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Anticoagulant rodenticides and biocides legislation

This page explains how the most well used rodenticides (chemicals used to control rodents such as rats and mice) are affected by the EU Biocidal Products Regulations (BPR). It is intended to help suppliers wishing to market these products in the UK, and people who use them, such as pest controllers.

For details of rodenticide products currently authorised in the UK see the UK Authorised Rodenticide Product Database.

Introduction

Rodents can carry diseases that can harm people, cause damage to buildings and spoil foodstuffs; rodenticides are one of the methods of controlling rodents. However, there can also be potential risks to people and the environment from the use of anticoagulant rodenticide products. HSE is seeking to establish a transparent and consistent approach for applying risk mitigation measures when First and Second Generation Anticoagulant Rodenticides (FGARs and SGARs) are authorised in the UK. This should take into account the need to control rat and mouse infestations, and protect buildings and infrastructure while protecting humans and non-target wildlife from exposure to FGARs and SGARs.

Professional use products and UK stewardship

Regulatory environmental risk assessments have concluded that the use of First and Second Generation Anticoagulant Rodenticides (FGARs and SGARs) outdoors present a higher level of risk to non-target animals (such as predatory birds and mammals) than would normally be considered acceptable. However HSE recognises that, despite carrying these risks, outdoor use of FGARs and SGARs is sometimes necessary as part of properly managed rodent control strategies.

In order to be able to authorise these rodenticides for use outdoors, HSE must be assured that the risks arising from such use will be properly managed. The UK Government Oversight Group has set out a number of high-level principles to help industry develop stewardship schemes to assure that rodenticides are being used in a safe and sustainable way.  Suppliers placing rodenticide products on the UK market for professional outdoor use will now be required to demonstrate that they adhere to the UK Government high level principles

High-level principles for Rodenticide Regime(s)

The UK’s Rodenticide Stewardship Regime is built on:

Delivering key benefits such as:

The Campaign for Responsible Rodenticide Use, has developed a stewardship scheme that adheres to the high level principles. The scheme will assist businesses provide robust assurance that the continued use of their FGARs and SGARs products will be based on a hierarchy of risk controls for rodents, promoting responsible use and good practice by all suppliers and professional users.

Link to First Report on Rodenticides Stewardship Regime - February 2017

Timelines for stewardship regime

Professional use products for which manufacturers have applied for professional outdoor use stewardship authorisation:

9th Adaptation to Technical Progress (ATP) to the CLP Regulation and anticoagulants

Proposals to revise the harmonised classifications of nine anticoagulants (brodifacoum, bromadiolone, chlorophacinone, coumatetralyl, difenacoum, difethialone, flocoumafen, warfarin and warfarin sodium) in the EU have been included in the 9th Adaptation to Technical Progress (ATP) to the CLP Regulation.

The proposals are to add the hazard class Toxic to Reproduction Cat 1A or 1B with a specific concentration limit of 0.003%. Under Article 19 of the BPR, biocidal products with such classifications (including anticoagulant rodenticides at these and higher concentrations) shall not be authorised for use by the general public. Authorisation holders intending to reduce the concentration of an anticoagulant in an authorised rodenticide product due to the implementation of the 9th ATP should submit a change application via R4BP. Applications may need to address the storage stability, analytical methods, dermal absorption and efficacy of the revised product. The 9th ATP entered into force on 8th August 2016.

On the additivity of reprotoxicity classifications for anticoagulants in the same product, ECHA’s draft guidance on CLP (July 2016) states: If the mode of actions of two substances is the same, additivity can reasonably be assumed, as in the case of anticoagulant rodenticides.

Rodenticide renewals

Other information

In 2012 stakeholders commented on a number of UK proposals for managing risk to the environment and human health, including possible restrictions on the outdoor use of SGARs:

A summary of the stakeholder responses is provided.

Rodenticide products marketed in the UK and the rest of the EU are considered to be either biocides (under Product Type 14) or plant protection products, depending on where and how they are used. Guidance on the borderline between the two regulatory schemes is provided on the European Commission’s website.

Updated 2017-03-15