The Certibiocide directive, which was due to be implemented in January 2025, was finally postponed by one year and came into force on January 1, 2026 .
A new European regulation that does not go towards simplification and where it is useful to understand which product and especially who is concerned by this "training" to obtain this " Biocide Certificate " whose effectiveness I objectively and personally doubt.
The products concerned by biocides in the cleaning products category are primarily surface or floor disinfectant cleaners , and food-grade disinfectants of types TP2 and TP3 . Disinfectant soaps are TP1, therefore requiring information on the use of biocides, but they do not fall under the scope of the Biocidal Products Regulation which mandates obtaining a certificate.
Indeed, if every user of disinfectant soap or hydroalcoholic gel had to pass a certification test... but things can change, and perhaps one day we will all have to be certified...
In this context, several misunderstandings and inaccuracies regarding the application of the obligation for resellers and users of Biocidal products must be clarified .
The updated directive is that of May 2025 from the Ministry of Ecological Transition and Biodiversity.
Definition of a Biocidal Product
Before addressing questions related to application, let's first look at the definition of a product called "Biocide".
A biocidal product is "Any substance or mixture..., consisting of one or more active substances..., which is intended:
To eliminate, repel, or render harmless harmful organisms,
to prevent its action,
or to combat them in any other way by an action other than a simple physical or mechanical action.
Summary of the types of products potentially affected
The products are defined into 4 main groups which are
Group 1: Disinfection
Group 2: Protective Products
Group 3: Pest control products
Group 4: Other biocidal products
Each group is then sub-categorized by Product Type (PT) from PT1 to PT22
Synthesis of the 4 Biocidal groups with the TP (Product Type)
Group 1
disinfectants (including algaecides and fungicides) | Group 2
protective products | Group 3
pest control products | Group 4
other Biocidal products |
Practical Exercise 1: Human Hygiene
TP2: Disinfectants and algaecides not intended for direct application to humans or animals
TP3: Veterinary Hygiene
TP4: Surfaces in contact with foodstuffs and animal feed
TP5: Drinking water | Practical Exercise 6: Protecting (manufactured) products during storage
TP 7: Film protection
TP 8: Wood Protection
TP 9: Protection of fibers, leather, rubber and polymerized materials
TP 10: Protection of building materials
TP 11: Protection of liquids used in cooling and manufacturing systems
TP 12: Anti-biofilm products
TP 13: Protection of working or cutting fluids | TP 14: Rodenticides: rodent control (rats,
mouse, …)
Other than repellents and baits
TP 15: Avicides
TP 16: Molluscicides, vermicides and products used to control other invertebrates
TP 17: Fishicides
Practical Exercise 18: Insecticides, acaricides and products used to control other arthropods: control of insects, mites, arachnids and crustaceans. Other than repellents and baits.
Practical Exercise 19: Repellents and Baits
TP 20: Control of other vertebrates (other than rodents, birds and fish and other than repellents and baits) | TP 21: Antifouling products (aquatic equipment)
TP 22: Fluids used for embalming and taxidermy |
What is Certibiocide?
The Certibiocide is an individual certificate.
Certain types of biocidal products are exclusively reserved for professionals (excluding those
used exclusively in a production or transformation process).
The Certibiocide is valid in France for 5 years and is renewable.
Please note that the Certibiocide certificate is not an accreditation . It is important to understand that there is no company accreditation for the service sector that includes the application of biocidal products. However, there are:
- A voluntary CEPA certificate
- A requirement to declare activity on the website https://certibiocide.din.developpement-durable.gouv.fr
Who is affected by the Certibiocide?
You buy products categorized as Biocide but you don't know if you are required to have completed the training to obtain "Certification"?
First of all, it is important to understand that a product can be categorized as a Biocide (Product Type from 1 to 22..) without having the obligation to have a "Certification" to sell, use or buy it.
Thus, category TP1, for example, does not require any certification.
Within the same framework, several professions are "exempt" from this obligation.
In the relevant categories listed in the table below, a certificate issued through training is mandatory in 3 cases:
- If you purchase an affected product.
In this case, you will need to provide an individual certification number. For a company, it is sufficient for one person to be trained and hold this certification for the company or legal entity to be able to purchase this type of product.
- If you use a product concerned, then the certification must concern the user.
- If you distribute or sell a product concerned. For a seller of biocidal products, again, only one person with this certification is required. For example, at Voussert, three people have obtained this certification, thus meeting this requirement and guaranteeing a thorough knowledge of biocides within the company.
What type of product (TP) is subject to the requirement of a Certibiocide?
From TP1 to TP22, that makes 22 categories of Biocide-type products...
You're going to tell me that we could have done it more simply, and I agree!
So here is a table which I hope will help you find your way around the "TP" (Public Works) which require a Certibiocide certificate and, above all, which certificate...
As you will see, many of these products do not require any certification, so apart from the obligation to provide information on the use of biocides, there is no certification requirement for their use. So, thank goodness, if you wash your hands with disinfectant soap, you're safe...
