With Regulation (EU) 2026/405, the European Union has fundamentally revised the legal framework for detergents for the first time in more than twenty years.[1] The previous Regulation (EC) No. 648/2004 will be repealed on September 23, 2029; transitional provisions apply to products already on the market until September 2030.[2]
For manufacturers, one question stands out above all others: Which requirements are actually changing compared to the previous legal situation? This article highlights the most important changes from the perspective of regulatory affairs and product managers and categorizes them based on whether they are new, amended, or essentially unchanged requirements.
What will stay the same—and what will change?
The fundamental objective of the regulation remains unchanged: to ensure the free movement of detergents within the EU while also ensuring a high level of protection for human health and the environment. [3]
Many familiar requirements—particularly those regarding the biodegradability of surfactants—therefore remain in place. The main changes relate instead to digitization, the responsibilities of economic operators, new product types, and the provision of regulatory information.
The following table provides a brief overview of what has changed and to what extent, as well as the resulting obligations for manufacturers.
| No. | Topic | Classification | Implications for Manufacturers |
|---|---|---|---|
| 1 | Responsibilities of Economic Operators and Technical Documentation | Changed | Stricter documentation and record-keeping requirements, as well as formalized conformity assessment |
| 2 | Digital Product Passport (DPP) | New | Introduction of a digital product passport with structured product information |
| 3 | Labeling and Ingredient Information | Changed | Physical labeling is supplemented by digital information; revision of how information is provided; refer to the information in the safety data sheet |
| 4 | New Product Groups (Microorganisms) | New | For the first time, specific requirements for detergents containing intentionally added microorganisms |
| 5 | Refill Stations and Refill Systems | New | For the first time, separate requirements for the provision of detergents through refills |
| 6 | Biodegradability | Largely unchanged | Existing requirements will remain in effect; plans are in place to expand to additional substance groups at a later date |
| 7 | Distance Selling and Advertising | Changed | Additional Disclosure Requirements Prior to Contract Conclusion and Stricter Requirements for Digital Product Information |
Each of these points will be explained in detail in the next section.
The Most Important Changes for Manufacturers
1. Increased Responsibilities and Technical Documentation
The new regulation is more closely aligned with the fundamental principles of European product safety law. In the future, manufacturers must be able to demonstrate that their products meet all the requirements of the regulation. These include, among other things, a conformity assessment, technical documentation, and defined obligations for manufacturers, importers, and distributors. [4]
For many companies, this does not mean entirely new processes, but it does mean a significantly greater degree of formalization. Technical documentation is becoming increasingly important and should be managed in the future using a structure similar to that already established in other European product regulations.
2. The Digital Product Passport as a Key Innovation
The most significant practical change is the introduction of the Digital Product Passport (DPP). For the affected detergents, digital product information must in the future be made available via a data carrier—such as a QR code. [5]
However, the DPP does not replace traditional labeling. Rather, it creates a two-tiered information system consisting of physical labeling and digitally provided information. Manufacturers should therefore assess early on whether their existing product data or product information management systems can manage the required information in a structured manner.
For more background information, see our article on the Digital Product Passport in the context of sustainability.
Companies whose product data has been scattered across various systems—such as safety data sheets, ERP systems, and marketing databases—are particularly affected.
3. Labeling and Ingredient Information
Labeling requirements are being modernized and better aligned with digital information concepts. At the same time, safety-related information must still be displayed directly on the product. [6]
The requirements for ingredient information are also being revised. For manufacturers, this means, in particular, that existing processes for maintaining the information required under Annex VII should be reviewed. Companies that have thus far been compiling this information largely manually should consider whether automated generation would be beneficial in the future.
You can learn more about ingredient labeling for detergents compared to REACH in our in-depth article.
In addition, the new Detergents Regulation should also be taken into account when preparing the safety data sheet. For products falling within the scope of Regulation (EU) 2026/405, it must be determined whether this regulation should be listed as the relevant EU legislation in Section 15.1 of the safety data sheet. The basis for this is Annex II, Part A, Section 15.1 of the REACH Regulation.[7] Therefore, when transitioning from the previous Regulation (EC) No. 648/2004, the corresponding information in the SDS should also be reviewed and updated as necessary.
