November 9, 2026Miguel Angel Gómez

New Royal Decree 952/2026 on biocides: what changes for medical devices

New Royal Decree 952/2026 on biocides: what changes for medical devices

New Royal Decree 952/2026 on biocides

📅 Published: 6 November 2026 · In force from: 1 July 2027


📢 The Spanish Official Gazette (BOE) has published Royal Decree 952/2026, which regulates the registration, manufacture, marketing and use of biocides in Spain. It complements Regulation (EU) 528/2012 and replaces, among others, Royal Decree 1054/2002.


⚖️ Biocide, medicinal product or medical device?

  • 💊 Medicinal product: antiseptics for the pre-operative surgical field and the injection site are outside the scope of the decree.
  • 🏥 Medical device: disinfectants intended for medical devices need CE marking under the MDR (class IIa or IIb).
  • 🧴 Biocide: disinfectants for surfaces, equipment and furniture that are not medical devices. The AEMPS reports on their efficacy.

What decides is the intended purpose declared by the manufacturer, not the formula.


⚠️ Watch your claims

  • The terms «higienizante» and «sanitizante» (sanitising) are considered biocidal claims.
  • Labelling must be at least in Spanish.

🗓️ Other changes

  • Mandatory transaction register for the most hazardous biocides, six months after entry into force.
  • Six years for application staff to obtain the new training.

✅ At MeDev Consulting we help you review the intended purpose and claims of your disinfection products and, when they are medical devices, obtain their CE marking. Contact us.