The recent European Commission proposal to class monitoring traps (that contain attractants) as biocides sent shockwaves through public health pest control, the food industry and the museums / conservation sector.
If the UK Health and Safety Executive were to accept the proposal, these products would have been lost from the pest control market imminently. Such products would have needed to go through a very long and costly approval process. Companies manufacturing such devices may not have been willing to invest in gaining expensive authorisations, as the economic return may well not justify the costs for ‘niche’ products.
Fear not, as common sense has prevailed and HSE will not insist on insect monitors requiring authorisation.
The HSE position is:
Traps purely for monitoring purposes to assess the necessity for, or success of, pest management measures, clearly labelled, sold and used as such, are not within scope of the EU Biocidal Products Regulation 528/2012, and so do not require authorisation in order to be placed on the UK market.
Such traps should be labelled and marketed to make it clear to the user that the trap is purely for monitoring purposes and should not make any claims or inferences that it could be used as a biocidal product, e.g. claims to reduce/control/kill the pest insect, or images such as dead insects. To help avoid potential confusion, we would advise that such traps should clearly indicate they are for monitoring purposes in the product name, e.g. Insect Monitoring Trap, Fruit Fly Monitoring Trap, or similar indications.
Traps intended for use beyond purely monitoring, such as those intended to help to reduce the insect population/to control the pests/for mass trapping, may be considered to be being marketed primarily for biocidal purposes and may therefore be regulated as biocidal products.
Note that traps which do not contain a pheromone, other attractant or other biocidal active substance, and that capture insects on a sticky surface simply by random ‘chance’ may be considered to be acting by merely physical means and would therefore not fall within the scope of the Biocidal Products Regulation.
This is the UK Biocides Competent Authority’s position on this matter; other EU Member States may hold a different opinion and companies should seek advice from a Member State’s Competent Authority before making a monitoring trap available in that Member State.