Message from the new Secretary General

As I am sure you are aware, ethanol is a key active component of hand sanitisers used throughout the health care industry. Whilst the Ethanol REACH Association represents and supports EU manufactures and importers of ethanol who need to register under REACH, such a registration does not cover supply of ethanol as an active biocide/disinfectant.

Supply into this market is only permitted in the EU (and at present also the UK) by manufacturers and importers who have registered under the Biocidal Products Regulation 528/2012 (BPR). Article 55 of the BPR does allow for the possibility of a temporary derogation from registration requirements in the event of a danger to public health that cannot be controlled by other means. For approved biocides, ECHA and the Commission are working to support member states and industry to co-ordinate requests for derogations and how to enact them. However, ethanol is not yet approved under the BPR and therefore the situation is fully in the hands of the Member States, who can take all measures considered necessary under national legislation. We are aware that some member states have already made such derogations.


If you receive a request for supply of ethanol or anticipate you may receive such requests and you are not registered under the BPR and are not aware of a national derogation being in place, you should contact your national competent authority for clarification.  If you are aware of national derogations being put in place, we would request that you advise us, along with a link to the respective competent authority website, so that we can cascade this information out to all members.


Kind regards,


Pablo Englebienne



Published on:  26 March 2020 1470 x viewed