Biocidal Products Regulation (BPR) Compliance Update – May 2025

Understanding Article 95: What’s Changed and Why It Matters

From March 2025, a pivotal shift in UK regulations took effect: any company wishing to supply biocidal products must now either appear on the UK Article 95 list or source their active substance – particularly in the case of hypochlorous acid – from a listed entity.

This isn’t just bureaucratic housekeeping. It’s about ensuring that products used in sensitive, often critical environments meet the highest standards of safety, traceability, and efficacy. And those standards begin with the source.

Aqualution’s Position: At the Core of Compliance

At Aqualution, we’ve always believed that regulatory excellence is not a formality – it’s a responsibility. As the original data submitters to the HSE for hypochlorous acid (active chlorine released from HOCl), we are officially listed on the UK Article 95 register.

This status gives us more than permission. It positions us as a key enabler for the wider industry. Any company aiming to be legally compliant must either hold their own data package or secure a valid Letter of Access from us.

We take that role seriously.

A Narrowed Field: What the Numbers Say

Back in June 2021, we submitted our dossiers for GB BPR. Fast forward to March 2025, and just ten companies – including Aqualution – are authorised to supply hypochlorous acid as a biocidal active in the UK.

That’s a significant contraction. The result is a leaner, more tightly regulated space. For customers and partners, it also means clarity: you know where your HOCl is coming from – and who stands behind it.

A Dual Commitment: GB and EU Compliance

We continue to maintain alignment with both GB and EU Biocidal Products Regulations. Aqualution owns the approved dossiers for the EU market and has received formal confirmation from the HSE that our UK dossiers are complete and under review.

The process is rigorous – as it should be. But it’s one we are fully prepared for. It’s the space we’ve chosen to lead in.

What This Means for You

If you’re a brand or manufacturer navigating this landscape – especially in the hypochlorous acid category – compliance isn’t optional. And while it may seem complex, the path is clearer with the right partner.

We’re here not just to inform, but to support. Whether you need clarity on the Article 95 process or hands-on guidance through regulatory submissions, we’re ready to help.

Because for us, HOCl isn’t just a product. It’s a science. It’s a standard. And it’s a promise.

Need Guidance on Article 95 or EU BPR?

Whether you’re uncertain about your compliance status or preparing to enter the regulated biocidal market, Aqualution offers precise, science-backed support.

Get in touch with our regulatory team to discuss your specific requirements.