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Understanding the Legal Use of Sodium Hypochlorite in Softwashing
Thanks to Ben Hawkins for initiating this important industry conversation by expressing the viewpoint that
“Softwashing without a biocidal claim….The whole point of Softwashing is that you kill the growths responsible for the dirty appearance hence allowing for a longer better clean.”
As exterior cleaning professionals, staying on the right side of the law while maintaining effective cleaning practices is vital.
Does Sodium Hypochlorite Always Count as a Biocide?
Many professionals use sodium hypochlorite (NaOCl) to clean surfaces impacted by algae, lichen, or mold. But whether it's classed as a biocidal product under the law depends entirely on how it’s used and marketed.
What HSE Says
"A product is only within the scope of BPR if its intended use is to control harmful organisms by chemical or biological means."
— HSE: Check if your product is regulated
So, if you're using pool-grade sodium hypochlorite to remove grime or brighten a patio without any biological control claims, it does not fall under the GB Biocidal Products Regulation (GB BPR). You are not required to register it as a biocide.
Legal Use Cases: What’s In and What’s Out
- NOT a biocide: Sodium hypochlorite used only to remove stains or lift dirt, with no claim of controlling organic growth.
- IS a biocide: Sodium hypochlorite marketed or used with the intent to kill algae, bacteria, moss, or fungi.
This distinction is consistent across both GB BPR (for England, Wales, and Scotland) and EU BPR (for Northern Ireland).
Real-World Example from Softwashing Practice
Our training at SoftWash UK reflects this. For example, when applying sodium hypochlorite to clean driveways or patios, we advise no claims of biocidal action unless you're using a registered biocide like:
This product is fully compliant for jobs requiring biocidal claims—especially on surfaces plagued by biological staining.
Supporting HSE Guidance
Intent and Marketing Matter Most
Even if a chemical contains known biocidal ingredients, if your marketing and usage do not claim biological control, it's not regulated as a biocide. This is supported by examples HSE provides, such as:
“Use of essential oils for fragrance, not for insect repellent effects, excludes them from BPR.”
Key Takeaways for Exterior Cleaning Pros
- Know your product's purpose: Is it for cleaning or killing?
- Read the labels: Don’t imply a biocidal effect unless your product is registered.
- Follow softwashing best practices: Responsible use of sodium hypochlorite includes protecting plants, using correct PPE, and managing runoff.
Need Help Navigating Compliance?
Join our SoftWash UK Training Program and gain CPD-certified knowledge in safe chemical handling, legal compliance, and proper softwashing application.
Conclusion
Sodium hypochlorite is a powerful cleaner—but whether it’s a biocide in the eyes of the law depends on how you use and present it. Stay informed, stay compliant, and let’s keep the softwashing industry safe and professional.
Further Reading: Visit HSE’s Biocides Guidance Portal.
