Detergents & Surfactants

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

Regulation (EU) 2026/405 generally applies from 23 September 2029. It establishes a mandatory model-level passport for detergents and end-user surfactants. Digital labelling is voluntary: Article 18 permits a physical-only label or a digital label with the required physical duplication. The DPP remains a separate obligation.

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

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

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.

Legal basis and current timeline

Sources reviewed: September 20, 2026

EUR-Lex

EU 2026/405

Binding text: scope, obligations, annexes and transitional provisions.

What must the detergents DPP and label architecture contain?

Each row identifies the information location or type of duty. A label, documentation or process duty does not mean publication in the DPP is required. Supporting passport data do not remove duties under other legislation. See details for conditions and dates.

Access badges are shown only where label or technical-documentation rules establish access. No badge does not mean public access: these fields appear under “All”. Detailed DPP access rights will be set by acts under Article 21(10)(d) of Regulation 2026/405.

attributes: 60 · clusters: 7

Type number, batch number or equivalent traceability element Label / instructions Mandatory Public

Details

Article 18 allows these identification details to remain on the physical label without duplication on a digital label; it does not prohibit duplication. The DPP separately requires the trade name and the manufacturer’s contact details, plus those of the importer or authorised representative where applicable.
Unique Formula Identifier (UFI) Label / instructions Mandatory Public

Details

The new Regulation requires a UFI on the label of detergents and end-user surfactants, not only mixtures subject to CLP poison-centre notification. UFI is not a separate minimum DPP field in Annex VI.
Manufacturer and, where applicable, importer or authorised-representative contact details DPP data Mandatory

Details

Article 18 allows these identification details to remain on the physical label without duplication on a digital label; it does not prohibit duplication. The DPP separately requires the trade name and the manufacturer’s contact details, plus those of the importer or authorised representative where applicable.
Unique operator identifier of the manufacturer DPP data Mandatory

Details

Annex VI Part A (b). The DPP must carry the manufacturer’s unique operator identifier in addition to the name, postal address, electronic address and telephone number, plus those of the importer or authorised representative where applicable.
Statement that the DPP is issued under the sole responsibility of the manufacturer DPP data Mandatory

Details

Annex VI Part A (e). The passport must contain an explicit statement attesting that the manufacturer assumes sole responsibility for issuing the DPP. This is distinct from the Annex VI Part A (g) declaration that compliance with the Regulation has been demonstrated.
Product trade name DPP data Mandatory

Details

Article 18 allows these identification details to remain on the physical label without duplication on a digital label; it does not prohibit duplication. The DPP separately requires the trade name and the manufacturer’s contact details, plus those of the importer or authorised representative where applicable.
Industrial or institutional professional-use-only indication Label / instructions Conditional Public

Conditional

Required where the product is an industrial and institutional detergent rather than a consumer detergent.
Surfactant indication: suitable for use in detergents Label / instructions Conditional Public

Conditional

Required for surfactants placed on the market as such.
Colour image of the packaging or label of the model DPP data Mandatory

Details

Annex VI Part A (a). The DPP must make the represented model visually identifiable.
Product identification enabling traceability DPP data Mandatory

Details

The DPP must identify the product so that it can be traced. It must state that compliance with this Regulation has been demonstrated and include references to other Union law with which the product complies, where relevant. — 2026/405, VI A(d,g)

Composition ranges for listed constituent classes Label / instructions Conditional Public

Conditional

For constituent classes and thresholds in Annex V Part A point 1(h), subject to the safety-data-sheet exception.

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.
Added enzymes, micro-organisms, optical brighteners and perfumes Label / instructions Conditional Public

Conditional

Enzymes, micro-organisms, optical brighteners and perfumes are listed if added, regardless of concentration. Preservatives and fragrance allergens follow their own thresholds and duplication exceptions. The equivalent-SDS exception for industrial and institutional detergents and surfactants applies to all four composition rules in points (i) to (iv).

Details

Enzymes, micro-organisms, optical brighteners and perfumes are listed if added, regardless of concentration. Preservatives and fragrance allergens follow their own thresholds and duplication exceptions. The equivalent-SDS exception for industrial and institutional detergents and surfactants applies to all four composition rules in points (i) to (iv).
Preservatives listing Label / instructions Conditional Public

Conditional

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. Exception: industrial and institutional detergents and surfactants where equivalent information is supplied in the safety data sheet (Annex V Part A 1(h)(v)).

