The term 'in situ' refers to the production of active substances manufactured on the spot, both with or without the use of other chemical substances (precursors).
In situ-generated active substances and their precursors are to be included in the Review Programme on active substances for biocidal products relating to the relevant product type. Companies using active substances manufactured in situ should review which kinds of approval are required for these. The alternative is to review the possibility of replacing existing methods.
One example of a process where the active substance is produced with the help of precursor chemicals is when active chlorine is produced through the electrolysis of sodium chloride.
One example of a case where no precursor chemicals have been released on the market is ozone generated from the oxygen in the atmosphere. Another example is active chlorine produced from seawater through electrolysis. In these cases too the active substances produced will in the long run require approval.
Many active substances generated in situ will be redefined in the Review Programme. This means that the new designations must describe both the active substance generated and the precursor chemicals used. This will mean that certain combinations of precursor chemicals and active substances will no longer be covered by the ongoing evaluation being carried out under the Review Programme. In order that these combinations of active substances and precursor chemicals may continue to be used, those wishing to have these combinations evaluated will need to notify ECHA of their interest. The final date for registering one’s interest is 27 April 2016.
Certain combinations of active substance and precursors/method for generation were not covered by past regulations on biocides. Since the current regulations include all in situ-generated active substances, those who are interested will need to submit an application for approval of these active substances no later than 1 September 2016. If no such application is submitted in time, the active substances may not be used or supplied after 1 September 2017.
You can find further information on how this might affect your company and what you need to do to adapt to the current regulations on the ECHA website.