(British Association of Chemical Specialities)
The use of Hydrogen Peroxide in Drinking Water Disinfection information note
Hydrogen peroxide is approved under the Biocidal Products Regulation (BPR) as an active substance for use in biocidal products for drinking water disinfection. The approval, as is the case when any active substance is approved under the BPR, triggered the requirement for the use of such biocidal products to be supported by applications, accompanied by product dossiers, for their authorisation. Under the BPR, active substances are first “approved” then biocidal products based on them are “authorised”. When a biocidal product is based on more than one active substance the timetable for the submission of the application for authorisation, accompanied by a product dossier, is determined by the last active substance approval date.
Applications for the authorisation of biocidal products for drinking water disinfection (BPR Product Type (PT) 5 use) based on hydrogen peroxide as the sole active substance had to be submitted by February 2017. The sell-out and use phase-out periods for such biocidal products for which no applications were submitted ended over two years ago. PT 5 products for drinking water disinfection based on hydrogen peroxide as the only active substance without an authorisation or an application still under evaluation then had to be removed from the market. Given that no biocidal products for PT 5 drinking water disinfection based on hydrogen peroxide as the sole active substance have yet been authorised in the UK, the placing on the market of such products in the UK relies on the applications, with supporting dossiers, which were submitted by February 2017 remaining in place and under evaluation.
We know that one supplier of hydrogen peroxide is no longer maintaining its application for biocidal product authorisations for PT 5 disinfection of drinking water for human consumption in the UK. In this case the biocidal products have already been removed from the market, although the BPR allows sell-out and use phase-out periods when applications are withdrawn just as it allowed these periods after the deadline for the submission of applications in 2017.
If you are using biocidal products, this is worth noting. It might be an idea to consider checking the situation with your own suppliers as well as confirming that their products are legal for use in the UK as, although the UK left the EU at the end of January, EU legislation including the BPR still applies during the Transition Period which runs to the end of December.
It should also be noted that the above relates to the biocidal uses of hydrogen peroxide which are regulated under the BPR. Hydrogen peroxide can also be used for drinking water treatment where the use is non-biocidal, for example for oxidation of sulphides or iron or for taste and odour control. Products for non-biocidal uses are regulated in the EU under REACH.