Details

Where possible the naming system from the Cosmetics Regulation is used.
Fragrance allergens above 0.01 % by weight Label / instructions Conditional Public

Conditional

Applies where intentionally added fragrance allergens listed in Annex V Part D exceed 0.01 % by weight and are not already labelled under CLP. Exception: industrial and institutional detergents and surfactants where equivalent information is supplied in the safety data sheet (Annex V Part A 1(h)(v)).

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 DPP data Conditional

Conditional

Mandatory for consumer detergents; under Annex VI Part A point (h) this list is not required for industrial and institutional detergents, or for surfactants, where the equivalent information is provided by a safety data sheet (Article 31 of Regulation (EC) No 1907/2006).

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 Technical documentation Conditional Supply chain

Conditional

For industrial and institutional detergents and surfactants where equivalent information is supplied in a safety data sheet complying with REACH Article 31.

Details

Annex V Part A point 1(h)(v) and Annex VI Part A(h) permit equivalent information in an Article 31 REACH safety data sheet when the conditions for industrial and institutional detergents and surfactants are met.
Ingredients data sheet in the technical documentation Technical documentation Mandatory Authorities

Details

The ingredients data sheet forms part of the technical documentation. Submission to appointed bodies under Article 8(6) applies to detergents and end-user surfactants that are mixtures not already subject to CLP Article 45 information duties. Submission is confidential, not public DPP disclosure.

List of intentionally added micro-organisms (genus, species, strain name or code) DPP data Conditional

Conditional

Required for detergents or end-user surfactants containing intentionally added micro-organisms.

Details

Annex VI Part A (i). The act explicitly expands the detergent definition to cover products with intentionally added micro-organisms.
Food-contact surface restriction or precautionary statement Label / instructions Conditional Public

Conditional

Required for detergents containing micro-organisms unless the Annex II risk assessment found the product safe for surfaces in contact with food.
Shelf life of the product Label / instructions Conditional Public

Conditional

Required for detergents containing micro-organisms under Annex V Part A 1(h)(vi).
Special microbial use instructions or precautions Label / instructions Conditional Public

Conditional

Required where relevant for detergents containing micro-organisms.
Annex II risk-assessment report for microbial detergents Technical documentation Conditional Authorities

Conditional

Relevant only where the product contains intentionally added micro-organisms.

Details

Annex IV 2.2(b) cross-refers to the risk assessment in point 7 of Annex II. The methodology must address identification, characterisation and risks such as spray exposure or food-contact use.
Test reports demonstrating compliance with Annexes I and II Technical documentation Conditional Authorities

Conditional

Include test reports demonstrating compliance with Annexes I and II where those requirements apply. The technical file is mandatory, but every product does not need every biodegradability or microbial test.

Details

Include test reports demonstrating compliance with Annexes I and II where those requirements apply. The technical file is mandatory, but every product does not need every biodegradability or microbial test.

Physical label on packaged products and refill sales Label / instructions Mandatory Public

Details

Packaged products use the label or packaging. For bulk supply, the carrier may be on the accompanying documentation; the specified identification details must also appear on transport containers and in all accompanying documents. Each refill package must receive a physical label and access to the carrier.
Digital label with duplicated core information Label / instructions Conditional Public

Conditional

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 Label / instructions Conditional Public

Conditional

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

Details

For ordinary packaged products, seven specified composition classes may be shown only digitally. Refill sales have a broader exception for composition information, but preservatives and fragrance allergens must remain in the physical information supplied for the refill.
Simplified physical dosage grid for consumer laundry detergents Label / instructions Conditional Public

Conditional

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 Label / instructions Conditional Public

Conditional

If the manufacturer voluntarily chooses a digital label under Article 18. The mandatory DPP remains a separate requirement.

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 Operational duty Conditional

Conditional

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 Operational duty Conditional

Conditional

When the product is offered for distance sale (Article 20).

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.
Instructions for use and special precautions Label / instructions Conditional Public

Conditional

Annex V Part A point 1(e): required where necessary and relevant, including for detergents without micro-organisms.

