EU public consultation: silver nitrate and (benzyloxy)methanol

The European Chemicals Agency (ECHA) is consulting on potential candidates for substitution and on derogation conditions.

The EU Biocidal Products Regulation 528/2012 (EU BPR) applies in NI.

Under EU BPR, if an active substance meets the exclusion criteria set out in Article 5(1), it would not normally be approved for use in biocidal products.

Silver nitrate and formaldehyde released from the reaction products of paraformaldehyde and benzyl alcohol ((benzyloxy)methanol) have been identified as fulfilling at least one of the criteria set out in the Article 5(1) exclusion criteria under EU BPR.

Where an active substance meets at least one of the exclusion criteria listed in Article 5(1), it may still be approved in accordance with Article 5(2) if one of the following conditions are met:

• the risk to humans, animals or the environment from exposure to the active substance in a biocidal product, under realistic conditions of use, is negligible; or
• the active substance is essential to prevent a serious danger to human or animal health or the environment; or
• not approving the substance would have a disproportionate negative impact on society compared to the risks

In these circumstances the active substance will also be considered as a candidate for substitution under Article 10(1) of EU BPR.

Before submitting its opinion on the approval or renewal of the active substance to the Commission, ECHA will launch a consultation to collect information on potential alternatives to this substance under Article 10(3) of EU BPR.

The following active substances have been identified as potential candidates for substitution under EU BPR and ECHA has launched public consultations running until the stated dates:

23 January 2026

• silver nitrate (CAS 7761-88-8 EC 231-853-9) in product types 1, 4, 5 and 9

26 January 2026

• formaldehyde released from the reaction products of paraformaldehyde and benzyl alcohol ((benzyloxy)methanol) (CAS N/A EC N/A) in product type 6

Comments should be submitted to ECHA using the dedicated webforms.

Please note these consultations and their outcome are not applicable under the GB Biocidal Products Regulations (GB BPR).

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