On March 23, 2026, The European Union notified the World Trade Organization (WTO) under the Technical Barriers to Trade (TBT) Agreement of a draft Commission Implementing Decision concerning the non-approval of poly(dimethyloctadecyl[3-(trihydroxysilyl)propyl]ammonium chloride), generated from dimethyloctadecyl[3-(trimethoxysilyl)propyl]ammonium chloride, as an existing active substance for use in biocidal products. The measure has been proposed by the European Commission. The draft decision concludes that the active substance cannot be approved for product types 2, 7, and 9 under Regulation (EU) No. 528/2012 due to significant data gaps, including the absence of validated analytical methods and insufficient information on physico-chemical properties. As a result, it was not possible to assess risks to human health and the environment, nor to determine whether the substance is carcinogenic, mutagenic, or toxic for reproduction. Additionally, efficacy has not been adequately demonstrated. Consequently, articles treated with or incorporating this active substance would no longer be permitted on the EU market 180 days after the adoption of the non-approval decision. The measure aims to protect human health, the environment, and ensure regulatory harmonization across the European Union. The proposed date of adoption is June 2026, with entry into force 20 days after publication in the Official Journal of the European Union and application 12 months after adoption. Stakeholders are invited to submit comments within 60 days of notification, by May 22, 2026.
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