Subject: Applications under BPR Transitional Rules
From: "Adam Thickett" <[email-masked]>
To: <[email-masked]>
Cc: "Hayley Lewis" <[email-masked]>, "Aiden Robertson" <[email-masked]>
Date: Tue, 5 May 2026 18:47:05 +0300

Tähelepanu! Tegemist on väljastpoolt asutust saabunud kirjaga. Tundmatu 
saatja korral palume linke ja faile mitte avada.

To whom it may concern,

We are working with a client who is interested in registering a biocidal 
product under Estonian transitional regulations. The active substances are 
currently under evaluation for approval within the EU BPR Review Programme 
but we have one question we would like to understand before we proceed with 
preparing the application form.

If aa product contains active substances which have been granted an approval 
decision by the BPC but for which the active substance approval start date 
has not yet been reached, can the applicant still seek an approval to market 
under Estonian transitional rules? If so, is there a deadline before the 
approval start date to submit these applications or can this be done up to 
the approval start date (providing a BPR authorisation application is also 
submitted prior to this date for the same product)?

We would appreciate any information you can provide in this regard to help 
with our clients decision making.

Many thanks and best regards.

Adam Savins Thickett (He/Him)
Regulatory Consultant
Yordas Group
My working days are Mon-Fri

t: +441612506199
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