Following on from Part 1 of this article, which provided an overview of the product types (PTs) included in the Main Group 3 Pest Control products, Dr Chris Vance, concludes his article on pesticides by considering the main active substances used in Pest Control.
Active substances in Annex I/IA
The substances currently included in Annex 1/IA of the Biocidal Products Directive 98/8/EC (BPD) for the Pest Control group, together with the Implementing Directives, are shown in Table 1.
PT 14: Rodenticides
PT 18: Insecticides, acaricides, and products to control other arthropods
Bacillus thuringiensis, strain AM65-52
Magnesium phosphide releasing phosphine
PT 19: Repellants and Attractants
Methyl nonyl ketone
The Implementing Directives referred to contains information such as the date of inclusion of the Active Substance in Annex I/ IA and the deadline by which Member States have to ensure that authorisations or registrations of biocidal products containing the active substances are granted, modified or cancelled as appropriate [compliance with Article 16(3) of the BPD]. Also specified are the conditions of the authorisation and the expiry date of the inclusion of the active substance.
Table 2 gives an example of the Annex 1 entry for DEET, an active substance for use in Product-type 19 (Repellents and Attractants).
IUPAC name identification numbers
Date of inclusion
Date of compliance with Article 16(3)
Expiry date of inclusion
N,N-diethyl- meta-toluamide (DEET)
1 August 2012
31 July 2014*
31 July 2022
EC No. 205-149-7
CAS No. 134-62-3
* Except for products containing more than one active substance, for which the deadline to comply with Article 16(3) shall be the one set out in the last of the inclusion decisions relating to its active substances.
Special provisions for Table 2
Member States shall ensure that authorisations are subject to the following conditions.
Primary exposure of humans shall be minimised by considering and applying appropriate risk mitigation measures, including, where applicable, instructions for the amount and frequency of application of the product on human skin.
Labels on products intended for application on human skin, hair or clothing shall indicate that the product is intended only for restricted use on children between two and 12 years old, and that it is not intended for use on children less than two years old, unless it can be demonstrated in the application for product authorisation that the product will meet the requirements of Article 5 and Annex VI without such measures.
Products must contain deterrents for ingestion.
Status of Main Group 3 active substances
In addition to the 35 active substances already listed in Annex I/IA, there are a total of 55 other active substances still under evaluation in the Review Programme (see Part 1). The main active substances in each PT are briefly discussed below.
Product type 14: Rodenticides
The production tonnage of PT14 active ingredients is relatively small, amounting to around 30 tonnes/annum in the EU.
There are currently 14 PT14 Rodenticide active substances listed in Annex I/IA. The most important in terms of tonnage include Bromodiolone (CAS No. 28772-56-7), Chlorophacinone (CAS No. 3691-35-8), Coumatetralyl (CAS No. 5836-29-3) and Warfarin (CAS No. 81-81-2) which act as anticoagulants, and Alphachloralose (CAS No: 15879-93-3) which is an acute CNS (Central Nervous System) depressant.
There are only two additional Rodenticides in the Review Programme, namely Hydrogen Cyanide (CAS No. 74-90-8) and Powdered Corn Cob (CAS No. 999999-99-4). Hence, unless new active substances are introduced in future years, the total number of active substances for use as Rodenticides will be 16 at most.
Rodenticides by their nature have a relatively high degree of toxicity to mammals. Those that operate through an anticoagulant mechanism in particular have a high degree of acute toxicity and the handling and use precautions reflect this.
Product type 15: Avicides
The only avicides that could currently be used as biocidal products in the EU are those that contain Alphahloralose (CAS No. 15879-93-3) as the active substance. However a non-inclusion decision for the use of this active in PT15 was published in Commission Decision 2012/78/EC, so avicide products containing this active have to be phased out by 1 February 2013.
Product type 16: Molluscides
There are no active substances for use in PT16 listed in Annex I/IA or included in the review programme. Non-inclusion decisions have been published for 13 actives with phase out dates ranging from 2006 to 2008. Hence, unless new active substances are accepted for this PT, there will continue to be no biocidal products authorised for use as molluscides under the BPD. However, products such as slug and snail killers to protect garden plants are authorised and marketed under the Plant Protection Products regulations.
Product type 17: Piscides
There are no active substances for use in PT17 in Annex I/IA and Rotenone (CAS No. 83-79-4) is the only active included in the review programme with the UK as the responsible Member State.
Product type 18: Insecticides, acaricides and products to control other arthropods
Product-type 18 is the most important in Main Group 3 in terms of the number and tonnages of active substances, which exceeds 5000tpa in the EU. As well as the 17 active substances already listed in Annex I/IA, there are still 41 actives in the Review Programme.
Among the actives already listed in Annex I are Aluminium phosphide releasing phosphine (CAS No. 20859-73-8), Bendiocarb (CAS No. 22781-23-3) and Deltamethrin (52918-63-5). Major tonnage actives still in the review programme include Cyanamide (CAS No: 420-04-2), Piperonylbutoxide (CAS No. 51-03-6) and Pyrethrin and Pyrethroids (CAS No. 8003-34-7).
In general, the active substances within PT18 have a high degree of acute toxicity to humans and non-target terrestrial mammals and to aquatic species and non-target insects. The risk assessments and product authorisations take into account not only the intrinsic hazards but also the exposure potential through the generally widespread dispersive use of the products by both consumers and professional users.
Product type 19: Repellents and attractants
The three PT19 active substances currently in Annex I/IA are DEET (CAS No. 134-62-3), Methyl Nonyl Ketone (CAS No. 112-12-9) and (Z,E)-tetradeca-9,12-dienyl acetate (CAS No. 30507-70-1). There are a further 11 actives in the review programme. This is a relatively large application with around 3000–4000tpa of actives used for this application in the EU.
Product type 20 (in the BPR): Control of other vertebrates
The only active substance for PT20 included in the Review Programme is Aluminium phosphide (CAS No. 2085-73-8) which acts by releasing the highly toxic phosphine gas when exposed to moisture. There are no current entries in Annex I/IA.
The active ingredients used in main Group 3 biocidal products constitute in tonnage terms a relatively small, but a commercially important application for biocides in the EU. The most significant markets are as rodenticides, insecticides and repellents and attractants. Of these the Review Programme is almost complete for rodenticides but there remain a large number of substances still under review for PT’s 18 and 19. It continues to important, therefore, that manufacturers and importers of such products regularly review the status of the actives they use using the EU Commission website (http://ec.europa.eu/environment/biocides/ ) and the information provided by the relevant national authorities.