Key takeaways
- In the EU, insect repellents are biocidal products (product-type 19) regulated by the Biocidal Products Regulation (EU) No 528/2012, known as the BPR.
- Approval happens in two steps: first the active substance is assessed and approved at EU level, then each finished product is authorised before it can be sold.
- Many active substances are still in the EU Review Programme. Until a decision is made, repellents containing them are sold under each country’s transitional national rules.
- An authorised product carries an authorisation number on the label, together with the active substance, its concentration and instructions for use.
- EU law also controls advertising: every repellent advert must say ‘Use biocides safely. Always read the label and product information before use.’
When you pick up a mosquito spray in a European pharmacy, you are holding one of the most tightly regulated products on the shelf. EU biocide approval is the process that decides which repellent ingredients may be used, which finished products may be sold and what they are allowed to claim. Here is what the system actually checks, what the words on the label mean and why two repellents on the same shelf can be at different stages of the process.
Why insect repellents count as biocides
EU law defines a biocidal product as anything intended to destroy, deter, render harmless or control a harmful organism by more than physical or mechanical action. A repellent deters mosquitoes and ticks with a chemical active, so it falls under the BPR rather than cosmetics law — even though you apply it to your skin like a lotion.
The BPR sorts biocides into 22 product-types. Insect repellents applied to skin, clothing or the air belong to product-type 19 (repellents and attractants), alongside products that lure pests into traps. This classification matters: a cream sold to ‘keep mosquitoes away’ is a biocide by law, whatever shelf it sits on.
The two-step EU approval process
Step 1: approving the active substance
Before any product can be authorised, its active substance must be approved for that product-type. A company submits a dossier on the substance’s chemistry, toxicology, effects on the environment and efficacy. One Member State acts as the evaluating authority, the European Chemicals Agency (ECHA) and its Biocidal Products Committee give an opinion, and the European Commission then adopts the decision for the whole EU.
Approval is not permanent. Active substances are typically approved for up to ten years and must then be renewed against current science.
Step 2: authorising the finished product
Once the active is approved, every product that contains it needs its own authorisation. The applicant must show that the specific formula — at its concentration, in its spray, lotion or roll-on format — works as claimed and is acceptable for people, animals and the environment when used as directed. Authorisation can be granted:
- nationally, by the authority of one Member State;
- by mutual recognition, where other countries recognise that first authorisation;
- as a Union authorisation, valid across the EU for suitable products.
The authorisation holder must be established in the EU and is responsible for the product on the market.
What ‘under review’ and transitional rules mean
When the BPR system started, thousands of substance and product-type combinations were already in use. Rather than banning them overnight, the EU created the Review Programme, which assesses these ‘existing’ active substances one by one. It is currently scheduled to run until the end of 2030.
While a substance is still in the programme, Member States may keep applying their own national rules to products containing it (Article 89 of the BPR). In practice that often means a national notification or registration — for example, Germany gives notified biocides a registration number beginning with ‘N-’. Rules differ from country to country, which is why a product can be on sale in one Member State and still waiting for paperwork in another.
Once the EU approves the active substance, the clock starts: companies must apply for full product authorisation within a set deadline. If the substance is not approved, products containing it have to leave the market after a phase-out period.
This applies to familiar actives too. DEET, icaridin (picaridin) and IR3535 are already approved for product-type 19, while a number of plant-derived actives are still being evaluated. We explain how the main ingredients compare in picaridin vs PMD vs DEET.
How to read approval status on a repellent label
| What you see | What it means | What to check |
|---|---|---|
| EU or national authorisation number | The finished product has been assessed and authorised | That the number matches the country of sale |
| National registration number (e.g. ‘N-’ in Germany) | Sold under transitional rules while its active is in the Review Programme | The active substance and its concentration |
| Active substance and concentration | Required on every biocide label | That it matches the protection time and pests claimed |
| Instructions, age limits and precautions | Conditions under which the product was assessed | Follow them exactly — especially for children |
| ‘Natural’, ‘non-toxic’ or ‘harmless’ on a repellent | Wording the BPR does not allow in biocide advertising | Treat it as marketing, not as a safety assessment |
If you want a deeper walk-through of actives, concentrations and claims, our guide to what PMD (Citrepel®) is and how it repels insects explains how one active substance works from the lab to the label.
