The COVID-19 pandemic, the war in Ukraine, and the energy crisis taught us one thing – the European Union needs effective crisis response tools. The answer to these challenges is Regulation (EU) 2024/2747, known as the Internal Market Emergency and Resilience Act (IMERA), which will come into force on May 29, 2026.
IMERA is a true “early warning system” for the European internal market. The regulation introduces a three-stage crisis response mechanism:
IMERA, as a tool for crisis prevention in the EU, can introduce two modes that support crisis management.
Vigilance mode – activated by the Council for a maximum of 6 months when a threat could escalate into a crisis. In this mode, Member States monitor supply chains of goods of critical importance.
Emergency mode – triggered when a crisis severely disrupts the free movement of goods, services, and persons. This is when the Commission can deploy extraordinary measures.
Arsenal of crisis measures
In a crisis situation, the European Commission can:
Good news: IMERA does not change BPR provisions! Article 55(1) of the BPR concerning emergency situations remains in force. The difference? Under BPR, Member States assess threats to public health, while under IMERA, the emergency mode is activated by the EU Council.
Key point: If biocidal products are designated as “crisis-relevant goods,” the Commission can apply the full range of IMERA measures – from information requests to recommendations for accelerating authorizations.
IMERA represents lessons learned from recent crises. During the pandemic, there was a shortage of disinfectants, and authorization procedures couldn’t keep pace with needs. The new regulation aims to ensure the EU is better prepared in the future.
For the biocides industry, this means: greater flexibility in times of crisis, but also potential information obligations and the need to comply with priority production orders.
Are you planning to enter the biocidal product market or are preparing to introduce another product? Entrust the registration of biocidal products to specialists – we provide comprehensive assistance, welcome.
Source: “Interaction between Regulation (EU) 2024/2747 and the BPR CA-108, 19 June 2025”, European Commission