---
title: "DetR — Detergents Regulation"
description: "The Detergents Regulation harmonises the rules for detergents and surfactants on the EU market, requiring biodegradable surfactants, ingredient and dosage labelling and phosphorus limits, and makes the manufacturer, meaning whoever places the product on the market, responsible. It has applied since 8 October 2005 and is repealed from 23 September 2029 by Regulation (EU) 2026/405."
type: "guide"
url: "https://www.conphora.com/regulations/detr/"
markdown: "https://www.conphora.com/regulations/detr.md"
locale: "en"
language: "en"
published: "2005-10-08"
updated: "2026-09-11"
author: "Conphora compliance team"
publisher: "Conphora"
reference: "Regulation (EC) No 648/2004"
celex: "32004R0648"
source: "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32004R0648"
tags: ["DetR", "Chemicals & Substances"]
license: "Free to quote with attribution and a link to the page"
---

# DetR — Detergents Regulation

The Detergents Regulation harmonises the rules for detergents and surfactants on the EU market, requiring biodegradable surfactants, ingredient and dosage labelling and phosphorus limits, and makes the manufacturer, meaning whoever places the product on the market, responsible. It has applied since 8 October 2005 and is repealed from 23 September 2029 by Regulation (EU) 2026/405.

## Key facts

- **Official title:** Regulation (EC) No 648/2004 of the European Parliament and of the Council of 31 March 2004 on detergents
- **Reference:** Regulation (EC) No 648/2004
- **CELEX:** 32004R0648
- **Act type:** Regulation
- **In force:** 2005-10-08
- **Applies from:** 2005-10-08
- **Enforced by:** The competent authorities appointed by each Member State under Article 8 enforce the regulation with the control measures of Article 10, the safeguard clause of Article 15 and the market surveillance powers of Regulation (EU) 2019/1020, which lists Regulation (EC) No 648/2004 in its Annex I; in Denmark, Miljøstyrelsen's chemicals inspection (Kemikalieinspektionen) supervises detergents under the chemicals act (lov om kemikalier, lovbekendtgørelse nr. 1200 of 25 September 2025). The toolkit is orders to end the unlawful situation, stop sales, warn users, remedy the cause, recall or destroy the product (kemikalieloven § 48), detention of non-compliant consignments and provisional withdrawal, recall or restriction of a detergent that presents a risk (Articles 15 and 18), and national penalties that must be effective, proportionate and dissuasive, in Denmark a fine for infringing an EU regulation on substances, mixtures or articles covered by the chemicals act (§ 59(1)(1)), rising to imprisonment of up to two years where the infringement is intentional or grossly negligent and has harmed or endangered the life or health of people or domestic animals or the environment, or has obtained or was intended to obtain an economic advantage (§ 59(2)), with criminal liability for companies under § 60 and a five-year limitation period under § 61.
- **Category:** Chemicals & Substances

## Who it applies to

**Covered by the act:** Detergents: any substance or mixture containing soaps or other surfactants intended for washing and cleaning processes, in any form and for household, institutional or industrial use, plus auxiliary washing mixtures for soaking, rinsing or bleaching, laundry fabric softeners, cleaning mixtures for all-purpose and surface cleaning and other cleaning and washing mixtures; Surfactants for detergents, whether sold on their own or as ingredients; Consumer laundry detergents and consumer automatic dishwasher detergents, which also carry the phosphorus limits and the dosage labelling; Industrial and institutional detergents used outside the domestic sphere by specialised personnel, with lighter labelling and a derogation route for surfactants that fail ultimate biodegradability; The manufacturer, meaning the person responsible for placing the detergent or surfactant on the Union market, including producers, importers, packagers working for their own account and anyone changing the characteristics or labelling

