Detergents are among the most widely used groups of chemical products in households and industry. Although to the end user they may seem like “ordinary cleaning products”, for manufacturers, importers and distributors they represent a distinct category with extensive regulatory obligations. Placing them on the EU market requires compliance with three key legal acts: REACH, CLP and the Detergents Regulation (EC) 648/2004.

This means that in addition to the standard requirements applicable to chemical products—such as preparing a safety data sheet and developing a compliant label—manufacturers face an additional layer of obligations that must be considered when designing a product and preparing it for market placement. It is worth starting with the most fundamental question: which products fall within the scope of the Detergents Regulation.

What Exactly Is a Detergent?

 

According to Regulation 648/2004, a detergent means any substance or mixture containing soaps and/or other surfactants intended for washing and cleaning processes. Detergents may be in any form (liquid, powder, paste, bar, cake, moulded piece, shape, etc.) and marketed for or used in household, or institutional or industrial purposes.

This is therefore a broad definition. Additionally, the Detergents Regulation introduces the following terms:

• Auxiliary washing mixture, intended for soaking (pre-washing), rinsing or bleaching clothes, household linen, etc.;
• Laundry fabric-softener, intended to modify the feel of fabrics in processes which are to complement the washing of fabrics;
• Cleaning mixture, intended for domestic all purposes cleaners and/or other cleaning of surfaces (e.g.: materials, products, machinery, mechanical appliances, means of transport and associated equipment, instruments, apparatus, etc.);
• Other cleaning and washing mixtures, intended for any other washing and cleaning processes.

 

If a product meets any of the above definitions, it is considered a detergent. Examples include:

• laundry liquids and powders,
• dishwashing liquids,
• sanitary cleaners,
• industrial degreasers,
• toilet blocks,
• fabric softeners,
• dishwasher tablets.

 

Of course, the full list is much broader, and all products that fall under this category must comply with the Detergents Regulation.

REACH Documentation – Raw Materials and Ingredients Under Control

 

Although REACH does not create a separate “detergent” category, it still imposes obligations on manufacturers regarding all chemical substances used in the product. We discuss these requirements, such as safety data sheets, in more detail in other articles, but below is a brief overview.

Key REACH Obligations

 

Substance registration

• The detergent manufacturer must verify that all substances used are registered by the manufacturer/importer if they are placed on the market in quantities >1 tonne per year per substance (unless an exemption applies).
• This responsibility also covers the import of ready-made mixtures.

 

Preparation of a Safety Data Sheet (SDS)

 

• A safety data sheet will often be required for detergents under Article 31 of REACH, because the substances they contain typically reach concentrations necessary for effective cleaning performance that also trigger classification as hazardous (especially for eye and skin irritation).

 

CLP – Classification and Labelling Elements

 

Applying the classification rules under the CLP Regulation determines whether a product is considered hazardous and, as a result, whether a compliant CLP label must be prepared.

Classification

 

CLP contains rules for the classification of substances and mixtures. Substances are classified based on toxicological, ecotoxicological and physicochemical data. Mixtures, however, are most often classified using calculation methods to avoid generating additional toxicological or ecotoxicological test data. Exceptions mainly concern physicochemical tests—e.g., confirming flammability through flash point testing.

Common hazard classes for detergents include:

• skin or eye irritation (Skin Irrit. 2 H315, Eye Dam. 1 H318, Eye Irrit. 2 H319),
• skin sensitisation (Skin Sens. 1 H317),
• aquatic toxicity (Aquatic Chronic 2 H411, Aquatic Chronic 3 H412),
• physicochemical hazards (less common, but some ethanol-based detergents may be flammable).

 

CLP Labelling – Mandatory Elements

 

• pictograms,
• signal word (“Warning”, “Danger”),
• H- and P-statements,
• product identifier,
• supplier details,
• nominal quantity.

 

UFI and PCN Notification

 

If a detergent is classified as hazardous to health or for physical hazards, it must carry a UFI code and be notified to the PCN database.

Detergents Regulation – Specific Industry Obligations

 

Regulation 648/2004 establishes additional requirements for every detergent placed on the EU market. This documentation is required in addition to REACH and CLP duties. These requirements do not replace the CLP label or the SDS.

Biodegradability of Surfactants

 

Manufacturers must demonstrate aerobic biodegradation based on OECD tests. This applies to pure surfactants—not the entire mixture. A note on the fulfilment of this requirement is often included in section 12 of the SDS.

Detergent Label – Mandatory Information

 

In addition to CLP information, the label must include ingredient-related statements (according to the Detergents Regulation), such as:

• types of surfactants (e.g., contains anionic surfactants 15–30%),
• additives: enzymes, preservatives,
• list of possible fragrance allergens (if present at >0.01%).

 

Certain product categories (e.g., laundry powders) must also include dosing instructions.

Ingredient Data Sheet (Ingredient Sheet)

 

This lesser-known requirement is crucial for detergents supplied for professional use. The ingredient sheet must list all ingredients in descending order by weight, using the following concentration ranges:

• 10% or more,
• 1% or more but less than 10%,
• 0.1% or more but less than 1%,
• less than 0.1%.

 

Unlike the detergent label, the ingredient sheet includes all components—even those that are not surfactants, additives or fragrance compositions. The complete version must be made available to competent authorities upon request, but it does not need to be publicly accessible.

Website Ingredient List

 

Manufacturers must publish a shortened ingredient list on their website. This obligation does not apply to industrial detergents for which safety data sheets are available.

What Does This Mean for Manufacturers and Importers?

 

Placing a detergent on the market requires integrating three regulatory frameworks. In practice, this means:

• collecting detailed documentation from raw material suppliers,
• classifying the mixture based on its formula or available test data,
• preparing dual labelling: CLP + detergent requirements,
• maintaining a public website listing ingredients,
• creating an ingredient data sheet,
• updating UFI codes and PCN notifications when formulations change.

 

Summary

 

Detergents—despite being everyday consumer products—are subject to one of the most stringent regulatory systems in the EU. The combination of REACH (substances), CLP (classification and labelling) and the Detergents Regulation (user information and biodegradability) means that manufacturers must manage extensive technical documentation.

Well-prepared documentation is not only a legal requirement but also part of responsible practice toward users and the environment. In the near future, we also expect publication of the updated Detergents Regulation, which will introduce additional obligations for manufacturers.