
For companies manufacturing biocidal products, understanding the status of the existing active substances Review Programme is crucial for business strategy planning and product portfolio development. The latest data from June 2025 shows both progress and significant challenges in implementing this ambitious programme.
Halfway Mark Reached, but Pace Remains Uneven
According to report CA-June25-Doc.5.1, the Review Programme has reached the symbolic 50% completion threshold. This is a milestone that, however, should not overshadow the fact that progress varies significantly depending on the priority list:
What Do These Numbers Mean for Industry?
The uneven pace of programme implementation has direct consequences for manufacturers:
The Backlog Challenge – 29 Reports Waiting Since 2013
Particularly concerning is the fact that 29 substance/PT combinations submitted before 1 September 2013 are still in the peer review process. This means some companies have been waiting for decisions for over 12 years! This includes popular substances like ethanol and DMDM Hydantoin.
ECHA Action Plan – Hope for Acceleration
In response to the crisis, ECHA developed an Active Substances Action Plan, approved at the 87th CA meeting in February 2020. Additionally, new agreements were reached at the 102nd CA meeting in December 2023 aimed at further streamlining the process.
Recommendations for Companies
Summary
While achieving 50% completion of the Review Programme is an important milestone, the road to programme completion by 2030 remains challenging. The pace of active substance evaluations, the complexity of data requirements, and the limited capacity of assessing authorities continue to pose significant hurdles that may result in further delays. For the biocidal industry, this means the need for a flexible and forward-looking approach to portfolio management, strategic planning, and long-term investment in innovations capable of supporting compliance with increasingly stringent regulatory expectations. Companies that proactively anticipate evolving scientific and policy trends, including sustainability considerations and hazard-driven criteria, will be better positioned to secure product continuity, minimise business disruption, and maintain competitiveness in a rapidly shifting regulatory landscape.
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