**Derived and downstream products:** Import into the Union customs territory is placing on the market, so the importer is the manufacturer under the regulation and must be established within the Community (Art. 2(9), Art. 2(10) and Art. 3(2)); A distributor who does not change the characteristics, labelling or packaging is not a manufacturer, but one who repackages, relabels or acts as importer is (Art. 2(10)); Surfactants that are biocidal active substances used as disinfectants are exempt from the biodegradability annexes II, III, IV and VIII under the conditions of Article 3(1), and the detergent that contains them is then labelled as containing a disinfectant, while the Annex VII A labelling and the other duties of the regulation still apply; Article 3(1) still names Directive 98/8/EC, but that directive was repealed with effect from 1 September 2013 by Regulation (EU) No 528/2012, whose Article 96 provides that references to it are construed as references to that regulation and read in accordance with the correlation table in its Annex VII, so the exemption is applied today under the Biocidal Products Regulation, which is also how Regulation (EU) 2026/405 Art. 4(2) writes it out; The regulation is without prejudice to REACH and to the classification, labelling and packaging rules of the CLP Regulation, including the poison-centre notification of Article 45 CLP (Art. 9(1) and Art. 11(1)); Regulation (EU) 2026/405 repeals the regulation with effect from 23 September 2029 and adds micro-organism detergents, digital labelling, refill supply, a digital product passport and explicit obligations for manufacturers, authorised representatives, importers and distributors (Regulation (EU) 2026/405, Art. 2(1), Art. 8 to Art. 12, Art. 21, Art. 35 and Art. 37)

**Roles under the act:**

- **Manufacturer (the party responsible for placing on the market, including brand owners and packagers)** — The natural or legal person responsible for placing a detergent or a surfactant for a detergent on the market; in particular, a producer, an importer, a packager working for his own account, or any person changing the characteristics of a detergent or of a surfactant for a detergent, or creating or changing the labelling thereof, is deemed to be a manufacturer. Manufacturers must be established within the Community and are responsible for the conformity of their products.
- **Importer** — Import into the Union customs territory is deemed to be placing on the market, and an importer is deemed to be a manufacturer; the importer therefore carries every manufacturer duty of the regulation for the detergents and surfactants it brings into the Union.
- **Distributor (wholesaler or retailer)** — A distributor who does not change the characteristics, labelling or packaging of a detergent, or of a surfactant for a detergent, is not deemed to be a manufacturer, except where he acts as an importer; distributors must respect national language requirements for the labelling of contents and dosage.

## Key dates

- 2004-03-31: Regulation (EC) No 648/2004 adopted by the European Parliament and the Council
- 2004-04-08: Published in OJ L 104 of 8 April 2004, p. 1
- 2005-10-08: Entry into force and direct application in all Member States; Directives 73/404/EEC, 73/405/EEC, 82/242/EEC, 82/243/EEC and 86/94/EEC and Recommendation 89/542/EEC repealed on the same day
- 2006-07-11: Regulation (EC) No 907/2006 in force: Annex III replaced, adding ISO 10708:1997 as a sixth ultimate biodegradability test method
- 2007-01-12: New Annex VII applies: allergenic fragrances above 0,01 % declared however they are added, the website address for the ingredient list on the packaging, and INCI names in the public ingredient list
- 2009-01-20: Regulation (EC) No 1336/2008 in force: the term preparation replaced by mixture throughout the text to align with the CLP Regulation
- 2009-04-20: Regulation (EC) No 219/2009 in force: Article 12 on the committee procedure replaced (M3 in the consolidated text)
- 2009-06-27: Regulation (EC) No 551/2009 in force: Annex V lists the first derogated surfactant, alcohols, Guerbet, C16-20, ethoxylated, n-butyl ether (7-8EO), for bottle washing, cleaning-in-place and metal cleaning until 27 June 2019; Annex VI (banned surfactants) stays empty
- 2012-04-19: Regulation (EU) No 259/2012 in force: Article 4a and Annex VIa on phosphorus limits, the definitions of consumer laundry and consumer automatic dishwasher detergent, dosage labelling in Article 11(4) and Annex VII B, delegated acts in Articles 13 and 13a, and the new Articles 14, 16 and 18
- 2013-06-30: Consumer laundry detergents with a total phosphorus content of 0,5 g or more per recommended dose for a standard load in hard water may no longer be placed on the market
- 2015-06-01: Points 2 and 3 of Article 1 of Regulation (EC) No 1336/2008 apply: Article 9(1) and Article 11(1) refer to Regulation (EC) No 1272/2008 (CLP) instead of the old classification directives
- 2017-01-01: Consumer automatic dishwasher detergents with a total phosphorus content of 0,3 g or more in the standard dosage may no longer be placed on the market
- 2019-06-27: End of the Annex V derogation for alcohols, Guerbet, C16-20, ethoxylated, n-butyl ether (7-8EO) in industrial applications
- 2026-03-02: Regulation (EU) 2026/405 on detergents and surfactants, signed on 11 February 2026, published in OJ L 2026/405
- 2026-03-22: Regulation (EU) 2026/405 enters into force; its Article 4(3) and (4) apply from this date, setting biodegradability deadlines of 23 March 2032 for films and 23 March 2034 for other organic substances added at 10 % or more
- 2029-09-23: Regulation (EC) No 648/2004 repealed; Regulation (EU) 2026/405 applies in full; detergents and surfactants placed on the market before this date in compliance with the old regulation may continue to be made available indefinitely
- 2030-09-23: End of the transitional window: detergents and surfactants placed on the market between 23 September 2029 and 22 September 2030 under the old rules may be made available until this date

