New Detergents Regulation: what you need to know | Coffee-Break Webinar recap
On 15 October we hosted our Coffee-Break Webinar on the new Detergents Regulation (EU) 2026/405. Here is what you need to know.
A completely new regulation
This is not an update to the old Detergents Regulation (EC) 648/2004. It is a completely new regulation with a new number: (EU) 2026/405. The difference is not cosmetic: the entire framework has changed, and you will notice it across five areas.
From product check to supply chain focus
The old regulation was essentially a product check: does your detergent meet the requirements, yes or no? The new regulation looks much broader. Not just at the product itself, but at who can demonstrate that the product complies, and who carries out those compliance checks. This shift from product focus to supply chain focus fits a wider trend in EU legislation, including the CLP legislation.
Responsibilities across the entire chain
Where the manufacturer used to be the sole responsible party, the new regulation addresses the full supply chain: from manufacturer and importer to distributor and retailer. Each link in the chain gets specific responsibilities. More complex, but also more transparent.
Evidence and technical documentation
Under Regulation 648/2004, the focus was on biodegradability test data for surfactants, and you only had to produce it on request. Now, significantly more technical documentation is required, including conformity assessments. Who in the chain assessed whether the product complies, how, and is it documented? The Digital Product Passport (DPP) becomes mandatory for both end products and surfactants.
Information: DPP and digital labelling
The information requirements are changing significantly. Under the old legislation, it was mainly about the label and the ingredient data sheets (IDSs), aimed at consumer products. Now the DPP and digital labelling are added, for consumer, professional and industrial products alike. Even for detergents without a hazard classification, a European-level database for sharing product information will be established.
Enforcement and the role of customs
The old regulation largely left enforcement to the Member State where the product was placed on the market. The new regulation dedicates a substantial part of the legal text to how enforcement will work. Customs will play an active role: the DPP will be linked to the customs system, and without a valid DPP, a product will not enter the EU. Additionally, the regulation introduces the Authorised Representative (AR), a new link bridging the gap between manufacturers and authorities.
What is a detergent? A broader definition
The definition has expanded. Under the old regulation, a detergent was essentially a product intended for cleaning. The new definition in Article 2 of Regulation (EU) 2026/405 also covers products that make textiles feel or smell differently during complementary washing processes, and products that support cleaning when used together with a laundry or dishwasher detergent.
In practice, this means products such as laundry perfumes, scent boosters and similar products now fall under the Detergents Regulation. It may go even further: for products like dry-wash sprays or shoe deodorants, it is not yet entirely clear whether they fall within the definition.
Requirements for professional detergents have also been tightened. Under the old regulation, professional products had milder requirements. That distinction has largely disappeared.
Just as important: not only the end product falls under the regulation, but also the surfactants themselves. They will also need a DPP, must undergo conformity assessments, and must meet all relevant requirements throughout the chain.
The timeline
The regulation was published on 2 March 2026 and entered into force on 22 March 2026. That means the law formally applies, but most substantive requirements only take effect from 23 September 2029.
Three years sounds like plenty of time, but the legislator still needs to finalise a number of details, and industry must prepare for significant changes.
| Deadline | What? |
|---|---|
| 22 March 2026 | Regulation (EU) 2026/405 entered into force |
| 23 September 2029 | Application date: nearly all requirements take effect; Regulation (EC) 648/2004 is repealed |
| 23 September 2030 | End of transitional period for products placed on the market after Sept 2029 under the old rules |
| 23 March 2032 | Biodegradability requirements for films and polymers in films |
| 23 March 2034 | Biodegradability requirements for organic substances at concentrations of 10% or more |
Several elements still need to be worked out by the legislator: the risk assessment for micro-organisms, the rules for digital labelling, the reduction of phosphorus and phosphorus compounds, and the test criteria for the biodegradability of films and organic substances. Until those are finalised, the full picture of what compliance looks like remains incomplete.
Do not expect the market to sit still until 2029, either. When new allergen requirements were introduced, major retailers started asking questions two years before the deadline. Expect the same to happen here.
The transitional period
Article 36 sets out a transitional arrangement that is notable and, frankly, unusual in its design.
Products placed on the market before 22 September 2029 in compliance with the old Regulation (EC) 648/2004 may continue to be made available on the market indefinitely. In other words: whatever is in the distribution chain before that date can keep being sold.
