From Pantry to Pest Control: How Culinary Ingredients Double as Biocides
As highlighted in the recent HSE Biocides ebulletin, invitations are open for submitting a notification for peanut butter under product type 19 (Repellents and attractants) for anyone wishing to support the substance/product type combination in the GB Review Programme. The deadline for submitting a notification is 14th March 2024.
In the past, it has been argued that peanut butter is not a biocidal product or an active substance and is therefore out of the scope of the BPR, but nonetheless, peanut butter has been notified under the EU biocides review programme. The important differentiation being the difference between a member of the public buying peanut butter to bait a trap and a company selling a trap containing peanut butter as bait. However, despite it being a common foodstuff, the Biocidal Products Committee (BPC) recommended that peanut butter should not be included in Annex I of the BPR (low risk substances) because it can cause allergic reactions, and therefore meets immunotoxic criteria.
Other substances that are unexpected biocides, all under PT19, include: honey, vinegar, cheese, powdered egg, yeast, peppermint oil, and concentrated apple juice. As these can be considered food and feed substances, these are subject to a simplified active substances process under Category A in GB BPR (Category 4, “Traditionally used substances of natural origin” under the EU BPR).
Additional substances you may not immediately consider to be biocides include lemon oil, black pepper extract and skimmed milk powder (again all PT19 repellents and attractants). These substances were subject to the food and feed derogation under the review programme. However, these are now not included under both GB and EU BPR because a compliant notification was not submitted at the declaration of interest/open invitation stage. Brandy is also a PT19 attractant, and although has been notified in the EU, has not been included under GB BPR.
If a notification for peanut butter is not received by HSE by the deadline, this particular active substance/product type combination will be subject to a GB non-approval decision and therefore subject to removal from the GB market. Peanut butter has been notified under EU BPR and is therefore subject to the EU biocide review programme.
As a reminder, it should be noted that GB BPR affects England, Scotland and Wales and decisions made are independent from the EU BPR. The EU BPR continues to apply in Northern Ireland.