## What you must do

### Manufacturer (the party responsible for placing on the market, including brand owners and packagers)

- Be established within the Community and take responsibility for the conformity of your detergents and surfactants with the regulation and its annexes, and where relevant with the biocides rules and other Community legislation.
- Use only surfactants that meet the Annex III criteria for ultimate aerobic biodegradation: at least 60 % mineralisation within 28 days in one of the six point A tests, or at least 70 % in the two point B DOC methods where justified; for industrial or institutional detergents, apply to the competent authority and the Commission for a derogation where a surfactant fails Annex III but passes the 80 % Annex II primary biodegradability test.
- Use only surfactants that meet the Annex III criteria for ultimate aerobic biodegradation: at least 60 % mineralisation within 28 days in one of the six point A tests, or at least 70 % in the two point B DOC methods where justified.
- For an industrial or institutional detergent with a surfactant that fails Annex III but passes the 80 % Annex II primary biodegradability test, apply to the competent authority and the Commission for a derogation before using it.
- Have the tests carried out under the Annex I standards, EN ISO/IEC 17025 or the principles of good laboratory practice, and hold at the disposal of the competent authorities the results of the Annex III tests, the Annex II and IV technical files for any derogation request, and documentation showing that the tests were performed correctly and that you may use the test results.
- Have the tests carried out under the Annex I standards, EN ISO/IEC 17025 or the principles of good laboratory practice.
- Hold at the disposal of the competent authorities the results of the Annex III tests, the Annex II and IV technical files for any derogation request, and documentation showing that the tests were performed correctly and that you may use the test results.
- Keep an ingredient datasheet per Annex VII C, naming the detergent and the manufacturer and listing every ingredient in decreasing order of weight within the bands 10 % or more, 1 % to below 10 %, 0,1 % to below 1 % and below 0,1 %, with the common or IUPAC name, the INCI name where available, the CAS number and the European Pharmacopoeia name, and make it available without delay and free of charge to any medical personnel on request.
- Label the consumer packaging legibly, visibly and indelibly with the product name and trade name, the name or trade mark, full address and telephone number of the party responsible for placing the product on the market, and the address, email address where available and telephone number from which the datasheet can be obtained; put the same information on the documents accompanying bulk shipments.
- Declare the contents per Annex VII A: the eighteen listed constituent classes, from phosphates and the four surfactant classes to bleaching agents, EDTA, NTA, hydrocarbons, soap, zeolites and polycarboxylates, in the bands below 5 %, 5 % to below 15 %, 15 % to below 30 % and 30 % and more where added above 0,2 %; enzymes, disinfectants, optical brighteners and perfumes whenever added; preservatives by their common nomenclature; allergenic fragrances above 0,01 % by name; plus the website address of the ingredient list, instructions for use and special precautions.
- For consumer laundry detergents, give the recommended quantities or dosage in millilitres or grams per standard load for soft, medium and hard water, the number of standard loads per package in medium-hard water, and the capacity and markings of any measuring cup; for consumer automatic dishwasher detergents, give the standard dosage for a fully loaded 12 place settings dishwasher, with water-hardness variants where relevant.
- Publish the ingredient list on a website per Annex VII D, with INCI names or the European Pharmacopoeia, common or IUPAC name, the words parfum and colorant for perfumes and colourants, allergenic fragrances above 0,01 % listed by name, without percentage bands or CAS numbers, freely accessible, kept up to date and linked to a table of correspondence between INCI names, Pharmacopoeia names and CAS numbers; industrial and institutional detergents with a technical or safety data sheet are exempt.
- Keep the total phosphorus content below 0,5 g per recommended dose for a standard load in hard water in consumer laundry detergents and below 0,3 g per standard dosage in consumer automatic dishwasher detergents; products at or above those limits may not be placed on the market.
- Respect national language requirements for the contents and dosage labelling, and remember that the regulation's labelling is without prejudice to the classification, labelling and packaging duties of the CLP Regulation and to the poison-centre notification of Article 45 CLP.

