Article 95 and chlorine dioxide, clearly explained
Anyone who looks into chlorine dioxide in more depth will sooner or later come across the term Article 95. It crops up in forums, in discussions and in legal assessments. However, it often remains unclear what exactly it means. To many people, Article 95 sounds like a ban or a restriction, although that is not the case.
Article 95 is not a blanket ban and is not aimed directly at consumers. It is part of a European body of rules intended to organise, regulate and monitor the market.
What lies behind Article 95
Article 95 has its origin in the European Biocidal Products Regulation. Its aim is to regulate the market for biocides and chemicals. The substances covered by it have been subject to strict requirements since 2015. Under these rules, a biocidal product, in this case chlorine dioxide as a ready-to-use solution, that consists of, contains or generates a substance included in the list may only be made available on the market (in other words, sold) if the substance manufacturer/supplier or the biocidal product manufacturer/supplier is included in the list for the relevant product type.
Article 95 therefore does not regulate purchases by end customers, but the conditions under which certain active substances and products may be made available on the market and, above all, who may do so.
To be listed under Article 95, a manufacturer has to register with ECHA (European Chemicals Agency). Over a period of years, production sites, staff, production methods and equipment as well as the raw materials are inspected, and extremely detailed dossiers are prepared and submitted. This process is not only time-consuming and resource-intensive but also an enormous investment for the manufacturer concerned, and so in several respects demonstrates professionalism, reliability, commitment and an exceptionally high sense of responsibility towards itself and its customers.
CDL2go is made for us exclusively by the only manufacturer approved EU-wide for ready-to-use chlorine dioxide products for private end consumers.
Why the term causes uncertainty
To outsiders, Article 95 often seems abstract. The term appears without explanation and is quickly equated with restrictions. In reality, it describes a regulatory framework that is mainly relevant for businesses.
Consumers feel the effects indirectly. The market is getting smaller because not everyone wants to carry the organisational and legal effort. At the same time, the remaining market is becoming more structured.
Since when Article 95 has mattered in practice
Article 95 is not a new instrument. The requirements have been known for many years, since 2015 to be precise, and were made binding step by step. The market barely changed, and where it did, only gradually, because before the rules of Article 95 could be applied in practice, suppliers and manufacturers first had to obtain licences and approval for the list under the article. This process took many years, so an enforceable structure has only been in place since the end of 2025. That explains why the market has changed not only abruptly, but also over several years, while a clearly noticeable upheaval in the market is only being seen now.
What Article 95 does not mean
Article 95 is not a guide for consumers to check lists themselves or to follow legal details. For buyers, it usually makes little sense to study the formal background in detail.
It is more important to understand why the market has changed and why products are presented differently today than in the past.
Where things stand in today's market
Today's market is more structured and calls for deliberate communication. Brands that have adapted to the current framework often avoid simplified statements and rely on explanatory context instead.
Our preferred product, CDL2go, also grew out of long observation of these developments and has been aligned with today's regulatory and communication framework from the start. This shows not in loud promises, but in a sober assessment.
Why this understanding matters
Anyone who puts Article 95 into the right context will see that it is not about bans, but about responsibility and clear conditions for competition. Away from the lack of transparency of many small, opaque suppliers, who disappeared as quickly as they had appeared on the market, towards stable & lasting suppliers that build trust!
The next article builds on exactly this and explains why these developments affect the market for private customers particularly strongly.
This is part 2 of our 4-part series on ready-to-use chlorine dioxide solutions, in which we try to unpack the current events and changes in this product segment and niche in a way that is easy to understand yet detailed. Feel free to read the following 2 articles in this short series as well, and get in touch with us if you have any questions.
