„Please note that, as of 1 September 2015, biocidal products may only be made available on the market if either the substance supplier or the product supplier is included in the list of active substance suppliers (Article 95 BPR). This also applies for biocidal products that are marketed during the transitional period in Germany. It is currently not necessary to provide a confirmation of the active substance supplier for notified biocidal products during the transitional period in Germany at BAuA. However, for biocidal products during the transitional period, compliance with Article 95 will be controlled by the local enforcement authorities. On request, you then will have to provide the corresponding information to the local enforcement authorities.” [Reach-CLP-Helpdesk Art. 95 Liste]
The aquagroup AG has been included as substance supplier and product supplier on the Art. 95 list by ECHA. This list is updated regularly and is available on the website of the European Chemicals Agency (ECHA) free of cost. http://echa.europa.eu/de/information-on-chemicals/active-substance-suppliers
NADES and NADES 2.0 are registered for PT 1-5 and PT 11 at BAuA, BfR and UBA and therefore marketable until the final decision by ECHA regarding the approval of sodium hypochlorite as “active substance”. Of course, this applies in combination with the inclusion in the Article 95 list.
In case of the in-situ production of NADES 2.0 salt (NaCl) is considered to be the relevant biocide product. Therefore please use only approved salt (NaCl) to operate the generator and purchase it only from suppliers that are listed by ECHA on the Art. 95 List. Since many of the suppliers are wholesalers or small businesses and only resell the salt, ECHA has left open the possibility that in this case the original manufacturer has to be on the list.
Ask your salt supplier, whether the manufacturer of the salt has been included on the Art. 95 list.
We advise you to remove products from non-listed suppliers from your portfolio.