Module A internal production control Operational duty Mandatory

Details

Annex IV. The conformity assessment procedure is internal production control: the manufacturer itself ensures and declares compliance on its sole responsibility.
Statement that compliance with the Regulation has been demonstrated DPP data Mandatory

Details

The DPP must identify the product so that it can be traced. It must state that compliance with this Regulation has been demonstrated and include references to other Union law with which the product complies, where relevant.
Technical documentation with risk analysis and assessment Technical documentation Mandatory Authorities

Details

Annex IV 2.1. The technical documentation must make it possible to assess compliance and include an adequate analysis and assessment of risks.
Test methods, calculations and examinations supporting Annex I to III compliance Technical documentation Conditional Authorities

Conditional

Relevant where the product falls under the biodegradability, phosphorus or microbial requirements that need documentary evidence.

Details

Annex IV 2.2(c) and (d) covers test methods, calculations for limit values and examination results.
Specimen of the label used for the product Technical documentation Mandatory Authorities

Details

Annex IV requires the technical file to keep a specimen of the label, giving authorities an auditable reference for what was physically and digitally communicated.
Corrective actions, withdrawal or recall records Operational duty Conditional

Conditional

When the manufacturer considers or has reason to believe the product is non-compliant; information duties apply to identified risks under Article 8(8)–(9).

Details

Article 8(8) and 8(9). When the manufacturer has reason to believe the product is non-compliant or risky, corrective action, withdrawal or recall and authority-notification duties are triggered.

No usage tracking and no consumer personal data without consent Operational duty Mandatory

Details

Article 22(h). The passport must be designed and operated so that economic operators do not track, analyse or use any usage information beyond what is strictly necessary to provide it online, and so that personal data of a consumer or other end-user is not stored in the passport without explicit consent under Article 6 of the GDPR.
Passport specific to a product model Operational duty Mandatory

Details

Article 21(2)(a) and recital 45. The default detergents passport is model-level, not per item. A batch or item layer is only used if another Union law requires it.
Persistent unique product identifier linked through a data carrier DPP data Mandatory

Details

Article 21(2)(h). The data carrier connects the passport to a persistent unique product identifier.
Visible, indelible data carrier before purchase Operational duty Mandatory

Details

Article 21(4). The carrier must be indelible, positioned for automated reading and visible before purchase. It appears on the label or packaging, or on accompanying documents for bulk transport. For refill sales, it must also be present on the refill station; Article 17(2) additionally requires a physical label and access to the carrier for each refilled package.
Scan invitation next to the data carrier Operational duty Mandatory

Details

Article 21(4)(e). The data carrier is accompanied by the statement “Please scan for more comprehensive information on the product” or similar wording.
Back-up DPP service-provider reference DPP data Mandatory

Details

Annex VI Part A (c). The passport must identify the service provider hosting the back-up copy, so information remains available even if the primary operator fails.
Registry submission of UPI and UOI and receipt of URID Operational duty Mandatory

Details

Article 24(1)–(2). Before placing the product on the market, the relevant operator uploads its unique product identifier (UPI) and unique operator identifier (UOI) to the registry, which returns a unique registration identifier (URID). Registration is not proof of compliance.
Commodity code in the registry and URID for customs Operational duty Conditional

Conditional

For products intended for the customs procedure of release for free circulation.

Details

Articles 24(1) and 25(2)–(4). The registry stores the commodity code, and the person arranging release makes the URID available to customs. Customs checks the URID and code against the registry. Automated verification through the systems interconnection applies from 23 September 2029 or when that connection becomes operational, whichever is later.
Commodity-code mapping DPP data Conditional

Conditional

Required where a customs classification is relevant for the product.

Details

Annex VI Part A (f) links the passport to the commodity code under Annex I to Regulation (EEC) No 2658/87.
Passport availability for 10 years after placing on the market, including insolvency Operational duty Mandatory

Details

Art. 21(2)(g); Art. 8(3) — EU 2026/405
Accurate, current DPP data in the required languages Operational duty Mandatory

Details

Article 21(2)(d)–(e). Keep the passport accurate, complete and up to date, in the language or languages required by each Member State where the product is made available.
Interoperability, open standards and transferable data Operational duty Mandatory

Details

Article 22(a)–(b). Ensure technical, semantic and organisational interoperability. Use open standards and interoperable formats; data must, as appropriate, be machine-readable, structured, searchable and transferable without vendor lock-in.
Free access according to rights, without consumer registration Operational duty Mandatory

