This page explains the main BPR Article 95 customer requirements for end users, liquid manufacturers, distributors and OEM partners using Envirolyte ECA generators or electrochemically activated disinfectant solutions.
The Biocidal Products Regulation, Regulation (EU) No 528/2012, concerns the making available on the market and use of biocidal products in the European Union. For many disinfectant applications, customers should verify whether the relevant active substance, product type and supplier-chain documentation meet the applicable BPR and Article 95 requirements.
Envirolyte provides this information for technical and regulatory reference only. Product authorisation, permitted use and documentation requirements may vary by country, product type, application and current regulatory status.
What Is Article 95 Under the BPR?
Article 95 of the Biocidal Products Regulation is related to the list of active substances and suppliers maintained by the European Chemicals Agency. In practice, companies placing biocidal products on the EU market should be able to demonstrate that the relevant substance supplier or product supplier is included on the Article 95 list for the correct active substance and product type.
For Envirolyte-related regulatory references, please see our ECHA / BPR information page and the official ECHA active substance suppliers list.
Requirements for End Customers
If you are an end customer using disinfectant solution directly from an ECA generator in your own application, you should confirm that the relevant supplier in the supply chain is Article 95 listed for the applicable active substance and product type.
End customers should also check whether the intended use requires national product authorisation, local notification, project-specific documentation or additional compliance evidence. Requirements can differ depending on the country, product type and field of application, such as drinking water, food and feed areas, veterinary hygiene, cooling systems or industrial water treatment.
Requirements for Liquid Manufacturers and Distributors
If you produce, bottle, relabel, rebrand, distribute or sell a disinfectant liquid under your own name or brand, you may have additional obligations under the BPR. In many cases, a liquid manufacturer or distributor must ensure that the relevant active substance or biocidal product supplier is included on the Article 95 list for the correct product type.
You should keep written evidence confirming the Article 95 status of the relevant supplier. This may include supplier declarations, agreements, invoices, regulatory letters, ECHA references or other auditable documentation confirming the supply chain.
Requirements for OEM Customers
If you are an OEM customer purchasing ECA generators or related technology from Envirolyte, your Article 95 position may depend on how the equipment and generated solution are marketed, branded and supplied to the end customer.
OEM customers should confirm whether they are acting as an equipment buyer, product supplier, distributor, liquid manufacturer or brand owner. The correct compliance route depends on the commercial model, the intended use and the relevant product type.
Envirolyte can support OEM partners with available technical documentation, Article 95 references and project-specific regulatory information for evaluation and tender purposes.
Documents Customers Should Request or Keep
- Article 95 supplier-chain confirmation for the relevant active substance and product type.
- Product type information under the Biocidal Products Regulation.
- Technical data sheets and system documentation for the ECA generator.
- Quality control and solution specification records, where applicable.
- Local authorisation, notification or registration documentation, if required in the country of use.
For related technical information, see Approvals & Compliance and Quality Control.
Frequently Asked Questions
In many cases, end users do not need to be listed themselves, but they should be able to confirm that the relevant supplier in the supply chain is Article 95 listed for the applicable active substance and product type.
No. Article 95 listing helps demonstrate the status of the relevant supplier, while product authorisation or notification may still be required depending on the country, product type and intended application.
Need Help With BPR or Article 95 Documentation?
Envirolyte can help customers, distributors and OEM partners identify relevant Article 95 references, technical documents and compliance information for project evaluation, tenders or regulatory discussions.
