Zoono customer info re Trading Standards 11.11.20
Further clarification on Zoono products performance and longevity claims
Following queries raised by Suffolk Trading Standards, Zoono has provided them with details of extensive expert testing, which verify the performance and longevity of our products. The Trading Standards Officers we are liaising with had commissioned their own UK testing, but results were delayed because the laboratories had to close following a number of Covid-19 infections amongst the staff there. We requested that they send the lab our extensive, expert test data to expedite results.
The main issue at the time was the COVID-19 claim which under the BPR/MHRA regulations states a biocidal product cannot name specific pathogens, naming specific pathogens puts the product under the guise of a medical product and therefore would need to be registered as such. This created some confusion due to different regulatory conditions around the world where we are able to make such claims, which in turn prompted some customers of ours here to make COVID-19 claims in their marketing which prompted Trading Standards to raise concerns, this was addressed immediately.
What has actually been asked for in terms of efficacy and longevity was to have our statements ‘fully substantiated’. This is what we have done in terms of the test results we have submitted. Whilst the laboratory commissioned by Trading Standards has yet to respond because of their closure, we have made it clear that given the level of integrity of the laboratories that have already conducted tests, we are in no doubt regarding ‘full substantiation’ – and are making this clear in our sales and marketing activities.
Our appointed verification consultants, KwikChex, have worked closely with Trading Standards Officers across the UK for some years - receiving a ‘Hero Award’ from the Chartered Trading Standards Institute last year. They have also helped us by additionally highlighting that UK government advice for the public on hand sanitisers actually does not even match WHO recommendations. It is their view that we should be urging higher standards and ensuring that the advanced science that makes Zoono products substantially more effective is adopted as a ‘higher tier solution’. We intend to follow this advice and more will be made public soon on this.
Within the last few weeks, we have seen amazingly positive news stories relating to field tests from major customers, including in the UK, and are excited about the story that is emerging. We believe this will elevate the Zoono brand to new heights.
For further clarification around guidelines set out by BPR and MHRA please see below:
HSE Statement
MHRA has advised HSE that antibacterial hand gels and hand sanitisers are not normally considered to be medical devices or medicinal products unless they are specifically surgical scrubs for use in operating theatres or make claims to treat/prevent infection associated with specifically named pathogens. This means that general hand sanitiser products should not name specific pathogens. Claims to treat or prevent infection associated with specifically named pathogens (such as Covid-19) could bring the product within the remit of medicinal products legislation.
REGULATION (EU) No 528/2012 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 22 May 2012 concerning the making available on the market and use of biocidal products
SECTION 2 Information about biocidal products
Article 69
Authorisation holders shall ensure that labels are not misleading in respect of the risks from the product to human health, animal health or the environment or its efficacy and, in any case, do not mention the indications ‘low-risk biocidal product’, ‘non-toxic’, ‘harmless’, ‘natural’, ‘environmentally friendly’, ‘animal friendly’ or similar indications.
Article 72 Advertising
Advertisements for biocidal products shall not refer to the product in a manner which is misleading in respect of the risks from the product to human health, animal health or the environment or its efficacy. In any case, the advertising of a biocidal product shall not mention ‘low-risk biocidal product’, ‘non-toxic’, ‘harmless’, ‘natural’, ‘environmentally friendly’, ‘animal friendly’ or any similar indication.
Please note going forward we will be promoting more heavily, good hand hygiene and cleaning protocols and practices in conjunction with our products technology.