Details

Article 22(c)–(d). Access is free of charge within each actor’s rights. Consumers and other end-users must not have to register or provide a password. Detailed access rights for DPP entries are established under Article 21(10)(d).
Data authenticity, integrity, security and privacy Operational duty Mandatory

Details

Article 22(i)–(j). Ensure data authentication, reliability and integrity, a high level of security and privacy, and protection against fraud.
Supply of the carrier or identifier to distributors and marketplaces Operational duty Mandatory

Details

Article 21(12)(a)–(b). Provide distributors and online marketplaces with a digital copy of the carrier or the UPI. Provide the requested copy or webpage link free of charge, promptly and within five working days.
A single passport and carrier, with links to earlier passports Operational duty Conditional

Conditional

Where other Union law also requires a data carrier or passport, or a new passport replaces or supplements an existing one.

Details

Article 21(5)–(8) and Article 22(f). Where other Union law also requires a carrier or DPP, use a single carrier or passport containing the required information. Keep other information clearly separate. Link any newly created passport to earlier passports for the same product.
Passport storage, back-up and service-provider use of data Operational duty Mandatory

Details

Article 21(12)(c) and Article 22(e), (g). Store the passport with the responsible operator or a service provider and make a back-up copy available through a DPP service provider. Providers must not sell, reuse or process the data beyond what the service requires unless specifically agreed with the operator placing the product on the market.

Ultimate aerobic biodegradability evidence for surfactants Technical documentation Conditional Authorities

Conditional

Except disinfectant active substances meeting Article 4(2).

Details

Surfactant biodegradability requirements have a specific exemption for qualifying disinfectant active substances under Article 4(2). The 2032 requirement covers films or polymers within films, not only water-soluble films. The 2034 rule excludes surfactants, films and polymers within films and allows Annex I Part D derogations.
Films or polymers within films compliance from 23 March 2032 Technical documentation Conditional Authorities

Conditional

Applies to films or polymers within films; compliance deadline under Article 4(3): 23 March 2032.

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 Technical documentation Conditional Authorities

Conditional

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

Surfactant biodegradability requirements have a specific exemption for qualifying disinfectant active substances under Article 4(2). The 2032 requirement covers films or polymers within films, not only water-soluble films. The 2034 rule excludes surfactants, films and polymers within films and allows Annex I Part D derogations.
Consumer laundry detergent phosphorus limit (< 0.5 g) Technical documentation Conditional Authorities

Conditional

Applies to consumer laundry detergents.

Details

Consumer laundry detergents must contain less than 0.5 g total phosphorus in the specified recommended dose for a standard load in hard water. Consumer automatic dishwasher detergents must contain less than 0.3 g in the standard dose. These are strict limits, supported by technical evidence.
Consumer automatic dishwasher detergent phosphorus limit (< 0.3 g) Technical documentation Conditional Authorities

Conditional

Applies to consumer automatic dishwasher detergents.

Details

Consumer laundry detergents must contain less than 0.5 g total phosphorus in the specified recommended dose for a standard load in hard water. Consumer automatic dishwasher detergents must contain less than 0.3 g in the standard dose. These are strict limits, supported by technical evidence.
Dosage instructions for laundry, dishwasher and surface detergents Label / instructions Conditional Public

Conditional

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

These examples illustrate possible label, DPP and authority views. They are not a final DPP access matrix: consumer label information is public, but access to each minimum Annex VI passport field must follow the Article 21(10)(d) implementing act.

Data field	Public	Authorities
Ingredient disclosure	Label information: the applicable composition declarations, preservatives, fragrance allergens and UFI. Access to the full DPP substance list follows the rights set under Article 21(10)(d).	Ingredients data sheet with detailed composition and information for poison centres and appointed bodies responding to health emergencies
Microbial detergent record	Label information: shelf life and relevant food-contact restrictions or precautions. Access to the DPP taxonomy follows the rights set under Article 21(10)(d).	Annex II risk-assessment report, test evidence and supporting technical documentation
Compliance record	Product identification and access through the data carrier. Access to individual DPP entries, including the compliance statement, follows the rights set under Article 21(10)(d).	Technical file, test methods, calculations, label specimen and registry-linked compliance checks

Additional compliance data are not automatically DPP fields. Annex VI concerns the passport, Annex V labels, and Annex IV documentation and the conformity assessment procedure.

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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