DetR - Regulation (EC) No 648/2004

What DetR is and why it matters

The Detergents Regulation (DetR) — formally Regulation (EC) No 648/2004 on detergents — is the EU’s dedicated law for placing detergents and the surfactants they contain on the market. If you manufacture, brand or import cleaning products of almost any kind, it applies to you. DetR harmonises two things across the Union: the biodegradability that surfactants must achieve, and the information that has to reach consumers, professionals and medical staff about what is in the product. By setting one rulebook for all Member States, it removes the patchwork of national detergent rules that existed before and lets a compliant product move freely across the single market.

DetR matters because detergents are high-volume consumer chemicals that end up in wastewater and watercourses, and because their ingredients can trigger allergies. The Regulation therefore couples an environmental test — that surfactants break down fully in the environment — with transparency obligations that let an allergic consumer avoid a fragrance they react to and let a poisons centre treat an exposed patient quickly. For a brand owner, DetR is the rule that decides whether a cleaning product is lawful to sell at all, sitting alongside the broader chemicals regime rather than replacing it.

📄 Official text: Regulation (EC) No 648/2004 on detergents — on EUR-Lex →

Who DetR applies to

DetR applies to anyone who places a detergent or a surfactant for a detergent on the EU market. The duties fall mainly on the person responsible for first making the product available:

Manufacturers — anyone who produces a detergent or a surfactant intended for use in detergents, or who has it made and markets it under their own name or trademark. They carry the core obligations for biodegradability testing and ingredient information.
Importers — businesses bringing detergents or surfactants from outside the EU into the Union market. They step into the responsible-person role and must ensure the imported product meets DetR before it is sold.
Distributors and retailers — actors further down the chain who should sell only products that carry the required labelling and supporting information.

The Regulation covers a broad range of products: laundry detergents, dishwasher and hand-dishwashing products, all-purpose and surface cleaners, rinse aids, soaps, and industrial and institutional cleaning preparations. A “detergent” under DetR is any substance or mixture containing soaps or other surfactants intended for washing and cleaning processes, and the rules reach both the finished detergent and the surfactant as an ingredient.

Core requirements

Ultimate biodegradability of surfactants

The environmental heart of DetR is that surfactants used in detergents must be ultimately aerobically biodegradable. “Ultimate” biodegradability means the surfactant is broken down completely by micro-organisms into carbon dioxide, water and mineral salts, not merely altered into a persistent breakdown product. A surfactant that fails the relevant test methods set out in the Regulation’s annexes may not be placed on the market in a detergent. Limited derogations exist for certain surfactants — for example in some industrial or institutional uses — but these require a risk assessment and authorisation rather than being freely available. Manufacturers must hold the test results and technical documentation demonstrating that each surfactant meets the standard, and make them available to the competent authorities on request.

Ingredient labelling, fragrance allergens and the data sheet

DetR sets specific labelling rules that go beyond ordinary product labels. The packaging must list certain classes of constituents — such as phosphates, bleaching agents, preservatives and others — within defined concentration bands, so a user can see what the product contains. Crucially, allergenic fragrance substances above a set threshold must be named on the label, allowing consumers who react to specific fragrance allergens to avoid them. Consumer laundry and dishwasher detergents must also carry dosage information.

Beyond the label, manufacturers must make a full list of ingredients available — historically on a website for consumer products — and must compile an ingredient data sheet giving the complete composition of the product. This data sheet must be made available, on request and without delay, to medical personnel so that a doctor or poisons centre can treat someone who has swallowed or been exposed to a detergent. These transparency duties are a defining feature of DetR and distinguish it from the general labelling rules that apply to other mixtures.

Restrictions on phosphates and phosphorus compounds

DetR restricts the use of phosphates and other phosphorus compounds in certain detergents to limit nutrient pollution and eutrophication of waterways. In particular, the Regulation sets limits that effectively phase out phosphates in consumer laundry detergents and in consumer automatic dishwasher detergents above a low phosphorus threshold. These restrictions were introduced through amendments to DetR and apply across the Union, so a reformulation that complies in one Member State complies everywhere. Industrial and institutional products are treated differently, but consumer-facing laundry and dishwasher products are the clearest case where phosphate content can render a product non-compliant.

Interplay with REACH and CLP

DetR does not sit in isolation. A detergent and its ingredients are also subject to the EU’s general chemicals framework: REACH (Regulation (EC) No 1907/2006) for registration, evaluation and restriction of the substances used, and CLP (Regulation (EC) No 1272/2008) for classification, labelling and packaging of any hazardous mixture. In practice a detergent that is classified as hazardous must carry CLP hazard pictograms, signal words and hazard and precautionary statements in addition to the DetR ingredient and allergen labelling, and its substances must be REACH-compliant. DetR therefore layers detergent-specific transparency and biodegradability duties on top of the obligations every chemical product already carries.

Obligations by role

Manufacturers — ensure surfactants meet ultimate biodegradability, hold the test data and technical documentation, apply DetR labelling including fragrance allergens and dosage, publish the ingredient list, prepare the medical data sheet, and respect phosphate restrictions.
Importers — verify that the detergent and its surfactants meet DetR before placing them on the market, and take on the responsible-person duties for documentation and information.
Distributors and retailers — handle and sell only products that carry the required labelling and supporting information.

Enforcement

DetR is enforced by the competent authorities designated in each Member State, which carry out market surveillance, can require documentation and test data, and can stop the sale of non-compliant detergents. In Denmark, detergent and chemical rules are overseen by the Danish Environmental Protection Agency (Miljøstyrelsen) under the Ministry of the Environment, working with the wider chemical inspection system.

Because DetR is a regulation, it is directly applicable in every Member State without national transposition, so the substantive requirements are the same across the EU. Consequences for non-compliance are set at national level and can include orders to withdraw products, sales bans, and fines. The practical risk for a brand is that a missing data sheet, an unlabelled fragrance allergen, a non-biodegradable surfactant or an over-the-limit phosphate level can each make a product unlawful to sell.

Getting compliant

Confirm your product is a detergent or surfactant within the scope of DetR.
Obtain and retain test data showing every surfactant is ultimately biodegradable.
Apply DetR labelling: constituent classes in the right concentration bands, fragrance allergens above the threshold, and dosage information for consumer laundry and dishwasher products.
Publish the ingredient list and prepare an ingredient data sheet you can supply to medical personnel without delay.
Check phosphate and phosphorus content against the limits for consumer laundry and dishwasher detergents.
Make sure the product also meets REACH and CLP, including hazard classification and labelling where it applies.

A modernised Detergents Regulation is coming

A recast Detergents Regulation has been adopted to modernise these rules and bring them up to date with developments such as digital labelling, refill sales and microorganism-based products, and it will in time replace Regulation (EC) No 648/2004. The core principles described here — biodegradability of surfactants and ingredient transparency — carry through, but brands should track the recast’s application dates and any new obligations as they take effect. Until then, Regulation (EC) No 648/2004 remains the law in force.

How Conphora helps

Conphora monitors DetR and maps your detergents against its requirements, flagging gaps in biodegradability evidence, ingredient and fragrance-allergen labelling, the medical data sheet and phosphate limits before they become enforcement problems. The platform helps you generate and keep the right documentation, and alerts you when the rules change — including the move to the recast Detergents Regulation — so your compliance stays current.

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Sources and further reading

This guide is for general information and is not legal advice.

Last updated: 12 June 2026