### Importer

- Treat import into the Union customs territory as placing on the market: as the importer you are deemed the manufacturer and carry every duty of Articles 3, 4, 4a, 9 and 11 for the detergents and surfactants you bring in, and you are the Community-established party the regulation requires.
- Obtain from the non-EU producer, and hold at the disposal of the competent authorities, the Annex III ultimate biodegradability results for every surfactant, the documentation on how the tests were performed and proof that you may rely on the test results.
- Compile the Annex VII C ingredient datasheet with full composition, CAS numbers and weight bands, and be able to hand it to medical personnel without delay and free of charge.
- Put your own name or trade mark, full address and telephone number on the consumer packaging as the party responsible for placing the product on the market, together with the datasheet contact details, the Annex VII A contents declaration, the fragrance allergens above 0,01 %, the website address of the ingredient list and, for consumer laundry and dishwasher detergents, the Annex VII B dosage information, in the language the Member State requires.
- Put your own name or trade mark, full address and telephone number on the consumer packaging as the party responsible for placing the product on the market, together with the address, email address and telephone number from which the datasheet can be obtained.
- Put the Annex VII A contents declaration on the consumer packaging, including the fragrance allergens above 0,01 % and the website address of the ingredient list, in the language the Member State requires.
- For consumer laundry and automatic dishwasher detergents, put the Annex VII B dosage information on the packaging, in the language the Member State requires.
- Check the phosphorus content before import: consumer laundry detergents at 0,5 g or more per dose and consumer automatic dishwasher detergents at 0,3 g or more per standard dosage may not be placed on the market.
- Expect the competent authorities to detain consignments of detergents that fail the regulation and to prevent their making available; Member States must provide such measures in their penalty rules.

### Distributor (wholesaler or retailer)

- If you sell a detergent without changing its characteristics, labelling or packaging, you are not the manufacturer; if you repackage, relabel, create your own-brand label, change the product or act as the importer, you become the manufacturer with all its duties.
- Where the Member State requires labelling in its national language, comply with that requirement for the contents declaration and the dosage information.
- Make available only detergents and surfactants that conform to the regulation: compliant products move freely, while the competent authorities may prevent the making available of non-compliant ones and detain consignments.
- Check that the consumer packaging you sell carries the responsible party's name, address and telephone number, the datasheet contact, the contents declaration with fragrance allergens, the website address and, for consumer laundry and dishwasher detergents, the dosage information, so that a product with missing labelling is not put on your shelves.
- Prepare for 23 September 2029, when Regulation (EU) 2026/405 replaces the regulation and gives distributors their own obligations in its Article 11, next to the rules on supply through refill and on cases in which manufacturer obligations apply to importers and distributors.

## Requirements

Each duty above as an identified requirement (23); ids are permanent and shared with the compliance engine.

### evidence

- `detr-mfr-use-biodegradable-surfactants` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product, before-market) — Use only surfactants that meet the Annex III criteria for ultimate aerobic biodegradation: at least 60 % mineralisation within 28 days in one of the six point A tests, or at least 70 % in the two point B DOC methods where justified. [Art. 4 and Annex III]
- `detr-mfr-keep-ingredient-datasheet` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product, before-market) — Keep an ingredient datasheet per Annex VII C, naming the detergent and the manufacturer and listing every ingredient in decreasing order of weight within the bands 10 % or more, 1 % to below 10 %, 0,1 % to below 1 % and below 0,1 %, with the common or IUPAC name, the INCI name where available, the CAS number and the European Pharmacopoeia name, and make it available without delay and free of charge to any medical personnel on request. [Art. 9(3) and Annex VII C]
- `detr-mfr-keep-total-phosphorus` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product, before-market) — Keep the total phosphorus content below 0,5 g per recommended dose for a standard load in hard water in consumer laundry detergents and below 0,3 g per standard dosage in consumer automatic dishwasher detergents; products at or above those limits may not be placed on the market. [Art. 4a and Annex VIa]
- `detr-imp-compile-annex-vii` (Importer, product, before-market) — Compile the Annex VII C ingredient datasheet with full composition, CAS numbers and weight bands, and be able to hand it to medical personnel without delay and free of charge. [Art. 9(3) and Annex VII C]

