Alternative suppliers are manufacturers or importers of active substances who were not involved in the review programme for the active substances under the Biocidal Products Directive and did not contribute to the approval of an active substance, but are benefitting from it by placing the active substance on the market.
Under the BPR, alternative suppliers have to submit to ECHA either a dossier, a letter of access, or if all data protection periods have expired, a reference to an existing dossier. This information should comply with the data requirements of Annex II of the BPR or of Annex II A of the previous directive.
ECHA will be responsible for implementing this provision and will publish a list of those who submitted a file to ECHA. The participants in the review programme will also be added to the list. From 1 September 2015, a biocidal product cannot be placed on the market if the manufacturer or importer of the active substances contained in the biocidal product, or where relevant the importer of the biocidal product, is not included in the list.