Why the BPR restricts certain words
Article 72 of the BPR sets rules for advertising biocides. Every advert must include the sentence ‘Use biocides safely. Always read the label and product information before use.’ Adverts must not be misleading about risks or efficacy, and they must not describe a biocide as ‘low-risk’, ‘non-toxic’, ‘harmless’, ‘natural’, ‘environmentally friendly’ or ‘animal friendly’, or use similar wording.
The logic is simple: a repellent is designed to have a biological effect, so the law wants buyers to judge it by its assessment and label, not by reassuring adjectives. For you as a shopper, this is useful — the most reliable information about any repellent is the active substance, the concentration, the pests it is tested against and the directions for use.
What EU approval does not tell you
- It is not a ranking. Approval means a product meets the requirements; it does not say one repellent is better than another.
- It does not replace the label. Protection times, target pests and age limits are specific to each product and format.
- It does not cover travel advice. For destinations with malaria, dengue or other mosquito-borne diseases, follow ECDC, WHO or travel-clinic guidance as well.
How incognito® helps
Our repellents are DEET-free and use PMD (Citrepel®), an active derived from Java citronella (Cymbopogon winterianus). Under EU biocide law it is assessed as ‘Cymbopogon winterianus oil, fractionated, hydrated, cyclized’, an active substance currently being evaluated in the EU Review Programme for product-type 19 — the same process described above.
Our Insect Repellent Spray is clinically proven, recommended against mosquitoes and ticks and vegan. For families, the Kids Insect Repellent Spray is formulated for children — check the label for the minimum age and how often to apply. Use biocides safely. Always read the label and product information before use.
FAQs
Are insect repellents regulated in the EU?
Yes. Insect repellents are biocidal products of product-type 19 under the Biocidal Products Regulation (EU) No 528/2012. Their active substances must be approved at EU level and finished products must be authorised, or sold under national transitional rules while the active is under review.
What does it mean when a repellent is authorised?
It means the finished product, at its specific concentration and format, has been assessed for efficacy and for risks to people, animals and the environment when used as directed. The authorisation number appears on the label.
Can a repellent be sold before its active substance is approved?
Yes, if its active is in the EU Review Programme. Until the EU decides, Member States may apply their own national rules, which often require a notification or registration. Rules and numbers vary by country.
Is DEET approved in the EU?
Yes. DEET is approved for product-type 19, as are icaridin (picaridin) and IR3535. Several plant-derived repellent actives, including the one in PMD (Citrepel®), are still being evaluated.
Why can’t repellents be advertised as natural or non-toxic?
Article 72 of the BPR bans terms such as ‘natural’, ‘non-toxic’, ‘harmless’ and ‘environmentally friendly’ in biocide advertising, because they can understate risks. Shoppers should rely on the active substance, concentration and label directions instead.
Where can I check a repellent’s approval status?
Start with the label: the authorisation or registration number, the active substance and its concentration. The European Commission and ECHA publish information on approved active substances and authorised products, and national authorities keep their own registers.
Sources
- European Commission — Biocides: overview of the regulatory framework
- European Commission — Biocides: active substances and the Review Programme
- European Commission — Biocides: authorisation of biocidal products
- ECDC — Protective measures against mosquitoes
- CDC — Preventing mosquito bites
- EPA — Skin-applied repellent ingredients
This article is for general information only and is not legal or medical advice. Regulatory status can change and differs between countries; always check the label of the product you buy. If you are travelling to an area with mosquito-borne disease, talk to your doctor or a travel clinic.