IN THIS ISSUE
• Welcome
• Meeting Minutes of General Assembly
• ECA Industry Update: Ethanol Under Substitution Review – Time to Act
• Membership fees and invoices
WELCOME
To our ECA Industry Association Newsletter!
As we, as an industry, move through the BPR regulatory process, many of us have identified the need for an industry association so that our views and concerns can be represented at the highest levels. Today we have better chances to influence than ever earlier. ECA Industry Association was accepted by ECHA to become an Accredited Stakeholder Organization (ASO). As an ASO, we are invited to take part in various working groups, including CLP and BPR legislation development, and to comment on guidelines related to enforcement activities, labelling guidelines and more. As a member you have a chance to get a seat at those meetings and workshops, present our industry and hear the latest developments. You may read more about ECHA ASO matters here: https://echa.europa.eu/about-us/partners-and-networks/stakeholders/echas-accredited-stakeholder-organisations
Board of Directors:
• Ville Sarja, Chairman
• Torben Faurby, Board Director
• Peter Madsen, Board Director
• Philipp Kunze, Board Director
• Tor Wauer, Board Director
• Damien Byrne, Board Director
Meeting Minutes of General Assembly
The General Assembly took place as a Teams meeting on 22 April 2025 at 14:00 CET.
15 member companies were present, including: Portsmouth Aviation, Luna IP, VDH Water Technology, Swiss D&W Technology, Aqualution, TOAF, Innowatech, Briotech, ECA Consortium, KS Natec, HyperDES Watertechnology, Activated Water and Watair.
Torben Faurby was selected as Chairman of the General Assembly and Peter Madsen as Secretary.
The meeting was held according to the association bylaws. Chairman Ville Sarja presented the Chairman’s report, highlighting the approval of the association as an Accredited Stakeholder Organization by the European Chemicals Agency and identifying key focus areas for the future. Future plans include leveraging the ASO role, adjusting membership fees, and initiatives like ethanol replacement, defence sector involvement, and energy performance improvements.
The Chairman’s report was accepted and adopted.
Peter Madsen presented the budget with a profit of €3,400. Members discussed membership fees; the final decision was to set the membership fee at €500 with an option for smaller companies to pay €200 as associate members. The Board may decide detailed criteria for membership fee alternatives, and invoices will be sent in May 2025.
The existing six board members were re-elected:
• Damien Byrne
• Tor Wauer
• Ville Sarja
• Phillip Kunze
• Peter Madsen
• Torben Faurby
Torben Faurby and Damien Byrne were elected as Auditors.
A data protection concern under Articles 59.5 and 60 of the BPR was raised, and it was agreed that ECA Industry Association will contact ECHA regarding revision of those articles.
The General Assembly accepted discharge of liabilities to the Board.
ECA Industry Update: Ethanol Under Substitution Review – Time to Act
In a move that may reshape the disinfectant formulation landscape in Europe, ECA Industry Association, together with the ECA Consortium, formally submitted its response to the European Chemicals Agency (ECHA)’s public consultation on ethanol as a potential substitution candidate under the Biocidal Products Regulation (BPR). This comes as ECHA’s Biocidal Products Committee (BPC) classified ethanol in October 2024 as meeting exclusion criteria due to suspected carcinogenicity and reproductive toxicity (Category 1A/1B), with ongoing evaluation of mutagenicity. The Analysis of Alternatives (AoA) is in progress; the consultation ended in April 2025, and a Commission decision is expected in 2026.
This matters because ethanol is widely used in hand and surface disinfectants. Its regulatory challenges may open the door for broader adoption of alternatives with strong safety and efficacy profiles, like hypochlorous acid (HOCl).
What Could Happen Next?
• Possible regulatory restrictions on ethanol-based products, especially in healthcare or consumer settings.
• Stricter compliance requirements for continued ethanol use.
• Increased demand for alternatives with lower health and environmental risks.
• Market shifts as procurement guidelines prioritise non-alcoholic disinfectants.
A Call to Readiness
ECA Industry Association urges members, especially those developing or distributing HOCl-based products, to take action:
- Review product portfolios and identify where ethanol formulations may need substitution.
- Prepare technical dossiers and performance data supporting HOCl as a viable alternative under BPR.
- Engage regulatory affairs experts to ensure readiness for evolving compliance.
- Monitor procurement trends and communicate with affected clients.
ECA Industry Association will continue coordinating industry dialogue, advocating for fair, science-based evaluations, and supporting members in navigating this transition. Stay tuned for upcoming webinars and technical guidance.
Membership fees and invoices
As decided in the General Assembly, invoices for membership in 2025 will be sent out soon. The membership fee for 2025 is €500.
Thank you for taking time to read our newsletter.
On behalf of the ECA Industry Association board,
Ville Sarja
Chairman