Last week, I wrote about how you can identify a biocidal product.
If you have determined that a product from your sales program is a biocide, or you plan to include such a product in your portfolio, here are the most important things you need to know BEFORE placing biocides on the market in Bosnia and Herzegovina.
First of all, keep in mind that the regulation of biocides varies in different parts of Bosnia and Herzegovina.
In the Federation of Bosnia and Herzegovina, there are no detailed regulations on biocides. The List of Poisons that can be marketed in the Federation of BiH is still in use, and the same rules apply to biocides containing poisons as to other chemicals.
For example, sodium hypochlorite, which is a well-known disinfectant—one type of biocide—appears on the List of Poisons. This means that if you import sodium hypochlorite or a product containing sodium hypochlorite, you must obtain a permit for the importation of poisons from the Federal Ministry of Health.
However, the term "biocide" is not defined in the Federation of Bosnia and Herzegovina. There are no regulations based on European Union biocide regulations, and there are no detailed requirements regarding the composition, purpose, or mandatory labeling of such products.
But considering that the Federation of Bosnia and Herzegovina has started harmonizing with EU regulations in this area, that the Law on Chemicals was adopted in 2020, and that the Law on Biocides is also planned, there is enough time to prepare for the implementation of upcoming regulations. Review your portfolio now and plan future activities in accordance with upcoming obligations.
Also, keep in mind that many provisions of the Law on Chemicals apply to biocides (classification and hazard labeling, safety data sheets, registration of manufacturers and importers of chemicals, etc.).
In the Republic of Srpska, the situation is different. The Law on Biocides has been in force since 2009 and prescribes the conditions under which biocides can be marketed.
It defines what a biocide is, which active substances are considered biocidal, how biocidal action is demonstrated, how biocides are labeled and packaged, how they are advertised, and so on.
Additionally, the procedure for placing biocides on the market involves obtaining a marketing authorization. This process is conducted in two phases:
- Submission of basic data about the biocide and registration in the Technical Dossier Submission Program ("temporary registration"),
- Submission of the technical dossier for the active substance(s) and the biocide and issuance of a marketing authorization.
Currently, only the first phase—registration in the Technical Dossier Submission Program—is fully implemented. This procedure is mandatory for all biocides placed on the market in the Republic of Srpska, regardless of where the importer's headquarters are located.
In addition to entity-specific requirements, keep in mind that some biocides require a special import permit, the so-called D permit. This requirement is defined for products classified under tariff number 3808 into sub-numbers defined for insecticides, fungicides, and herbicides.
As you can see, you first need to know where your potential buyers or users are located. Depending on this, you must meet different requirements.
If this seems complicated, you might need help. Contact me at nina.pajovic@bens-consulting.eu.
Slika autora Gerd Altmann od Pixabay
Back to posts
