U.S. regulatory requirements associated with antimicrobial-treated surfaces are complex. Any product offered for sale in the United States claiming to control or mitigate pests, including microorganisms, must be registered by the U.S. Environmental Protection Agency (EPA). Typically, coatings incorporating preservatives to protect the integrity of the product, both in the can and on the coated surface, are exempt from registration. However, increased concerns regarding disease transmission offer an opportunity to provide products that can sanitize surfaces. Products making claims to control microorganisms on treated surfaces are now more closely scrutinized by the EPA. They may require registration or they may be exempt under EPA's "Treated Article" exemption.
This paper focuses on the regulatory requirements associated with antimicrobial substances (antimicrobials) used in paints and surface treatments in the United States. Antimicrobials have historically been used in paints or on coated surfaces as preservatives to protect the integrity of the paint or coated surface.