### data

- `detr-mfr-publish-ingredient-list` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product, before-market) — Publish the ingredient list on a website per Annex VII D, with INCI names or the European Pharmacopoeia, common or IUPAC name, the words parfum and colorant for perfumes and colourants, allergenic fragrances above 0,01 % listed by name, without percentage bands or CAS numbers, freely accessible, kept up to date and linked to a table of correspondence between INCI names, Pharmacopoeia names and CAS numbers; industrial and institutional detergents with a technical or safety data sheet are exempt. [Annex VII D]

### mark

- `detr-mfr-label-consumer-packaging` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product, before-market) — Label the consumer packaging legibly, visibly and indelibly with the product name and trade name, the name or trade mark, full address and telephone number of the party responsible for placing the product on the market, and the address, email address where available and telephone number from which the datasheet can be obtained; put the same information on the documents accompanying bulk shipments. [Art. 11(2)]
- `detr-mfr-declare-contents-annex` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product, before-market) — Declare the contents per Annex VII A: the eighteen listed constituent classes, from phosphates and the four surfactant classes to bleaching agents, EDTA, NTA, hydrocarbons, soap, zeolites and polycarboxylates, in the bands below 5 %, 5 % to below 15 %, 15 % to below 30 % and 30 % and more where added above 0,2 %; enzymes, disinfectants, optical brighteners and perfumes whenever added; preservatives by their common nomenclature; allergenic fragrances above 0,01 % by name; plus the website address of the ingredient list, instructions for use and special precautions. [Art. 11(3) and Annex VII A]
- `detr-mfr-give-recommended-quantities` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product, before-market) — For consumer laundry detergents, give the recommended quantities or dosage in millilitres or grams per standard load for soft, medium and hard water, the number of standard loads per package in medium-hard water, and the capacity and markings of any measuring cup; for consumer automatic dishwasher detergents, give the standard dosage for a fully loaded 12 place settings dishwasher, with water-hardness variants where relevant. [Art. 11(4) and Annex VII B]
- `detr-mfr-respect-national-language` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product-market, before-market) — Respect national language requirements for the contents and dosage labelling, and remember that the regulation's labelling is without prejudice to the classification, labelling and packaging duties of the CLP Regulation and to the poison-centre notification of Article 45 CLP. [Art. 9(1), Art. 11(1) and Art. 11(5)]
- `detr-imp-mark-name-address` (Importer, product, before-market) — Put your own name or trade mark, full address and telephone number on the consumer packaging as the party responsible for placing the product on the market, together with the address, email address and telephone number from which the datasheet can be obtained. [Art. 11(2)]
- `detr-imp-declare-contents` (Importer, product-market, before-market) — Put the Annex VII A contents declaration on the consumer packaging, including the fragrance allergens above 0,01 % and the website address of the ingredient list, in the language the Member State requires. [Art. 11(3), Art. 11(5) and Annex VII A]
- `detr-imp-give-dosage-information` (Importer, product-market, before-market) — For consumer laundry and automatic dishwasher detergents, put the Annex VII B dosage information on the packaging, in the language the Member State requires. [Art. 11(4), Art. 11(5) and Annex VII B]

### procedure

- `detr-mfr-test-under-standards` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product, before-market) — Have the tests carried out under the Annex I standards, EN ISO/IEC 17025 or the principles of good laboratory practice. [Art. 7 and Annex I]

### submission

- `detr-mfr-apply-industrial-derogation` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product, before-market) — For an industrial or institutional detergent with a surfactant that fails Annex III but passes the 80 % Annex II primary biodegradability test, apply to the competent authority and the Commission for a derogation before using it. [Art. 5, Art. 6 and Annex II]

### verification

- `detr-imp-obtain-non-eu-producer` (Importer, product, before-market) — Obtain from the non-EU producer, and hold at the disposal of the competent authorities, the Annex III ultimate biodegradability results for every surfactant, the documentation on how the tests were performed and proof that you may rely on the test results. [Art. 7, Art. 9(1) and Art. 9(2)]
- `detr-imp-check-phosphorus-content` (Importer, product, before-market) — Check the phosphorus content before import: consumer laundry detergents at 0,5 g or more per dose and consumer automatic dishwasher detergents at 0,3 g or more per standard dosage may not be placed on the market. [Art. 4a and Annex VIa]
- `detr-dist-comply-requirement-contents` (Distributor (wholesaler or retailer), product-market, before-market) — Where the Member State requires labelling in its national language, comply with that requirement for the contents declaration and the dosage information. [Art. 11(5)]
- `detr-dist-make-available-detergents` (Distributor (wholesaler or retailer), product, before-market) — Make available only detergents and surfactants that conform to the regulation: compliant products move freely, while the competent authorities may prevent the making available of non-compliant ones and detain consignments. [Art. 3(1), Art. 14(1) and Art. 18]
- `detr-dist-check-consumer-packaging` (Distributor (wholesaler or retailer), product, before-market) — Check that the consumer packaging you sell carries the responsible party's name, address and telephone number, the datasheet contact, the contents declaration with fragrance allergens, the website address and, for consumer laundry and dishwasher detergents, the dosage information, so that a product with missing labelling is not put on your shelves. [Art. 11(2), Art. 11(3) and Art. 11(4)]

