Deep Blue Pool Supplies
EU Biocide Registration Consultant
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Job Title
Company Overview
Deep Blue Pool Supplies is a UK-based manufacturer and retailer of swimming pool and spa water treatment chemicals. We sell across our own websites and the Amazon European marketplaces. We are expanding our European operations and require a specialist regulatory consultant to obtain national biocide authorisations for our chlorine product range.
The Role
We are looking for an experienced EU biocide regulatory consultant to manage and submit national marketing authorisation applications for three swimming pool disinfectant products across five EU member states, together with the supporting Poison Centre Notifications and efficacy testing programme. You will take full ownership of each country application, from data gap analysis through submission and authority liaison to final authorisation, working directly with our team.
Products
- SDIC Granules
- Active substance: Sodium dichloroisocyanurate dihydrate
- CAS: 51580-86-0
- Stabilised Chlorine Tablets 20g / 200g
- Active substance: Symclosene (trichloroisocyanuric acid, TCCA)
- CAS: 87-90-1
- Multifunctional Tablets 20g / 200g
- Active substance: Symclosene (TCCA) with copper sulphate pentahydrate, aluminium sulphate and boric acid
- CAS: 87-90-1
Both active substances are included in the EU BPR Review Programme under Commission Delegated Regulation (EU) No 1062/2014, under IIAHC notifications [N456]A (Symclosene) and [N455]A (sodium dichloroisocyanurate dihydrate). Our active substance supplier is listed on the ECHA Article 95 list for both substances for PT2.
Scope of Work
1. National Registrations
Prepare and submit transitional national authorisation applications under Article 89 of Regulation (EU) No 528/2012 for three products in the following countries:
| Country | Authority and Route | Notes |
|---|---|---|
| Spain | Ministerio de Sanidad | Priority. ES/MR number required. ENAC accredited efficacy and analysis data required. |
| Italy | Ministero della Salute, PMC registration | |
| Belgium | FPS Public Health, Gestautor | Bilingual French and Dutch labelling. |
| Poland | URPL | Polish labelling and sworn translations. Efficacy methods must follow EN or Polish norms or be separately recognised. |
| Netherlands | Ctgb, WGB transitional dossier | Most complex. Full or limited assessment to be determined. Dutch WG/GA and labelling. Possible IIAHC Letter of Access requirement. |
2. Efficacy Testing Programme
Our manufacturer holds no efficacy test data and has not submitted any to the BPR process. Efficacy data is required for Spain, Italy, Netherlands and Poland. The consultant will:
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- Define the testing strategy for each product in line with the ECHA Efficacy Guidance for PT2, expected to include suspension tests, simulated use tests and field tests.
- Identify and obtain quotations from suitable accredited laboratories, including ENAC accredited laboratories where Spain requires it.
- Advise whether one test set can serve all target countries and whether the two TCCA based products can share data.
- Act as study monitor during testing and review the resulting reports for regulatory adequacy.
3. Poison Centre Notifications
Prepare and submit PCN dossiers via the ECHA submission portal and IUCLID for three products across Germany, France, Sweden, Spain, Netherlands, Belgium, Poland and Italy. Ireland is already notified and UFI codes are assigned.
4. Supporting Compliance Work
- Data gap analysis for each product against each country's requirements, delivered as a written report.
- Review of the English language SDS and of the eight translated label variants for BPR and CLP compliance.
- Advise on and, where possible, obtain a Letter of Access to the IIAHC active substance dossier. Our previous route through a former IIAHC consultant is no longer available.
- Reporting to the Swedish Products Register.
- Provide authorisation numbers and compliant wording for upload to our Amazon EU listings as each registration is granted.
- Advise on whether an EU established applicant or representative is required in any country, and on options if so.
Responsibilities
- Review existing documentation and produce a written data gap analysis per product per country.
- Produce a strategy report covering requirements, authority fees and realistic timelines for each country.
- Define and manage the efficacy testing programme, including laboratory selection and study monitoring.
- Prepare complete application dossiers compliant with each national authority's requirements.
- Submit applications and manage all correspondence with authorities through to final decision.
- Coordinate with our manufacturer to obtain formulation data, certificates of analysis and raw material safety data sheets.
- Provide written progress updates at least fortnightly and flag risks early.
- Hand over complete records, submission references and authorisation certificates on completion.
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Essential Requirements
- Demonstrated experience preparing and submitting biocidal product applications under Regulation (EU) No 528/2012 in at least two of the five target countries.
- Working knowledge of national transitional procedures under Article 89 BPR.
- Familiarity with PT2 disinfectants and the associated efficacy testing requirements, for example EN 1276, EN 1650 and EN 13623.
- Experience preparing PCN dossiers in IUCLID and submitting through the ECHA portal.
- Ability to prepare or coordinate multilingual label and SDS requirements.
- Available to start within four weeks.
Desirable
- Background in pool, spa or water treatment chemistry.
- Direct experience of Gestautor, Ctgb, URPL or Italian PMC submissions.
- Knowledge of IIAHC dossiers for chlorinated isocyanurates and Letter of Access procedures.
- Established relationships with accredited efficacy testing laboratories.
- Understanding of mutual recognition for extending authorisations to further member states.
What We Provide
- Translated product labels for target countries.
- English and EU language safety data sheets for all three products.
- ECHA Article 95 listing evidence for our active substance supplier.
- Existing German, French and Irish registration documentation and UFI codes.
- Direct contact with our manufacturer for formulation data and certificates.
- Payment of all authority fees, laboratory fees and translation costs on top of your fee.
Commercial Terms
| Item | Detail |
|---|---|
| Engagement | Contract or freelance, outside IR35, invoiced monthly |
| Location | Fully remote |
| Duration | 6 to 18 months depending on authority timelines |
| Rate | Competitive, based on experience. Day rate or fixed project fee both considered |
| Excluded from your fee | Authority fees, laboratory testing costs, sworn translations, any local agent fees |
How to Apply
Please apply with a brief covering note setting out:
- Your experience with biocide registrations in each of the five target countries.
- Examples of comparable projects completed, with outcomes and timelines.
- Your approach to the efficacy testing question given that no data currently exists.
- Your day rate or a fixed project fee, broken down by country where possible.
- Your availability to start.
Applications without relevant biocide registration experience will not be considered.
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