For products placed on the market after 22 September 2029 but before 23 September 2030 that still comply with the old regulation, a one-year transitional period applies. After 23 September 2030, those products may no longer be made available on the market. They must either be brought into compliance with the new requirements or withdrawn.
This is an unusual construction. The expectation is that it is designed to give major retailers certainty: if you have it sorted before September 2029, you are fine.
Supply chain communication
Communication across the supply chain is becoming critical, and not just with your direct supplier, but with the entire chain behind them.
Biodegradability and carry-over substances
A good example of how supply chain communication will need to intensify is the biodegradability of organic substances. Once the requirements for these substances take effect, every component in your formulation needs to be accounted for. That includes carry-over substances such as in-can preservatives: biocides used to preserve raw materials that end up in your finished product. Until now, these were rarely scrutinised, but under the new regulation you need to know exactly which substances they are and in what quantities. That information has to come from your supply chain.
The same applies to biodegradability data for raw materials. If those raw materials come from outside the EU, you will need to explain to your suppliers why you need that information. Without it, neither the raw material nor the end product can be placed on the EU market.
Allergens: decoupled from cosmetics
Allergen requirements have also been tightened. The allergen list was previously linked to the Cosmetics Regulation (EC) 1223/2009. That link has been dropped: the allergens are now specified directly in the Detergents Regulation. Additional allergens have been added that fall under detergent legislation but not under cosmetics. A standard allergen list based on the Cosmetics Regulation (like an IFRA list) was already insufficient, and under the new regulation that becomes even clearer.
The Digital Product Passport
Beyond the detergent itself, the Digital Product Passport covers much more ground. It also includes packaging information and other aspects. As a result, anyone already working on the PPWR (Packaging and Packaging Waste Regulation) knows that communicating this kind of data across the supply chain is not easy. This will be no different.
Your direct supplier is not necessarily the manufacturer of the raw material. It can be three, four or five steps further before you reach the party with sufficient knowledge about the substance. The complexity of the supply chain makes this one of the biggest challenges of the new regulation.
Frequently asked questions
What is the difference between the old and the new Detergents Regulation?
Regulation (EC) 648/2004 was primarily a product-focused law: does the product comply, yes or no? Regulation (EU) 2026/405 looks at the entire supply chain. Every link, from manufacturer to distributor, receives specific responsibilities. In addition, the Digital Product Passport, conformity assessments and broader biodegradability requirements are introduced.
When do I need to comply with the new Detergents Regulation?
The regulation entered into force on 22 March 2026. Most substantive requirements apply from 23 September 2029. For biodegradability of films the deadline is 23 March 2032; for organic substances (≥10%) it is 23 March 2034.
What changes in the definition of 'detergent'?
The definition has broadened. Beyond cleaning products, it now also covers products that make textiles feel or smell differently during washing, as well as products that support cleaning in combination with a laundry detergent. Think of laundry perfumes and scent boosters.
Do I need a Digital Product Passport (DPP) for my detergent?
Yes. From 23 September 2029, a DPP is mandatory for detergents and for surfactants made available directly to end users. The DPP will also be linked to the EU customs system.
Does the new regulation apply to industrial and professional detergents?
Yes. Under the old regulation, professional products had milder requirements. That distinction has largely disappeared under Regulation (EU) 2026/405. Professional and industrial detergents must also meet the new requirements, including DPP and conformity assessments.
What are carry-over preservatives and why do they matter?
Carry-over preservatives (or in-can preservatives) are biocides that suppliers use to preserve raw materials. These substances end up in your finished product. Under the new regulation, you need to know exactly which substances they are and in what quantities, because they too must meet the biodegradability requirements.
More to follow
This article gives an overview. In the coming months we will go into each topic in depth.
We are working on a series of articles breaking down the regulation step by step: responsibilities per link in the chain, product compliance and conformity assessments, carry-over preservatives, allergens, digital labelling, the physical label and the DPP.
We will also be back with more Coffee-Break Webinars in the series "Pop the Bubble", where we highlight the key elements of the regulation, including specific attention to products from outside the EU.
And in our podcast 'The Regulatory Vibe' we will cover not just the letter of the law, but also the practice: where will you run into problems, what are the expected bottlenecks, and how can you best prepare?
Questions, dilemmas or ideas for topics? We would love to hear from you. And anyone who is interested is welcome as a guest on our podcast.
Get in touch via info@thesdsfactory.com or call +31 85 009 2200.
