
Surface disinfectant supplied in Great Britain for stated PT4 food- and feed-area uses under applicable transitional arrangements. Suitability, label conditions and any required rinse must be checked for the specific surface and process.
Frequently Asked Questions
Common questions about this topic, answered by our technical team.
Important Regulatory and Safety Information
- A biocidal product must be authorised for its intended use or qualify for lawful supply and use under applicable GB BPR transitional arrangements.
- GB BPR status is product-, route- and use-specific. Authorisation or transitional status for one product type does not establish another.
- For authorised products, verify the authorisation number and conditions. For transitional products, verify the active substance or precursor route and product type, Review Programme status and deadlines, Article 95 supply chain, and other applicable requirements.
- GB Article 95 listing is a supply-chain requirement, not product authorisation, an efficacy finding or an HSE endorsement.
- All biocidal products must be stored, handled, and used in accordance with their Safety Data Sheet and product label directions.
- Appropriate personal protective equipment (PPE) must be worn when handling biocidal products as specified in the product SDS and COSHH assessment.
- This guidance applies to the Great Britain market (England, Scotland, and Wales). Northern Ireland operates under the EU BPR with separate authorisation requirements.
This information is general guidance, not legal advice or confirmation of any product's current status. Check HSE's current lists and guidance, the product documentation and any applicable national regime, and seek professional regulatory advice where necessary.
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Why cooling and process-liquid preservation may be PT11 and other claims may fall within a different product type.
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Sources & References
This article references guidance from the following authoritative sources:
- Biocidal Products Regulation (BPR, Regulation (EU) 528/2012)
ECHA - European Chemicals Agency
- GB Biocidal Products Register
HSE - Health and Safety Executive
- GB Review Programme for existing biocidal active substances
HSE - Health and Safety Executive
- In situ generation: active substances vs biocidal products
HSE - Health and Safety Executive
- GB Article 95: the basics
HSE - Health and Safety Executive
- BPR active substance lists for GB and NI
HSE - Health and Safety Executive
- UK authorised biocidal products
HSE - Health and Safety Executive
- ACOP L8: Legionnaires' disease - Control of legionella bacteria in water systems
HSE - Health and Safety Executive
- Control of Substances Hazardous to Health Regulations 2002 (COSHH)
HSE - Health and Safety Executive
- Drinking Water Inspectorate - Approved Products
UK Government - Drinking Water Inspectorate
- Health and Safety at Work etc. Act 1974
UK Government - UK Government Legislation
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