All you need to know about Aircraft Disinsection in the EEA

We receive many questions concerning aircraft disinsection, mostly from within the EU, as complex requirements and legislation meet here on different fronts. In this article, we will be strongly focusing on the options and try to answer all questions concerning correct aircraft disinsection in the European Economic Area (EEA). 

Important: These regulations are all applicable to airlines from the EEA and international airlines flying into the EEA. The World Health Organization clearly specifies that spray cans should be compliant with the regulations in the country of both flight departure and arrival.

The EEA consist of the 27 EU Member States* + Iceland, Norway and Switzerland.

*Austria, Belgium, Bulgaria, Croatia, Republic of Cyprus, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.

First and foremost: The most recent World Health Organization recommendations can always be found on the official WHO website. It is advised to always check the official website to make sure you are consulting the most recent recommendations.

Note: The WHO does not authorize aircraft insecticides. This is a common misconception. However, they are currently compiling an official 'List of Vector Control Products'. This is in the prequalification phase and Aero-Sense is of course involved in the process. 

The role of the WHO in aircraft disinsection is mainly that of an advisory body. They gather expert panels and industry stakeholders on a regular basis in their Geneva headquarters, where they hold stakeholder meetings and expert sessions. This may result in an update or even an entirely new version of their "WHO aircraft disinsection methods and procedures".

Note: Aero-Sense is of course always present at these meetings!

In these recommendations, the WHO specifies which active substances should be used in aircraft disinsection products, which product formulations should be used and which procedures should be carried out. It also includes how much product is needed, depending on the volume to be disinsected. 

WHO recommended active substances

There are only two active substances that are WHO recommended for use in aircraft insecticides:

• 1R-trans phenothrin = d-phenothrin (different names for the same active substance)
• Permethrin

There are products being used as aircraft insecticides that contain other (extra or alternative) active substances. This is regularly done to circumvent the European Biocidal Products Regulation and the long, expensive authorization procedure for an EU product approval. However, if the product contains any other active substance, it is no longer in line with the WHO recommendations. Using these types of product is to be avoided at all costs.

WHO recommended product formulations

Only four product formulations (based solely on the two recommended active substances) are WHO recommended for aircraft disinsection:

• A 2% w/w 1R-trans phenothrin based aerosol 
• A 2% w/w 1R-trans phenothrin + 2% w/w permethrin based aerosol
• A 2% w/w permethrin based aerosol
• A 2% w/w permethrin based emulsifiable concentrate

However, only the first option is possible in the EU. The other three have formulations that contain the active substance permethrin, but permethrin based aircraft insecticides cannot be authorized under the European Biocidal Product Regulation. They do not pass the necessary risk assessments. As a concrete result, there are no products legally available in the EU that conform with WHO recommendations to perform residual disinsection. More detailed info on the European Biocidal Product Regulation can be found below.

WHO recommended disinsection procedures

With the use of these four different product formulations, the WHO recommends several different possible disinsection procedures:

• Pre-embarkation (single flight sector) cabin disinsection with a 2% m/m permethrin based aerosol
• Pre-departure (single flight sector) cabin disinsection with a 2% m/m 1R-trans phenothrin based aerosol
• Pre-departure (single flight sector) cargo disinsection with a 2% m/m 1R-trans phenothrin based aerosol
• Pre-departure (single flight sector) cargo disinsection with a 2% m/m 1R-trans phenothrin + 2% permethrin based aerosol
• Residual (long term) cabin disinsection with a 2% w/w permethrin based emulsifiable concentrate
• Residual (long term) cargo disinsection with a 2% w/w permethrin based emulsifiable concentrate

However, as mentioned earlier, from these procedures, the options are limited for airlines in the EEA. All procedures requiring a product containing the active substance permethrin are off the table. This leaves only two options:

• Pre-departure (single flight sector) cabin disinsection with a 2% m/m 1R-trans phenothrin based aerosol
• Pre-departure (single flight sector) cargo disinsection with a 2% m/m 1R-trans phenothrin based aerosol

Pre-departure cabin disinsection involves aerosol spraying of the aircraft cabin after passenger embarkation but before the overhead lockers are closed and the aircraft is pushed back for departure. 

Pre-departure cargo disinsection involves spraying manually at the last departure airport after all cargo has been loaded and just before the cargo door has been closed. 

The fact that cargo disinsection can also be carried out with a 2% m/m 1R-trans phenothrin based aerosol instead of a combination aerosol containing both active substances is a concession by the WHO in the most recent revision of their recommendations. The reason is very specifically because of the non-availability of permethrin based aircraft insecticides to EEA airlines.

Note: there is one other WHO approved disinsection procedure, called the 'on-arrival' treatment. The on-arrival treatment is also a single flight sector disinsection procedure carried out with a 2% m/m 1R-trans phenothrin based aerosol. However, this is a back-up procedure, which is only to be carried out by (Port Health) Authorities, if aircraft disinsection has not been (correctly) performed while it is required at destination. Airlines should never plan on this contingency procedure. 

