New Detergents Regulation – 2026/405/EU
On 2 March 2026, Regulation 2026/405/EU – referred to as the new Detergents Regulation – was published in the Official Journal of the European Union. It will replace the currently applicable Regulation 648/2004/EC, and its primary objective is to align the legislation with technical progress and changes in the detergents market that have occurred since the publication of the previous regulation.
Among the key challenges that Regulation 2026/405/EU aims to address are the digitalisation of compliance, enhanced market surveillance to eliminate products that may pose risks to human health and the environment due to the presence of undesirable substances, and the simplification and harmonisation of requirements for detergents arising from various regulations (REACH, CLP).
Whether EU legislation will successfully meet these objectives will become clear over time. However, it is already worth taking a preliminary look at what the new Regulation will introduce. Although the requirements of Regulation 2026/405/EU will only become applicable in 3.5 years – as the current legal act and its requirements remain in force until 23 September 2029 – some of the changes and obligations are significant enough that companies should use this period to develop appropriate internal strategies and procedures.
Detergents – Changes and New Obligations
As expected, more than two decades after its publication and over a decade since its last update, the Detergents Regulation required a comprehensive revision. This is clearly reflected in the scope of the amendments introduced, ranging from updated definitions to the introduction of the Digital Product Passport (DPP).
When reading the new Regulation, one of the first noticeable changes is the expansion of the definition of a detergent to include products that function based on the presence of microorganisms. Other definitions have also been amended and clarified (such as cleaning and surfactant).
New concepts have been introduced as well, such as the authorised representative (who may assume obligations normally incumbent on the manufacturer), and detailed requirements have been set out for manufacturers, importers and distributors of detergents. Regulation 2026/405/EU sets clear and demanding obligations for all actors in the supply chain to ensure the safety of this product group.
In this article, we will not describe all new requirements in detail. A thorough analysis and interpretation will require time, and it is also worth waiting for industry feedback, including from AISE. However, we will highlight the areas where, in our view, the most significant changes will occur.
Digital Product Passport, Labels and Ingredient Data Sheet
Of the three documents mentioned in the heading of this section, only one is entirely new – the Digital Product Passport (DPP). The concept has been discussed within the EU for some time and is gradually being introduced for various product groups. Now it is the turn of detergents.
In simple terms, the Digital Product Passport can be defined as a digital declaration by the manufacturer confirming that the product placed on the market complies with the applicable EU legislation (whether referring to Regulation 2026/405/EU or the CLP Regulation). In practice, this will most likely take the form of a QR code displayed on the website where the product is sold and on its packaging, allowing the end user to access confirmation of compliance and additional product information.
From a business perspective, this will require:
- Preparation of the Digital Product Passport
- Proper registration in the designated registry
- Obtaining a “data carrier” (e.g. a QR code)
- Placing the QR code on the label
Although these steps may seem limited, this is an entirely new obligation. It will require supplier assessment, verification of the documentation necessary to substantiate the declaration of conformity, and implementation of procedures ensuring that each product is supported by a DPP and appropriate documentation.
Minor changes will apply to detergent labels themselves (apart from the obligation to include a reference to the DPP). Nevertheless, several simplifications and improvements have been introduced – for example, the possibility to combine information required under the Detergents Regulation and the CLP Regulation, which should be viewed positively as it removes duplicated information.
The concept of digital labelling is also introduced in Regulation 2026/405/EU. However, similarly to the CLP Regulation, its scope is limited to a narrow set of information and subject to technical requirements regarding stability and accessibility. For this reason, at least initially, it may not be fully practical – unless it can be effectively integrated with the Digital Product Passport.
The Ingredient Data Sheet, which previously received relatively little attention, will now become significantly more important. It will form part of the information submitted within the framework of a PCN notification – an example of the closer alignment between CLP and the Detergents Regulation. While in the past some companies treated this element of documentation with a degree of flexibility, it will now become essential for meeting core obligations related to placing chemical products on the market.
2026/405/EU – What Else?
As mentioned at the outset, the scope of changes is broader and requires further analysis. However, it is worth noting that:
- A distributor placing products on markets other than those covered by the manufacturer will be required to submit the Ingredient Data Sheet in the appropriate language(s) to poison centres via PCN notification.
- The format of the Ingredient Data Sheet will change and will include additional information, such as the UFI code.
- A distributor who changes the product’s trade name or trademark will assume obligations equivalent to those of a manufacturer.
The list of changes is certainly longer, but those outlined above are among the most significant and will have a substantial impact on business operations.
New Detergents Regulation – Next Steps
At this stage, we recommend reviewing the text of the Regulation and assessing which obligations will apply to your company based on your role in the supply chain. It is also advisable to conduct a preliminary analysis of the impact of the new requirements on label design and content, as labelling is typically the most technically challenging element to modify.
Subsequently, companies can begin planning and await guidance from major industry associations, particularly AISE, as well as our upcoming articles, where we will analyse specific aspects of the forthcoming changes in greater detail.
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