Our article on updating safety data sheets explains what other changes need to be taken into account during ongoing maintenance.
4. New Product Group: Microorganisms in the Scope of Application
The previous regulation was enacted at a time when microorganism-based cleaning products did not yet play a significant role.
The new regulation not only defines new terms in this regard but also sets forth specific requirements for safety assessment and labeling. Among other things, it provides for additional instructions on safe use as well as product-specific information, such as shelf life or specific restrictions on use. [8]
For manufacturers of such products, this means that existing product evaluations must be reviewed and, if necessary, updated.
5. Refill Stations and Refill Systems
With the growing popularity of refill systems, the new regulation establishes, for the first time, a separate legal framework for the distribution of detergents through refill stations. Both the term “refill” and the refill station are defined. In addition, specific obligations for the economic operators providing these services are established. [9]
Companies that offer detergents through refill stations must take appropriate measures to minimize risks to consumers. These include, in particular, measures to protect children, as well as organizational precautions to ensure that different products within a refill station do not mix with one another or react dangerously. [10]
It is also worth noting that the dispensing of a product via a refill station is expressly not considered packaging or repackaging. This results in distinct regulatory requirements for manufacturers and retailers that differ from those for traditional filling processes. [11]
The new regulation provides, for the first time, a clearly defined legal framework—particularly for companies that develop sustainable packaging concepts or reusable systems.
6. Biodegradability remains a priority—with an eye toward future expansions
The established requirements for the complete aerobic biodegradability of surfactants remain fundamentally unchanged.
What is new, however, is that the European Commission’s regulation explicitly provides for the possibility of extending the requirements to additional groups of substances in the future. Specifically mentioned are water-soluble polymer films and other organic substances, provided that new scientific findings justify such an extension. [12]
Therefore, manufacturers currently have no immediate need to make adjustments. However, the development of delegated acts should be closely monitored.
7. Distance Selling and Advertising
The new regulation also places greater emphasis on online retail. When detergents are offered for sale at a distance, the essential labeling information must be clearly and prominently displayed before the purchase contract is concluded. In addition, a digital copy of the data carrier or the unique product identifier must be provided so that consumers can access the digital product information before making a purchase. [13]
For manufacturers, this means that product information on packaging, company websites, and online stores must be consistent. Marketing, e-commerce, and regulatory affairs should therefore work closely together to avoid conflicting or incomplete information.
Conclusion
The new Detergents Regulation is much more than just an update to the previous regulations. While numerous technical requirements—such as those regarding the biodegradability of surfactants—remain largely unchanged, the main change lies in the way manufacturers manage and provide regulatory information.
The Digital Product Passport, digital labeling, new requirements for products containing microorganisms, and the increased integration of distance selling make it clear that, in the future, the focus will no longer be solely on a product’s chemical composition, but equally on its digital documentation.
Companies should use the transition period through September 2029 to align their product data, labeling processes, and technical documentation with the new requirements well in advance. It is particularly beneficial to involve Regulatory Affairs, Product Management, IT, and E-Commerce in this process. This approach allows for more efficient implementation of future adjustments and helps avoid duplication of effort.
Checklist for Manufacturers
- Update technical documentation and conformity assessment.
- Document responsibilities within the supply chain.
- Prepare the data foundation for the Digital Product Passport.
- Check the labeling and consumer information.
- Review the product portfolio for new areas of application.
- Evaluate requirements for refill systems.
- Update the online store and distance selling information.
Sources
[1] https://eur-lex.europa.eu/legal-content/DE/TXT/PDF/?uri=OJ:L_202600405&qid=1783327505203
[2] https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202600405&qid=1783327505203#art_36
[3] https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202600405&qid=1783327505203#art_1
[4] https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202600405&qid=1783327505203#cpt_III
[5] https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202600405&qid=1783327505203#cpt_V
[6] https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202600405&qid=1783327505203#cpt_IV
[8] https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202600405&qid=1783327505203#anx_II
[10] https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202600405&qid=1783327505203#art_12
[11] https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202600405&qid=1783327505203#014.002
[12] https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202600405&qid=1783327505203#anx_I
[13] https://eur-lex.europa.eu/legal-content/DE/TXT/HTML/?uri=OJ:L_202600405&qid=1783327505203#art_20