Since the product to be used and as the procedures to be performed are now clear, one final question remains: How much product? 

Luckily, the WHO recommendations also provide us with a Spray Rates Listing with the required amount of product (in grams) for both the cabin and cargo areas for many common aircraft types. This can be found starting at page 49 in the official document, or a simplified version can be downloaded below for EEA airlines (where we do not list pre-embarkation disinsection, as it is not applicable).

Note: These are the minimum amounts of aerosol spray required.

Download the Aero-Sense spray rates listing here.

Insecticides are specifically formulated to kill insects. Therefore they are considered biocidal products. There is regulation in place, of course, to be able to manufacture and sell biocides. 

In the EU, the unified approach biocidal products is called the European Biocidal Products Regulation (BPR 528/2012/EC or "EU BPR"). The EU BPR aims to harmonize the market, simplify the approval of active substances and authorization of biocidal products. EU BPR is slowly replacing the "old" national biocidal product legislations in the 27 EU Member States.

When is EU BPR applicable?

To sell a biocidal product in the EU, this product needs to be authorized under the EU BPR, but only if the active substance(s) used in the product has/have already been evaluated by ECHA. If the active substance(s) is/are still under evaluation, you can still authorize them under "old" national biocidal regulations. (This is by definition temporary, because as soon as the active substance has been evaluated and is approved or forbidden, EU BPR applies.)

However, as has been established above, there are only two WHO recommended active substances: 1R-trans phenothrin (= d-phenothrin) and permethrin. Both the WHO recommended active substances for aircraft disinsection have already been evaluated by ECHA and both active substances are approved for use.

But – and this is extremely important here – authorization of the active substance does not mean that a product based on this active substance will be authorized. Chances of authorization success depend greatly on combination of the exact product formulation and specific the intended use, because that is what is evaluated by the member state(s) during the approval process. So in the case of aircraft insecticides, ECHA evaluates whether the specific WHO recommended product formulations for use in an aircraft cabin are acceptable. 

Research has shown that any product based on 2% m/m permethrin can never be authorized under European Biocidal Product legislation (EU BPR) for the specific purpose of aircraft disinsection. Technically, an authorization procedure for a product based on 2% permethrin (either an aerosol for ‘pre-embarkation’ or the emulsifiable concentrate for the ‘residual treatment’) could be started, as the active substance permethrin has been approved, but it will not pass the multi-year authorization procedure.

So in short: permethrin based aircraft insecticides are forbidden in the EEA. These products simply cannot be authorized because the (WHO required) 2% permethrin content induces unacceptable data during the (eco)tox assessment. Products that are not authorized as a legal biocide cannot be sold legally. Even though the 2% permethrin based formulation is WHO recommended, EU legislation is more strict: ECHA does not deem this product formulation safe enough for the intended purpose. 

Note: Although 1R-trans phenothrin based aircraft insecticides are used with passengers on board, the fact that this type of product is authorizable under EU BPR means that this is considered safer by ECHA than the use of a permethrin based insecticide, which are carried out in an empty aircraft cabin without passengers.

There are two types of EU BPR authorizations:

• A "new" national product authorisation, applicable for one country (a product may have several national authorizations for several countries
• A Union product authorisation, applicable for all EU Member States.

A Union authorization is a longer procedure, but does guarantee the best authorization coverage: 27 EU countries + Iceland, Norway and Switzerland.

Note: While EU BPR is only applicable to the 27 EU Member States (listed above), the countries Iceland, Norway and Switzerland have adopted nearly identical regulations in their own national legislation. The concrete result of this is that if a product that acquires a Union Authorisation (for all member states), additional approvals in Iceland, Norway and Switzerland are easily added, based on the existing EU authorization.

Where do I check whether products are approved?

The European Chemicals Agency (ECHA) is responsible for implementing the European Biocidal Products Regulation. It is also the central information repository to check whether a product holds an authorisation under EU BPR. 

On the official ECHA website, all approved active substances as well as approved products can be checked.

Example: Aero-Sense ASD Aircraft Insecticide with Union Authorisation # EU-0024297-0000. On the Biocidal product factsheet you can consult the Authorisation type, countries where the product has been approved and download the product authorisation in the national language of these countries.

Note: The map shown on the Biocidal product factsheet is not always correct, so always do double check the listed countries!

Technical aerosols, such as aircraft insecticides, all contain some form of propellant. Aerosol cans use propellants which are fluids that are compressed so that when the propellant is allowed to escape by releasing a valve, the energy stored by the compression moves the propellant out of the can and that propellant forces the aerosol payload out along with the propellant. Sometimes they also double as a solvent for the contained other ingredients. 

