Products for non-professional use
There are specific requirements regarding the plant protection products which are intended for non-professional users, and regarding the packaging of these products. These requirements are described in detail in this guidance document.
A plant protection product cannot be authorised for non-professional use if it is classed as one or more of the following hazard classes and categories:
- Self-reactive substances and mixtures
- Self-heating substances and mixtures Cat. 1
- Organic peroxides (Type A/B/C/D/E/F)
- Flammable gas Cat. 1 + Cat.2
- Flammable liquids Cat. 1
- Flammable solids Cat. 1
- Acute toxicity Cat. 1 + Cat. 2 + Cat. 3
- Skin corrosion Cat. 1,
- Carcinogenicity Cat. 1A/B
- Germ cell mutagenicity Cat. 1A/B
- Reproductive toxicity Cat. 1A/B
- Specific target organ toxicity STOT SE 1 + STOT RE 1
Moreover, the assessment of exposure to non-professional users is carried out using more stringent model parameters than those used for professional users. The model used in Belgium is the EFSA model in which the only clothing worn by the user is a T-shirt, shorts, sandals and gloves (this concerns a worse-case situation which is however not to be recommended). A plant protection product is not authorised for non-professional users if the exposure assessment reveals that other protective equipment, like additional clothing or respiratory protective equipment, must be worn to achieve an acceptable level of risk.
Moreover, adjuvants, which make it possible to promote the functioning of the plant protection product, are not authorised for non-professional use.
For every other plant protection product which is intended for non-professional use, the following aspects are examined:
- the packaging,
- the formulation and
- the method of application.
The level of exposure for non-professional users and the environment must be acceptable.
Requirements regarding packaging
For the packaging of plant protection products which are intended for non-professional users, the following elements must be observed (see checklist):
- treatment of an area of max. 5 are,
- a closure cap for bottles,
- a safety system for aerosols (e.g., of the type on/off),
- packaging which can be closed repeatedly for solid formulations (if not sold in bottle form, provide with e.g. a sticker, clasp, etc.)
Depending on the risk which is related to the product, various types of packaging may be imposed. Liquid formulations must be sold in a bottle which can be completely emptied with ease. For all the other types of packaging of the product, a derogation may be granted based on the reasoning of the applicant.
- The contents of the packaging of the products which are available in mono-doses (e.g. WG in water-soluble bags) must be adapted to the area which will be treated in order to avoid such bags being opened and not completely used, whereby there is a higher risk that the product will escape into the environment.
- A measuring system must be provided with the packaging of liquids (only liquids which need to be diluted) or products which are sold in powder or pellet form, in order to facilitate accurate and straightforward dosing. The measuring system should have gradations, whereby quantities of product can be measured out in 2 times, which correspond with realistic treatment surfaces in gardens for amateur users. The units of the measurement system will need to be adapted to the physical form of the product (gradations in millilitres for liquid formulations and in grams for solid formulations).
- In the case of a solid formulation which is combined with a measurement system with gradations in millilitres, a conversion factor can nonetheless be accepted. The conversion must be indicated for each use. For example: lawn: 20 g/10 m² (20 g = 35 mL in the measurement system). This is not necessary for products which, for example, are sold in water-soluble bags or in tablet form.
The authorisation numbers (which must be indicated on the label) for these products clearly differ from the authorisation numbers for products for professional use. They are given XXXXG/B numbers, while products for professional use are given XXXXP/B numbers. This differentiation is a form of protection to avoid that products for professional use might be sold to non-professional users.
A product which is authorised for professional use may not be offered for free, cannot be sold, and cannot be used by a non-professional user.