While laudable in its intent, the EU’s Biocide Product Directive (98/8/EC) led to a decade and a half of doubt for marine coatings suppliers. This reflected both the number of potential “active substances” falling under the Directive’s oversight, and that expectations for the approved list changed over time. From the early 2000s, coatings manufacturers knew that the biocides used to keep hulls free of fouling would be subject to scrutiny as never before, but the list of substances approved for dispersal in the marine environment was a matter for conjecture.
By 2002, the coatings industry accepted the fact that it would have to withdraw organotin as an antifouling substance following action by the International Maritime Organization. It also believed that it was only a matter of time before regulators would place copper, zinc and possibly other commonly used marine biocides in their sights for phase-out.