March 6, 2026
By Klaudia Sostaric, Senior Regulatory Specialist and Dr. Martina Schneider, Regulatory Affairs Manager, Supply Chain Team, UL Solutions
On March 2, 2026, the European Union published Commission Delegated Regulation 2026/405 on detergents and surfactants repealing the old detergent Regulation (EC) No 648/2004. The new legislation will ease product sales across the EU, protect health and the environment, simplify consumer information, and clarify labelling requirements for businesses.
This Regulation results from the Commission’s April 2023 proposal, which introduced measures to address gaps and eliminate overlaps among EU chemical legislations (see UL’s news article on proposal here).
The updated Detergents Regulation expands the definition of detergents to include new products, such as those containing micro-organisms. It also introduces an animal testing ban as well as requirements for detergents and surfactants sold to end-users through refill systems, reflecting new developments in the market.
The revision removes previous overlaps with CLP labelling rules and introduces digital labelling and a digital product passport (DPP).
Manufacturers located outside the EU may place detergents and surfactants on the EU market, provided they appoint an authorised representative established in the EU.
This Regulation will apply from 23 September 2029, except for certain biodegradation related provisions, which follow separate timelines.
The following transition periods apply:
Detergents and surfactants placed on the market before September 23, 2029 that comply with the old detergent Regulation (EC) No 648/2004 may continue to be made available without any time limit.
Detergents and surfactants placed on the market between September 23, 2029 and September 22, 2030 that comply with the old detergent Regulation (EC) No 648/2004 may continue to be made available until September 23, 2030.
Labelling requirements
All detergents and surfactants, regardless of whether they are sold in individual packaging or provided through refill, must be accompanied by a label. When these products are supplied directly to end users via refill stations, the responsible economic operator is required to provide both the physical label and the data carrier specified in Article 21(2)(h). These must be made available for every package that is refilled with detergent or surfactant.
The fundamental labeling requirements established under the 2004 regulation continue to apply. In accordance with Article 17(3), labels for detergents and surfactants must include the mandatory information listed in Part A of Annex V of the new regulation. This covers the essential product and traceability details. This means that in addition to the product name or trade name, labels must display a type or batch number (or another traceable identifier) and the UFI (Unique Formula Identifier), indicated as “UFI:” followed by the code. The label must also identify the manufacturer (and, where relevant, the importer) by providing their name or registered trade name or trademark, a single postal address within the EU, an email address, and a telephone number. Instructions for use and any special precautions must also be included.
For products intended just for professional use in industrial or institutional settings, this restriction must be explicitly stated on the label. Labels for surfactants must additionally confirm that the substance is suitable for use in detergents. Certain ingredients must also be listed on the label in accordance with the rules set out in Part A, point 1(h) of Annex V with the fragrance allergens listed in part D of Annex V.
In addition, labels for consumer laundry detergents, consumer automatic dishwasher detergents, and consumer surface-cleaning detergents must include dosage instructions, as required by Part B of Annex V.
In accordance with Article 18 of the Regulation, the labelling information may be provided either on a physical label or on a digital label, provided that a physical label is still included. An exception applies for the information included in Part C of Annex V, which may be supplied in digital form only. While certain details such as traceability elements e.g. type number, batch number, the manufacturer’s and, if applicable, the importer’s name, registered trade name or trademark, email address, telephone number, postal address indicating a single point in the Union, and product’s name and trade name are required to be provided on the physical label only.
For detergents and surfactants sold via distance sales, the online offer must clearly and visibly present the labelling information required under Article 17, along with a digital version of the data carrier or the unique product identifier.
Biodegradability requirements and detergents containing microorganisms
Annex I sets out the new biodegradability criteria which have been revised and extended. In the future, the Commission shall adopt delegated acts setting out biodegradability criteria and test methods for films and polymers within films and organic substances intentionally added in concentration of at least 10% w/w.
The definition of detergents is extended to include new products, such as those containing micro-organisms. Related requirements to added micro-organisms are set out in Annex II.
Conformity assessment and the digital product passport
Annex IV describes the requirements for a conformity assessment procedure including the need of technical documentation that should make it possible to assess the compliance of the detergent or surfactant.
The regulation also introduces the requirement for the digital product passport (DPP) to provide information on compliance with this Regulation. This replaces but contains similar information as the original ingredient data sheets in the 2004 legislation.
According to Annex VI, part A, the DPP must include the following information:
- Product identification: trade name, unique product ID, and a clear colour image of the packaging or label
- Company information: name, postal/e‑mail address, phone number of manufacturer (and importer/authorized representative if applicable), plus the manufacturer’s unique operator ID
- Reference to the passport service provider hosting the back‑up copy of the DPP
- Traceability details: identification information enabling product traceability
- A confirmation statement that the manufacturer is solely responsible for the DPP
- Commodity codes: relevant customs codes (from Regulation 2658/87), if applicable
- A confirmation of compliance with this Regulation and any other relevant EU law
- List of all intentionally added substances (as defined under CLP Regulation 1272/2008), including carry‑over preservatives when required by regulation
- List of all intentionally added micro-organisms with full taxonomic classification (genus, species, strain)
The DPP is connected to the product via a unique identifier. According to Article 24, a reference must be included in the registry established under the ecodesign requirements for sustainable products Regulation (EU) 2024/1781. The DPP will be required at EU borders, must be interoperable with other EU digital passport systems, and will allow authorities - especially customs - to automatically verify compliance. By creating a DPP, manufacturers declare full responsibility for ensuring their product meets all applicable regulatory requirements.
Importers, manufacturers, authorised representatives, and certain distributors will also have to provide an ingredients data sheet for mixtures that are not classified as hazardous for health, using the systems already in place under CLP. To support this, the Commission should be empowered to define the technical requirements.
References
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