Biocidal products: new European guidance on trade names to prevent misleading wording

The Competent Authorities of the Member States for biocidal products have agreed on a harmonised approach and prepared a guidance note aimed at limiting the use of potentially misleading terms in the trade names of products regulated by Regulation (EU) No 528/2012 (BPR). The document, updated in March 2026, is intended to promote consistent application of the legislation across the Member States, while specifying that it does not represent an official position of the European Commission and is not legally binding.

The initiative stems from discussions launched during the December 2022 meeting, which we covered in this news article. At that meeting, the Competent Authorities considered whether the use of potentially misleading terms, such as prefixes or suffixes, in the trade names of biocidal products should be generally prohibited, rather than following a case-by-case assessment approach. The majority of Member States expressed their support for the former approach.

How the new approach will be applied

The document agreed upon by the Competent Authorities of the Member States sets out the practical arrangements under which the Authorities and the Commission will apply the approach.

In particular:

• ongoing national and European Union authorisation applications will have to adjust the trade names by removing terms considered misleading. If the applicant does not replace the name, the designation will be removed from the Summary of Product Characteristics (SPC) and from the authorisation or, if it is the only proposed trade name, the product will not be authorised;
• for products already authorised under the BPR, the adjustment will take place when the authorisation is renewed or earlier, at the request of the authorisation holder or as part of a modification of the authorisation provided for by the Regulation;
• the approach may also be applied to products placed on the market under the transitional measures, with market surveillance authorities being responsible for the relevant control activities;
• products authorised through temporary permits under Article 55(1) of the BPR are excluded.

The document also clarifies that, when a potentially misleading term forms an integral part of a company's name or identifies a specific technology developed by the company, the name may be used only in its complete form and not by using solely the term that could be considered misleading.

List of non-permitted terms

The annex to the document contains a non-exhaustive list of terms that should not appear in the trade names of biocidal products. The list also includes the corresponding translations in the languages of the European Union and is intended to be reviewed and updated annually during meetings of the Competent Authorities.

The terms currently included are:

• “bio” (with exceptions for “biocide”, “biocidal” and “biofilm”);
• “natur”, “nature” and “natura” (with an exception for “denatured”);
• “organic”;
• “eco” and “ecological”;
• “green”;
• “safe”;
• “sensitive”;
• “soft protection”;
• “soft touch”;
• “gentle”.

Specific exceptions apply to some terms. For example, “green” may be used simply to indicate the colour of the product or, for Product Type 2 products, when it refers to green algae as the target organism.

Revision of the document

The document has undergone two successive revisions.

In September 2023, the list of terms was expanded to include “ecological”, and further exceptions were introduced for “biofilm” and “denatured”.

With the revision approved in March 2026, the timing for adapting already granted authorisations was clarified, and the list of non-permitted terms was extended to include “sensitive”, “soft protection”, “soft touch” and “gentle”.

The update confirms the objective of the Competent Authorities to promote a more consistent application of the BPR provisions, reducing the risk that the trade names of biocidal products may mislead users regarding the characteristics or properties of the products themselves.