Detergents & Surfactants

Detergents & End-User Surfactants: DPP confirmed under Regulation (EU) 2026/405

Regulation (EU) 2026/405 repeals Regulation (EC) No 648/2004, entered into force on 22 March 2026 and applies from 23 September 2029. It creates a model-level digital product passport for detergents and end-user surfactants, linked by a data carrier and paired with a dual-layer label. That makes this sector operationally different from most ESPR categories: the legal minimum passport dataset is already fixed in Annex VI, but manufacturers still need to connect formulation, CLP or UFI logic, poison-centre workflows, refill operations and micro-organism evidence before go-live.

Regulatory note: the text was published in the Official Journal on 2 March 2026, adopted on 11 February 2026, and applies from 23 September 2029. The DPP obligation in Article 21 covers detergents and end-user surfactants. Surfactants supplied only as upstream B2B inputs do not follow the same passport layer unless they are made available directly to consumers or other end-users.

Confirmed minimum data set (Annex VI) DPP per model, unless other Union law requires batch/item level

The detergent DPP does not replace the physical label. Article 17, Article 18 and Annex V create a dual-layer model: core safety, UFI and use information stay physically available, while selected content may shift to the digital label or the passport.

Regulatory Timeline

2 Mar 2026

Official Journal publication

Regulation (EU) 2026/405 is published in the Official Journal and formally repeals the old detergents framework of Regulation (EC) No 648/2004 on the future application date.

22 Mar 2026

Entry into force

The Regulation enters into force on the twentieth day after publication. From this point, delegated-power and implementation preparation starts, even though the main obligations do not yet apply.

By 1 Oct 2028

Commission must define specific digital-labelling rules

Article 30 requires delegated acts specifying the concrete requirements for detergent digital labelling, including the IT solutions that may be used and alternative means of access for users who cannot scan or reach the digital layer.

23 Sep 2029

Core application date for DPP, label and refill regime

Article 37 sets the main application date. From this point, detergents and end-user surfactants falling within the Regulation need the new Article 17 to Article 24 architecture: label, digital label logic, data carrier, model-level DPP and registry linkage.

23 Sep 2030

End of the one-year transitional market-availability window

Article 36 preserves indefinite sell-through for products lawfully placed on the market before 23 September 2029, but products placed under the old regime during the additional one-year transition may only remain available until 23 September 2030.

23 Mar 2032

Biodegradability criteria expand to films and polymers within films

Article 4 introduces the next data step for unit-dose or comparable formats: films or polymers within films must comply with the biodegradability requirements in Annex I Part B.

23 Mar 2034

Biodegradability criteria expand to certain high-concentration organics

Organic substances intentionally added at 10 % w/w or more, excluding water and the categories carved out by the Regulation, must comply with the Annex I Part C criteria unless a derogation applies.

What must the detergents DPP and label architecture contain?

46 attributes · 7 clusters

Composition ranges for listed constituent classes Public

Details

Annex V Part A 1(h)(i). The bands “less than 5 %”, “5 % or over but less than 15 %”, “15 % or over but less than 30 %” and “30 % and more” are used when listed classes are added above 0.2 % w/w.
Always-listed classes: enzymes, micro-organisms, optical brighteners and perfumes Public

Details

Annex V Part A 1(h)(ii). These classes must be listed irrespective of concentration when intentionally added.
Preservatives listing When relevant Public

When relevant

Applies where preservatives meet the treated-article or labelling conditions in Annex V Part A 1(h)(iii) and are not already labelled under CLP or the Biocidal Products Regulation.

Details

Where possible the naming system from the Cosmetics Regulation is used.
Fragrance allergens above 0.01 % by weight When relevant Public

When relevant

Applies where intentionally added fragrance allergens listed in Annex V Part D exceed 0.01 % by weight and are not already labelled under CLP.

Details

This is one of the ingredient categories that cannot disappear from the physical refill layer under Annex V Part C(2).
Full list of intentionally added substances Public

Details

Annex VI Part A (h). The DPP goes further than the physical label by requiring the full intentionally added substance list identified in accordance with CLP Article 18(3). Carry-over preservatives are included where the labelling rules trigger them.
SDS-equivalent disclosure route for industrial and institutional detergents or surfactants When relevant Supply chain

When relevant

Relevant where the product is industrial or institutional and the equivalent information is provided through the safety data sheet under REACH Article 31.

Details

In those cases, the public ingredient-content layer in Annex V Part A 1(h)(i) to (iv), and the Annex VI Part A (h) DPP obligation, may be displaced by the SDS route.
Ingredients data sheet for appointed bodies Authorities

Details

Annex IV 2.2(e) and Article 8(6). This is the emergency-health-response layer for mixtures not already covered by the Article 45 CLP poison-centre route. It is submitted electronically for the appointed bodies rather than general consumers.

Physical label on packaged products and refill sales Public

Details

Article 17(1) and 17(2). Products made available through refill still need a physical label, and the operator must make the physical label and the data carrier available for each refilled package.
Digital label with duplicated core information When relevant Public

When relevant

Relevant where the manufacturer chooses a digital label under Article 18 instead of keeping everything purely physical.

Details

Article 18 allows either a physical label only, or a digital label duplicated on a physical label.
Digital-label-only composition fields When relevant Public

When relevant

Annex V Part C allows only selected Part A composition fields to move to digital-only format.