### standing

- `detr-mfr-hold-test-results` (Manufacturer (the party responsible for placing on the market, including brand owners and packagers), product, ongoing) — Hold at the disposal of the competent authorities the results of the Annex III tests, the Annex II and IV technical files for any derogation request, and documentation showing that the tests were performed correctly and that you may use the test results. [Art. 9(1) and Art. 9(2)]

## Penalties

Member States lay down the rules on penalties applicable to infringements of the regulation and take all measures necessary to ensure that they are implemented; this may include measures allowing the competent authorities to prevent the making available on the market of detergents or surfactants that fail to comply, the penalties must be effective, proportionate and dissuasive, and the rules must include measures allowing the authorities to detain non-compliant consignments. The competent authorities may apply all necessary control measures to detergents on the market, using the Annex VIII reference methods, without obliging manufacturers to repeat or pay for tests already passed at an approved laboratory, and a Member State may provisionally withdraw, recall or restrict a compliant detergent that presents a risk to human or animal health or the environment. Market surveillance follows Regulation (EU) 2019/1020, which lists the regulation in its Annex I. In Denmark the regulation is directly applicable and supervised by Miljøstyrelsen's chemicals inspection (Kemikalieinspektionen) under the chemicals act, lovbekendtgørelse nr. 1200 of 25 September 2025: the authority must have an unlawful situation ended and may order the responsible party to stop sales, warn users, remedy the cause, recall or destroy the product (§ 48); unless a higher penalty is due under other legislation, infringing an EU regulation on substances, mixtures or articles covered by the act is punished with a fine (§ 59(1)(1)), and the penalty rises to imprisonment of up to two years where the infringement is intentional or grossly negligent and has harmed or endangered the life or health of people or domestic animals, has harmed or endangered the environment, or has obtained or was intended to obtain an economic advantage, including through savings, for the person concerned or for others (§ 59(2)); any economic advantage obtained is confiscated even where no harm or danger was caused (§ 59(7)), the supervisory authority, or the police on its behalf, may seize unlawful substances, mixtures and articles (§ 48 b), companies can be held criminally liable (§ 60) and the limitation period for that liability is five years (§ 61).

## Checklist

1. Confirm the product is a detergent or a surfactant for detergents under Article 2(1): it contains soap or surfactants for washing or cleaning, or is an auxiliary washing mixture, fabric softener or cleaning mixture; body-cleaning products are cosmetics instead.
2. Decide who the manufacturer is: the producer, the importer, an own-account packager or anyone changing the product or its label is responsible for conformity and must be established in the Community (Article 2(10) and Article 3(2)).
3. Collect Annex III ultimate biodegradability results for every surfactant, at least 60 % in 28 days, run under EN ISO/IEC 17025 or GLP, and keep the test documentation and property-rights evidence ready for the authorities (Articles 7 and 9).
4. For industrial or institutional detergents with a surfactant that fails Annex III, check Annex II primary biodegradability and prepare the Annex IV file for a derogation request, or reformulate (Articles 4 to 6).
5. Measure the total phosphorus content: below 0,5 g per dose for consumer laundry detergents and below 0,3 g per standard dosage for consumer automatic dishwasher detergents (Article 4a and Annex VIa).
6. Draw up the Annex VII C ingredient datasheet with CAS numbers and weight bands and set up the address, email and telephone number through which medical personnel obtain it without delay (Article 9(3) and Article 11(2)(c)).
7. Write the label: product name, responsible party with address and telephone, Annex VII A contents bands, enzymes, disinfectants, optical brighteners, perfumes and preservatives, fragrance allergens above 0,01 %, the ingredient-list website address, instructions and precautions, in the national language where required (Article 11).
8. Add the Annex VII B dosage information for consumer laundry detergents (soft, medium and hard water, loads per package, measuring cup) and for consumer automatic dishwasher detergents (standard dosage for 12 place settings).
9. Publish the Annex VII D ingredient list online with INCI names, keep it current and link to the INCI, Pharmacopoeia and CAS correspondence table; keep CLP classification, labelling and the Article 45 poison-centre notification in place alongside.
10. Plan the transition to Regulation (EU) 2026/405: it applies from 23 September 2029 with a digital product passport, digital labelling, refill rules and micro-organism requirements; detergents and surfactants placed on the market before 23 September 2029 in compliance with the old rules may be made available indefinitely, while those placed on the market from 23 September 2029 up to and including 22 September 2030 under the old rules may only be made available until 23 September 2030.