There are many different gases commonly used as propellant in aerosols such as nitrous oxide, carbon dioxide, and many halogenated hydrocarbons. The selection of the propellant is important, as not all components may be compatible. In the case of aircraft insecticides, there are only limited options for the propellants.

The go-to propellants from the distant past were CFCs (chlorofluorocarbons), but due to their massive impact on global warming, these are no longer in use. Since the late 1970s, the use of CFCs has been heavily regulated because of their destructive effects on the ozone layer. In aerosols, they have mostly been replaced by HFCs (hydrochlorofluorocarbons). However, HFCs are also a big concern in terms of their global warming impact. This has led to international legislation to ban these harmful products. This happens mainly via the implementation of the the Kigali Amendment to the Montreal Protocol.

The Kigali Amendment to the Montreal Protocol

• The Montreal Protocol, finalized in 1987, is a global agreement to protect the ozone layer by phasing out the production and consumption of ozone-depleting substances.
• The Kigali Amendment to the Montreal Protocol is an international agreement to gradually reduce the consumption and production very specifically of HFCs. It is a legally binding agreement designed to create rights and obligations in international law. As of April 10, 2024, 157 states and the European Union have ratified the Kigali Amendment.

As a result of the Kigali Amendment to the Montreal Protocol, HFCs are also quickly becoming a thing of the past in most of their applications. 

The Montreal Protocol and the Kigali Amendment are both international agreements. This means that after a country has ratified the Kigali Amendment, they will implement the agreement into their national legislation. So after ratification, it is only a matter of time before HFCs are banned for use, to certain limits of course.

The ratification status of a country can easily be consulted via the Ozone Secretariat of the United Nations Environment Programme. On the country profile on the Ozone Secretariat, the national focal points (contact persons) who are responsible for the implementation and follow up of the Kigali Amendment into national legislation can be found as well.

In practice, legislation is passed to limit the Global Warming Potential (GWP) of propellants that can be used. 

The "Global Warming Potential" value of a propellant compares the impact of a gas, such as a propellant used in aerosols, with the impact a similar amount of CO₂ would have on a certain time frame. The GWP for CO₂ is therefore 1, it’s a reference point. Products with a GWP > 1 have a larger impact on global warming than the same amount of CO₂ would have. Example: methane has a GWP of 28. 

Most commonly, aerosol propellant with a GWP > 150 are banned for use.

The consequences

• In the EU, the implementation of the Kigali Amendment of the Montreal Protocol has led to the introduction of Regulation (EU) 2024/573 on fluorinated greenhouse gases. 
  • Result: Technical aerosols with a Global Warming Potential (GWP) higher than 150 can no longer be sold and used inside the EU
• In Canada, the the implementation of the Kigali Amendment of the Montreal Protocol has led to the introduction of Ozone-depleting Substances and Halocarbon Alternatives Regulations
  • Result: Technical aerosols with a Global Warming Potential (GWP) higher than 150 can no longer be sold and used in Canada
• In the US, the EPA's American Innovation and Manufacturing (AIM) Act is limiting the use of HFCs with a Global Warming Potential (GWP) greater than 150 in aerosol products starting 01/01/2025.
  • Result: Technical aerosols with a Global Warming Potential (GWP) higher than 150 will soon become illegal in the United States

These are only a few examples, more and more countries introduce HFC-lowering legislation as they implement the Kigali amendment they have ratified. 

Propellants used in aircraft insecticides

In previous generation aircraft insecticides, the propellant used was (or in some cases: is still) HFC 134a. This is a hydrochlorofluorocarbon with a GWP of 1300. This means that this propellant is 1300 more harmful than CO₂ and more than 46 times more harmful than methane. It also exceeds the common GWP limit of 150 by 766%. It goes without saying that this kind of product is strongly forbidden in the EU and all other countries where the Kigali Amendment has been implemented into local legislation.

Future proof aircraft insecticides now mostly use a brand new propellant HFO 1234ze. This is not a hydrochlorofluorocarbon but a hydrofluoroolefins. HFO 1234ze has a GWP < 1. This makes new generation aircraft insecticides 99.9% less harmful to the ozone layer compared to old, harmful aircraft insecticides.

Example: An airline using 30.000 x 100g aircraft insecticide aerosols per year can save over 3800 tons of CO₂e emissions just by switching to aircraft insecticides not based on HFC 134a.

This is equivalent to greenhouse gas emissions from:

• Almost 16 million kilometres driven by an average gasoline-powered passenger vehicle
• More than 1.6 million litres of gasoline consumed

Or, this is equivalent to greenhouse gas emissions avoided by:

• 1 wind turbine running for an entire year
• More than 1300 tons of waste recycled instead of landfilled

Source: https://www.epa.gov/energy/greenhouse-gas-equivalencies-calculator#results

If you have any questions about aircraft disinsection products, procedures or any linked legislation, don't hesitate to reach out via info@aero-sense.com.