The regulatory status of Geraniol is evolving
In the interest of transparency and to keep all our partners informed, BREYNER would like to provide an update on the current regulatory status of geraniol within the European Union.
As an official supplier of geraniol listed under Article 95 of the European Union’s Biocidal Products Regulation (BPR), and as the dossier holder, we closely monitor regulatory and administrative developments relating to this active substance.
Incorrect and sometimes even contradictory information is currently circulating regarding the status of geraniol and the possibility of continuing to place products containing it on the market. We therefore believe it is important to distinguish established regulatory facts from potential misinterpretations.
Key Milestones to Remember
On 5 June 2025, ANSES informed us that the deadline for completing the requested studies had not been met on our part and notified ECHA accordingly.
On 2 July 2025, ECHA published an update to its “Notifications List”, indicating that the Geraniol dossier had not been taken over within the prescribed timeframe.
On 22 August 2025, ECHA announced that subcategories would be created within the BPR Article 95 list to better reflect the status of several substances, including Geraniol, pending a decision by the European Commission.
At this stage, the regulatory status of Geraniol therefore remains subject to ongoing developments and does not, in itself, constitute a decision not to approve the substance. The transitional provisions set out in Article 89(2) of the BPR remain applicable pending the European Commission’s final decision.
ANSES indicated that certain data required for the Geraniol dossier had not been received by the deadlines it had set, a fact that we did not dispute, and characterised this situation as a procedural failure. ANSES specified that it had informed ECHA accordingly. As a result, the dossier thereafter fell exclusively under the remit of the European Commission.
Throughout 2024, however, we regularly kept ANSES informed of the progress of the dossier and of the difficulties involved in meeting the original deadline of the end of December 2024, particularly given the complexity of the requested studies and the unavoidable time required to complete them. Despite these communications, we did not receive a clear response from ANSES.
This situation therefore concerns a purely administrative and scheduling issue, rather than an unfavourable scientific conclusion regarding geraniol.
Furthermore, there is considerable confusion among some market participants regarding the applicable regulatory frameworks. The date of 30 April 2026 referred to in Commission Implementing Regulation (EU) 2023/1757 concerns the plant protection products sector (https://eur-lex.europa.eu/eli/reg_impl/2023/1757/oj/eng) and does not apply to the BPR procedure governing biocidal products.
This distinction is essential to understanding the regulatory status of geraniol in the biocidal products sector.
It should also be noted that, as of 30 April 2026, plant protection products containing geraniol as an active substance had received approval for placing on the market.
What Is the Current Situation?
The key point is as follows:
To date, no formal decision has been adopted by the European Commission to terminate the approval of geraniol under the BPR.
On 10 November 2025, within the applicable statutory time limits, we initiated legal proceedings against ANSES concerning procedural matters relating to the Geraniol dossier. The dossier is therefore currently before the competent French court. A ruling may be issued, but, based on practical experience with case law, the timeframe is more likely to be measured in years rather than weeks or months.
In early 2026, this situation was reflected in updates to the BPR Article 95 list published by ECHA, which included a note indicating that ongoing litigation could affect the dossier’s withdrawal status.
Pending this decision, geraniol remains usable for Product Types 18 and 19 (PT18 and PT19) under the BPR, in accordance with the information communicated by ECHA and the European Commission.
It is therefore important not to automatically equate:
“Procedural difficulties relating to the dossier” with “a definitive ban on geraniol”!
These two situations are not equivalent.
As of today, the approval procedure for geraniol under the BPR has not been definitively concluded by a non-approval decision issued by the European Commission.
Furthermore, work on the geraniol approval dossier is ongoing, and its preparation has not been suspended.
Our Commitment
We are fully aware of the responsibility borne by European and national authorities for protecting human health and the environment. We fully share these objectives and continue our work within this framework.
Geraniol remains an active substance of strategic interest to the market, particularly in view of its properties and performance (including with regard to humans, bees, etc…).
We will continue to closely monitor regulatory developments and keep our partners informed in a transparent, factual and up-to-date manner, as we have always done.
In Summary
✔ Geraniol remains authorised on the EU market for use in Product Types 18 and 19 (PT18 and PT19) until further notice.
✔ The regulatory status of the Geraniol dossier is currently evolving.
✔ Legal proceeding is ongoing.
✔ The European Commission remains the only competent authority responsible for making a decision on approval at EU level.
✔ The European Commission has indicated that it is awaiting the outcome of the legal proceedings before taking a decision.
✔ To date, no formal decision not to approve geraniol under the BPR has been adopted.
✔ It is important to distinguish between the regulatory framework governing biocidal products (BPR) and that governing plant protection products.
✔ We continue to work on preparing and finalising the approval dossier.
✔ Our objective: to provide you with clear, factual information on the status of geraniol and the evolution of its regulatory framework.
✔ If you wish, we would be pleased to support you in formulating geraniol-based products to optimise their performance. We have developed specific patented expertise in this area.
✔ Please do not hesitate to contact us if you require any further clarification or additional information regarding this dossier.