## Questions

### Which products count as detergents under Regulation (EC) No 648/2004?

Any substance or mixture containing soaps or other surfactants intended for washing and cleaning processes, in any form, whether marketed for household, institutional or industrial use. The regulation also counts as detergents the auxiliary washing mixtures for soaking, rinsing or bleaching, laundry fabric softeners, cleaning mixtures for all-purpose and surface cleaning and other cleaning and washing mixtures. Washing means the cleaning of laundry, fabrics, dishes and other hard surfaces, so products for cleaning the human body are cosmetics, not detergents.

### Who is the manufacturer when I import or private-label a detergent?

The regulation's manufacturer is the person responsible for placing the detergent or surfactant on the market. A producer, an importer, a packager working for its own account and anyone who changes the characteristics of the product or creates or changes its label is deemed to be the manufacturer, and import into the Union customs territory is itself placing on the market. A distributor that sells the product unchanged is not a manufacturer unless it acts as the importer. Manufacturers must be established within the Community.

### What are the phosphate limits and since when do they apply?

Consumer laundry detergents may not be placed on the market since 30 June 2013 if the total phosphorus content is 0,5 g or more in the recommended quantity for the main cycle of a standard washing machine load in hard water, for normally soiled fabrics with heavy-duty detergents and lightly soiled fabrics with delicate detergents. Consumer automatic dishwasher detergents may not be placed on the market since 1 January 2017 if the total phosphorus content is 0,3 g or more in the standard dosage. Both limits were added by Regulation (EU) No 259/2012, and Member States may keep or adopt national phosphate rules for detergents the annex does not cover.

### Which fragrance allergens must be named on a detergent label?

Allergenic fragrances added at concentrations above 0,01 % by weight must be listed by name on the packaging of detergents sold to the general public, using the nomenclature of the cosmetics rules; the list is the one in Annex III, Part 1 to Directive 76/768/EEC as amended by Directive 2003/15/EC, plus any allergenic fragrances added later, and Directive 76/768/EEC was repealed by Regulation (EC) No 1223/2009 with effect from 11 July 2013, so references are read as references to that regulation. Since 12 January 2007 the duty applies however the allergen is added, whether as a pure substance or within a perfume or essential oil, and the same allergens appear in the online ingredient list. The Commission may lower the 0,01 % threshold by delegated act when the Scientific Committee on Consumer Safety sets individual risk-based limits.

### What is the ingredient datasheet and who may ask for it?

The Annex VII C datasheet names the detergent and the manufacturer and lists all ingredients in decreasing order of weight within four bands, 10 % or more, 1 % to below 10 %, 0,1 % to below 1 % and below 0,1 %, with the common or IUPAC name, the INCI name where available, the CAS number and the European Pharmacopoeia name; impurities are not ingredients, and a perfume, essential oil or colouring agent counts as one ingredient except for its allergenic fragrances above 0,01 %. The manufacturer must make it available without delay and free of charge to any medical personnel on request, or to a public body the Member State has designated for that purpose, and the recipients must keep it confidential and use it only for medical purposes.

### Do I have to publish the ingredients of my detergent online?

Yes for detergents sold to the general public. The manufacturer must make the ingredient datasheet available on a website, without the weight bands and CAS numbers, using INCI names or, failing those, the European Pharmacopoeia, common or IUPAC name, with parfum and colorant for perfumes and colouring agents and the allergenic fragrances above 0,01 % listed by name. Access may not be restricted, the content must be kept up to date, the site must link to a correspondence table between INCI names, Pharmacopoeia names and CAS numbers, and the website address must be printed on the packaging. Industrial or institutional detergents and their surfactants are exempt where a technical data sheet or safety data sheet is available.

