The intended use of biocides is to kill, to destroy or to deter living organisms. Undesirable effects on environment and health are thus likely to occur. This is true even if products are authorised, because the aim of the authorisation procedure is for every single product to keep these effects below an unacceptable level, not to eliminate the effects as a whole. The same rationale underlies the Directive 2009/128/EC on the sustainable use of pesticides. Therefore this Directive provides a frame for sustainable overall use of pesticides, complementing the authorisation of individual products according to the Regulation (EC) No 1107/2009 concerning the placing of plant protection products on the market. From our point of view, a comparable approach aiming at reducing risks from the use of biocides is appropriate for biocides, too. The Federal Environment Agency of Germany (UBA) conducted two research projects for further elaborating the approach1. This position paper contains the conclusions which UBA draws from these research projects and the corresponding discussions over the last six years. The objective of this paper is to provide the European Commission with our conclusions and to encourage their consideration in the context of the upcoming report required according to Article 18 of regulation (EU) No 528/2012. Corresponding to the competence of the Federal Environment Agency, the proposals focus on the environmental aspects of the use of biocides.
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