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Microbial cleaners in the context of legislation

EU-harmonised legislation

Microbial cleaners clearly fall under the EU Directive on occupational health risks of biological agents. With respect to sectoral legislation, the picture is more unclear. It seems that the EU Detergent Regulation does not apply. The EU chemical legislation REACH is rather unlikely to apply, but that is not entirely clear. The EU biocide legislation might possibly apply to some, but not all, of these products. Thus, at present, no sectoral environmental legislation is clearly covering these products. If so, EU Directive 2001/95/EC (European Union, 2001) on general product safety would still apply and require a certain safety assessment and risk-related information to consumers by manufacturers and importers of these products. However, there is substantial leeway on how to interpret the requirements of this directive. Consequently, the only clear requirements established are for assessing certain risks for workers’ health. There is no EU legislation regulating any environmental impacts of these products.

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