Our submission to the EU BPR 2026 consultation on pyrethrum derivatives
Mosticare has submitted formal comments to the European Chemicals Agency on the proposed renewal conditions for pyrethrum-based active substances in product type 18 (insecticides, acaricides). We oppose renewal without mandatory residential use restrictions.
title: "Our submission to the EU BPR 2026 consultation on pyrethrum derivatives" date: "2026-04-17" author: "Mosticare Policy" authorRole: "Policy & Regulatory Affairs · Mosticare Foundation" mins: 6 region: "EU" alert: null excerpt: "Mosticare has submitted formal comments to the European Chemicals Agency on the proposed renewal conditions for pyrethrum-based active substances in product type 18 (insecticides, acaricides). We oppose renewal without mandatory residential use restrictions." sources:
- text: "ECHA BPR 2026 Consultation · pyrethrum derivatives PT18 renewal" href: "https://echa.europa.eu"
- text: "EU BPR Regulation (EU) No 528/2012" href: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012R0528"
- text: "Chen et al. 2021 · Pyrethroid inhalation and respiratory outcomes, Respiratory Research" href: "https://doi.org/10.1186/s12931-021-01785-z"
- text: "EFSA 2024 · Conclusion on peer review of pyrethrin active substance" href: "https://doi.org/10.2903/j.efsa.2024.8647" correctionEmail: "corrections@mosticare.org"
On 14 April 2026, Mosticare submitted formal comments to the European Chemicals Agency (ECHA) on the proposed renewal conditions for pyrethrum-derived active substances under the EU Biocidal Products Regulation (BPR), specifically for product type 18 (insecticides and acaricides for use by the general public).
We are publishing the substance of our submission here because we believe stakeholders affected by the outcome, European households, parents of young children, people with respiratory conditions, and the beekeeping community, deserve to know what is being argued, by whom, and on what evidence.
Our position in summary
We oppose renewal of pyrethrum derivatives in PT18 without mandatory restrictions on indoor residential use, specifically:
- Prohibition of aerosol formulations for indoor use in enclosed spaces, existing BPR conditions permit indoor aerosol spraying without residential concentration limits or ventilation requirements.
- Mandatory exposure modelling for children under 12, current EFSA assessment does not include a cumulative residential exposure scenario for young children in rooms where aerosol and coil products are used simultaneously, as they frequently are in southern European households in summer.
- Labelling reform, the current "for domestic use" classification misleads consumers into underestimating inhalation risk. The EFSA 2024 peer review itself acknowledges that the toxicological profile is not consistent with unrestricted indoor use.
The evidence basis
The peer-reviewed literature on pyrethrin respiratory effects has grown substantially since the last BPR review in 2017. The Chen et al. 2021 cohort study in Respiratory Research, the largest to date, found statistically significant associations between residential pyrethroid use and wheeze, bronchial hyperresponsiveness, and early-onset asthma in children aged 2–8, even at exposures typical of "as directed" consumer product use.
EFSA's own 2024 conclusion acknowledges this literature and notes that the acceptable operator exposure level for pyrethrum concentrate is set at 0.025 mg/m³. No equivalent indoor residential air concentration standard exists for household consumer products. The products can be used legally in enclosed rooms with no ventilation requirement, at concentrations that may exceed occupational limits.
This is not a fringe reading of the science. It is the conclusion reached by EFSA itself. We are asking that it translate into regulatory action.
What we are not arguing
We are not arguing that pyrethrins should be banned from all uses. We are not arguing against outdoor use, agricultural use, or professional pest-control use under controlled conditions. We are specifically asking for restrictions on the formulations that European households routinely spray in bedrooms, children's rooms, and kitchens, the uses that produce the highest residential inhalation exposures.
We are also not arguing for chemical-free alternative branding. Mosticare sells a permethrin-treated net, a single, well-chosen active ingredient bound into the fibre. We have an economic interest in physical-barrier products. We are naming that interest explicitly, and we are asking that the submission be weighed on its evidence, not its source.
What happens next
ECHA will compile stakeholder submissions and present a consolidated assessment to the BPR Standing Committee in Q3 2026. If the renewal proceeds without restrictions, existing products remain on market under existing conditions. If restrictions are adopted, Member States have twelve months to implement them.
The full submission text is available from Mosticare's regulatory affairs team at policy@mosticare.org.