EU User Categories

The European Commission has published guidance intended to create a common understanding of user categories for anticoagulant rodenticides and to support more consistent implementation of Mutual Recognition (MR) procedures across Member States.

The guidance describes three user categories:

• General Public – occasional, private users with no formal training.
• Professional Users – users applying rodenticides as part of their work activities.
• Trained Professionals – users with additional training, certification or demonstrated competence, including professional pest controllers.

While the guidance aims to support harmonisation, it also acknowledges that Member States may operate different national classification systems. Importantly, it confirms that countries can adapt user categories under Article 37 of the Biocidal Products Regulation (BPR) where justified on the grounds of protecting human health, animals or the environment.

From a Pelgar perspective, this guidance is particularly relevant as we continue to see a growing number of Member States stipulating trained professional user categories during MR applications, even where the reference authorisation contains broader professional user claims.

This development can have a significant impact on product positioning, label development and registration strategy across Europe. Manufacturers and authorisation holders seeking access to multiple European markets will need to consider how national interpretations of user categories may affect product approvals and commercial opportunities, despite the Commission’s efforts to encourage greater consistency across Member States.