BPR: Automotive Industry Guideline

AIG-BPR Key Messages:

1. Identify BPs and Tas
   Create an inventory of any ASs in BPs or TAs that you manufacture, import, use or supply.
2. Identify the product-type
   Decide on the correct PT, based on your customers’ uses and your own, and using technical knowledge of the product from the companies involved (suppliers, distributors, manufacturers).
3. Identify your roles
   For each BP or TA on the inventory, identify your role(s) eg manufacturer, supplier, importer, professional user, and then your corresponding BPR obligations.
4. Check active substance status (ASS)
   You need to understand the BPR status of each active substance (AS) in each BP and TA on your inventory, in order to determine the applicable transitional measures for marketing and use.
5. Substitute or eliminate ASS
   Where the AS status identifies the need, make and implement plans to substitute or eliminate those affected ASS.
6. Label BPs and Tas
   BPs always require BPR labelling. TAs require BPR labelling if you make a biocidal claim about the TA, or if the approval conditions of the AS mention labelling as a requirement.
7. Provide further information to customers
   On request from a customer about biocidal treatment of a TA, as a minimum you must provide information identifying each AS.
8. Maintain records
   Ensure that you are able to demonstrate BPR compliance in case of audits or inspections.