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The French  law “EGALIM” and its effect on biocidal products and more specifically geraniol based insecticides and repellents

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EGALIM is the abbreviation used for the

“Loi n° 2018-938 du 30 octobre 2018 pour l’équilibre des relations commerciales dans le secteur agricole et alimentaire et une alimentation saine, durable et accessible à tous.”

Or in English

“Law n° 2018-938 of October 30, 2018 for the balance of trade relations in the agricultural and food sector and healthy, sustainable and accessible food for all.”

From the title it seems like it has nothing to do with biocides, but this is wrong. Indeed, article 76 of this law forbids

  • advertising and self-service sales for certain categories of biocides to the general public,
  • and commercial practices (discounts and rebates) on certain categories of biocides for the general public.

Two decrees were already published and the first one (n° 2019-642 of 26 June 2019) prohibits discounts and rebates for biocidal products in the Product Types 14 (rodenticides) and 18 (Insecticides, acaricides and products to control other arthropods). So, one product, one price.

Geraniol is an existing active substance under both PT 18 and PT 19 (Repellents and attractants) and repellents are not within the scope of EGALIM! This is good news but it will require a clear message on the product that this is a repellent and not an insecticide!

The second decree (n° 2019-643 also of 26 June 2019) forbids publicity for certain biocides towards the general public. Publicity addressed to professional users is not forbidden but certain rules have to be followed!

This applies to all biocidal products of PT 14 and 18. It also applies to biocidal products of PT 2 and 4 classified H400 and H410.

The third prohibition (decree no 2019-1052 of 14 October 2019) relates to the self-service sale of certain biocidal products:

  • for which the appearance of resistance is established or suspected,
  • for which cases of involuntary poisoning are reported,
  • which are not the subject of a simplified marketing authorization (AMM) and which are often used disregarding the rules aimed at protecting human health or the environment appearing in their AMM or in the manufacturer’s instructions.

this means in practice that such biocidal products have to be locked up and the client has to ask a salesperson to get access to the biocidal products concerned.

Geraniol based repellents will be available for self-service sale! Unfortunately, geraniol based insecticides will not be available for self-service sale.

Another decree will be published following advice of ANSES (l’Agence nationale chargée de la sécurité sanitaire de l’alimentation, de l’environnement et du travail – National Agency for Food, Environmental and Occupational Health Safety) on the criteria to be applied for identifying the concerned biocidal products.

ANSES proposes the following criteria to determine whether self-service sales should be prohibited:

  • products containing active substances for which resistance has been identified,
  • products containing active substances for which serious accidental poisonings or deaths have been reported,
  • products containing active substances whose substitution should be encouraged,
  • products classified for their serious local effects on human health (skin corrosion, ocular effects, skin sensitizers), which will very likely lead to the restriction or even prohibition of use by the general public during the assessment of the application for marketing authorization,
  • products containing co-formulants of particular concern (substances of concern).

Based on these criteria, ANSES recommends that all rodenticides (used to control rodents), insecticides and antifouling paints for boat hulls should no longer be available in self-service.

This is still a proposal and needs to be incorporated in a decree.

It has to be noted that the EGALIM law and its decrees apply also to biocidal products imported into France!

In case the ANSES recommendations are becoming law, the situation with geraniol based products may look different.
Geraniol based insecticides will remain within the scope of EGALIM and all restrictions including prohibition of self-service sale will apply. Unless geraniol will be eligible for the BPR annex I listing, low risk active substances. This is unlikely as one of the exclusion criteria for this annex I is skin sensitization and geraniol has been classified as a skin sensitizer.
Geraniol based repellents may become within the scope of EGALIM as products classified for serious local effects like skin sensitization will also be prohibited for self-service sale! However, EGALIM applies to products and not to active substances. So, if it can be shown that the repellent is not a skin sensitizer, it should remain outside the scope of EGALIM and self-service sales should be allowed.

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