Details

These include anionic, cationic, amphoteric and non-ionic surfactants, phosphates, phosphonates and soap.
Simplified physical dosage grid for consumer laundry detergents When relevant Public

When relevant

Applies when the full dosage information from Annex V Part B is moved to the digital label.

Details

Annex V Part C(3) still requires a simplified physical grid with basic instructions, medium-water recommendations by soil level and the washing-machine-load indication.
Accessible, searchable and free digital label Public

Details

Article 19 requires the digital label to be searchable, accessible across the Union, compatible with major operating systems and browsers, and obtainable by other means on request or when temporarily unavailable. Tracking beyond what is strictly necessary is prohibited.
Refill-station risk mitigation and incompatibility control When relevant Supply chain

When relevant

Relevant where detergents or end-user surfactants are made available through refill.

Details

The operator must apply risk-mitigation measures, especially for children, and ensure products provided through the refill station do not react with each other in a way that could endanger human health.
Distance-sales display of label information and data carrier or unique product identifier Public

Details

Article 20. Before purchase in distance sales, the offer must clearly and visibly indicate Article 17 label information plus a digital copy of the data carrier or the unique product identifier.

Ultimate aerobic biodegradability evidence for surfactants Authorities

Details

Article 4(1) and Annex I Part A. Surfactants placed on the market, whether contained in detergents or sold separately, must meet the ultimate aerobic biodegradability requirements demonstrated with the listed test methods.
Films or polymers within films compliance from 23 March 2032 When relevant Authorities

When relevant

Relevant where the detergent uses water-soluble films or polymers within films, such as unit-dose capsule formats.

Details

Article 4(3). This extends the biodegradability architecture beyond classic surfactants.
Organic substances intentionally added at 10 % w/w or more compliance from 23 March 2034 When relevant Authorities

When relevant

Relevant for non-surfactant organic substances intentionally added at 10 % w/w or more of the total mass of substances, excluding water, subject to the carve-outs in Article 4(4).

Details

Article 4(4) and Annex I Part C.
Consumer laundry detergent phosphorus limit (0.5 g) When relevant Public

When relevant

Applies to consumer laundry detergents.

Details

Annex III. The limit is expressed in the recommended quantity used in the main cycle for a standard washing-machine load in hard water.
Consumer automatic dishwasher detergent phosphorus limit (0.3 g) When relevant Public

When relevant

Applies to consumer automatic dishwasher detergents.

Details

Annex III. The limit is expressed in the standard dosage.
Dosage instructions for laundry, dishwasher and surface detergents When relevant Public

When relevant

Applies to consumer laundry detergents, consumer automatic dishwasher detergents and consumer detergents for surfaces under Article 17(4) and Annex V Part B.

Details

For laundry detergents, the law specifies standard loads and allows the detailed grid to move digital only if a simplified grid remains on the physical label.

Public Supply chain Authorities Post-market data Regulatory context

Tiered access and emergency health response

Unlike the battery passport, the detergents act does not yet fix the full actor-by-actor access matrix. It does, however, combine a public-facing DPP and label layer with authority-side ingredients-data-sheet and emergency-health-response duties. In IT terms, one product record usually feeds at least three layers: public consumer information, operational refill / e-commerce / packaging data, and authority or poison-centre documentation.

Attribute	Public	Authorities
Ingredient disclosure	Intentional ingredient list, labelled preservatives, fragrance allergens and UFI visible to the end-user	Ingredients data sheet with the more detailed composition and emergency-health-response information needed by appointed bodies or poison centres
Microbial detergent record	Genus/species/strain, shelf life and food-contact limitation or precautionary wording	Annex II risk-assessment report, test evidence and supporting technical documentation
Compliance record	Model ID, data-carrier access and statement that compliance has been demonstrated	Technical file, test methods, calculations, label specimen and registry-linked compliance checks

* "Supply chain" is a working label for the non-public layer used by economic operators with a legitimate operational reason to access the record. Article 21(10)(d) still leaves the final actor-by-actor access matrix to a Commission implementing act.

**** Source labels indicate where the data usually lives in enterprise systems. They are IT-architecture guidance, not legal categories. Abbreviations used on this page: UFI = Unique Formula Identifier under CLP Annex VIII; CLP = Classification, Labelling and Packaging Regulation; SDS = Safety Data Sheet.

Who Is Actually Covered?

Regulation (EU) 2026/405 reaches further than a simple “laundry detergent QR code” reading suggests. In practice it concerns:

manufacturers of consumer laundry detergents, dishwashing products, surface cleaners and other household cleaning products
manufacturers of industrial and institutional detergents, which remain inside the Regulation even when some ingredient disclosure can be shifted to the safety data sheet route
manufacturers of end-user surfactants sold directly to consumers or other end-users
non-EU manufacturers, importers and authorised representatives, especially in distance sales and online marketplaces
operators of refill stations and stores offering detergents or end-user surfactants through refill
formulation, regulatory, poison-centre, packaging and e-commerce teams that must align one product record across label, DPP and registry workflows
private-label brands and economic operators placing products on the market under their own name or modifying them in a way that can affect compliance

Important nuance: yes, industrial and institutional detergents remain inside the Regulation, even where some ingredient disclosure can move to the SDS route. The narrower carve-out concerns surfactants: recital 7 and Article 21 point the DPP layer to detergents and end-user surfactants, so a surfactant sold only as an upstream B2B input to another manufacturer does not automatically carry the same passport layer. If it is made available directly to consumers or other end-users, the DPP logic applies.

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