The summary of the following table shows that the Product Types that require a Certibiocide certificate are as follows:
TP2 / TP3 / TP4 / TP14 / TP18 / TP20 / TP8 / TP15 / TP20
Type of biocidal product (TP)
(Annex V of EU Regulation 528/2012) | Maybe
concerned
by decree
"Certibioicide" | Category of Certibiocide to be obtained |
Certibiocide
Disinfectants | Certibiocide
Pests | Certibiocide
Other products |
| Group 1: Disinfectants |
| TP1: For human hygiene (skin, scalp) | NO | | | |
| TP2: Disinfectants and algaecides not intended for direct application to humans or animals | YES | X | | |
| TP3: Veterinary Hygiene | YES | X | | |
| TP4: Surfaces in contact with foodstuffs and animal feed | YES | X | | |
| TP5: Drinking water | NO | | | |
| Group 2: Protective Products |
| TP6: Protecting (manufactured) products during storage | NO | | | |
| TP7: Film protection | | | | |
| TP8: Wood Protection | YES | | X | X |
| TP9: Protection of fibers, leather, rubber and polymerized materials | NO | | | |
| TP10: Protection of construction materials | NO | | | |
| TP11: Protection of liquids used in cooling and manufacturing systems | NO | | | |
| TP12: Anti-biofilm products | NO | | | |
| TP13: Protection of working or cutting fluids | NO | | | |
|
TP14: Rodenticides: rodent control (rats,
mouse, …) | YES | | X | |
| TP15: Avicides | YES | | X | X |
TP16: Molluscicides, vermicides and products used for
fight against other invertebrates | NO | | | |
| TP17: Fishicides | NO | | | |
| TP18: Insecticides, acaricides and products used to control other arthropods: control of insects, mites, arachnids and crustaceans | YES | | X | |
| TP19: Repellents and Baits | NO | | | |
TP20: Control of other vertebrates (other than rodents, birds and fish and other than repellents and
bait) | YES | | X | X |
| Group 4: Other biocidal products |
| TP21: Antifouling products (aquatic equipment) | YES | | X | X |
| TP22: Fluids used for embalming and taxidermy | NO | | | |
What type of Biocide certificate is required?
As shown in the previous table, there are 3 different types of certificates which are directly linked to the type of product (TP) concerned.
Some types of products are compatible with two certificates.
This means that one or the other is sufficient, but certainly not both...
- Certibiocide disinfectant valid for TP2 / TP3 / TP4. This is the one relevant to us in the field of hygiene and disinfection of floors and surfaces in public spaces. The training module lasts 7 hours.
- Certibiocide noxious valid for TP8 / TP14 / TP15 / TP18 / TP20 / TP21. This is the most demanding with a 21-hour training module.
- Certibiocide for other products TP8 / TP15 / TP20 / TP21 with a training duration of 7 hours.
Training can be done in person or remotely via video conference, which is the choice of most stakeholders.
Who can buy BIOCIDAL products?
On the website www.voussert.fr, the products are clearly indicated in the specifications for each product. We also specify the TP category and whether or not a certificate is required to purchase and use the product.
This will allow you to complete your customer area with your Biocide certification number to ensure compliance.
However, there are special cases with professions that have been granted exemptions due to their initial training in health-related subjects , such as nurses, doctors...
There are also product exceptions, particularly for personal hygiene products , in special cases (otherwise it would be too simple...) which are TP2 and TP4 but compatible with professional and general public products and therefore do not require a BIOCID certificate.
Examples of hand care products, swimming pool products...
If you have any doubts, please do not hesitate to contact us.
Which professionals are exempt?
There are a number of exempt professions, such as food service businesses (for the disinfection of surfaces, premises, and equipment used). This includes restaurants, canteens, cafes, bars, bakeries, caterers, and meat processing plants. Food production areas include farms, dairies, and intensive livestock farms . (Information available on the Certibiocide website).
Regulatory framework in France and Europe
Several texts govern the placing on the market and use of biocidal products.
European regulations
The best-known regulation at the European level is REACH Regulation No. 1907/2006
This regulation requires prior authorization for the import and sale of chemical substances in the European Union, including biocidal products.
The second regulation is CLP No. 1272/2008
It stipulates that products classified as hazardous must meet certain labelling and packaging requirements.
For biocidal products, depending on the results of the hazard assessment carried out within the framework of the MA: the substance is classified in a "category" of hazards which allows a simplified idea of the real hazards of the product.
This information must be indicated on the packaging, technical data sheets, and on online sales sites and sales media.
- Hazard statements that specify the risks associated with the product
- Pictograms that provide a quick illustration of the risks
- Safety advice indicating the necessary precautions to take to eliminate or limit risks.
This is why many manufacturers are developing "CLP-free" cleaning and maintenance product formulations, thus providing increased safety for the user.
European Biocidal Products Regulation No. 528/2012
This regulation defines the types of Biocidal products from TP1 to TP22
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