### Is the Detergents Regulation being replaced?

Yes. Regulation (EU) 2026/405 on detergents and surfactants was signed on 11 February 2026, published on 2 March 2026 and entered into force on 22 March 2026. It applies from 23 September 2029, when Regulation (EC) No 648/2004 is repealed, except its Article 4(3) and (4), which already apply and set biodegradability deadlines for films in 2032 and for other organic substances added at 10 % or more in 2034. The new regulation covers detergents containing micro-organisms, digital labelling and a digital product passport, supply through refill, animal-testing limits and separate obligations for manufacturers, authorised representatives, importers and distributors. Products placed on the market before 23 September 2029 under the old rules may be made available indefinitely, and products placed on the market between 23 September 2029 and 22 September 2030 under the old rules may be made available until 23 September 2030.

### Do REACH and CLP still apply to a detergent that complies with DetR?

Yes. The information duties of Article 9 are without prejudice to Article 45 of the CLP Regulation on poison-centre notification, and the labelling rules of Article 11 are without prejudice to the classification, labelling and packaging provisions of Regulation (EC) No 1272/2008, so a hazardous detergent carries the CLP hazard label on top of the detergent contents declaration. The successor regulation states expressly that it does not affect REACH, CLP or the Biocidal Products Regulation.

## What changed

- 2030-09-23 (applies): **Transitional window under Regulation (EU) 2026/405 closes** — Detergents and surfactants placed on the market between 23 September 2029 and 22 September 2030 in compliance with Regulation (EC) No 648/2004 as it stood on 22 September 2029 may be made available on the market only until this date.
- 2029-09-23 (amendment): **Regulation (EC) No 648/2004 repealed; Regulation (EU) 2026/405 applies** — The new regulation on detergents and surfactants applies in full and repeals Regulation (EC) No 648/2004, with references to the old act read through the correlation table in its Annex VIII; products placed on the market before this date under the old rules may continue to be made available indefinitely.
- 2026-09-11 (guidance): **Guide rewritten from the consolidated text and Regulation (EU) 2026/405** — The body now follows the consolidated text of 1 June 2015 with exact dates, limits and article references, the Article 2(10) manufacturer definition covering importers and own-brand packagers, the Danish enforcement basis in the chemicals act, and the repeal by Regulation (EU) 2026/405 with its application date of 23 September 2029 and the transitional window to 23 September 2030; the earlier text spoke of an adopted recast without dates.
- 2026-03-22 (amendment): **Regulation (EU) 2026/405 on detergents and surfactants in force** — Signed on 11 February 2026 and published in OJ L 2026/405 on 2 March 2026, the successor regulation entered into force on the twentieth day after publication. It applies from 23 September 2029, except Article 4(3) and (4), which apply immediately and require films to meet biodegradability criteria by 23 March 2032 and other organic substances added at 10 % or more by 23 March 2034; it adds detergents containing micro-organisms, digital labelling, a digital product passport, supply through refill, animal-testing limits and obligations for manufacturers, authorised representatives, importers and distributors, and keeps the phosphorus limits of 0,5 g and 0,3 g in its Annex III.
- 2017-01-01 (applies): **Phosphorus limit for consumer automatic dishwasher detergents applies** — Consumer automatic dishwasher detergents with a total phosphorus content of 0,3 g or more in the standard dosage may no longer be placed on the market; the Commission's Article 16 review did not lead the Parliament and Council to change the limit before 31 December 2016.
- 2015-06-01 (applies): **CLP references in Articles 9(1) and 11(1) apply** — Points 2 and 3 of Article 1 of Regulation (EC) No 1336/2008 apply: the manufacturer's information duties are without prejudice to Article 45 of Regulation (EC) No 1272/2008 and the labelling rules are without prejudice to the CLP classification, labelling and packaging provisions.
- 2013-06-30 (applies): **Phosphorus limit for consumer laundry detergents applies** — Consumer laundry detergents with a total phosphorus content of 0,5 g or more in the recommended dose for a standard washing machine load in hard water may no longer be placed on the market.
- 2012-04-19 (amendment): **Regulation (EU) No 259/2012 in force: phosphates, dosage labelling and delegated acts** — The amending regulation of 14 March 2012, published in OJ L 94 on 30 March 2012, added Article 4a and Annex VIa with the phosphorus limits, the definitions of consumer laundry and consumer automatic dishwasher detergent and of placing and making available on the market, dosage labelling in Article 11(4) and Annex VII B, delegated-act powers in Articles 13 and 13a, a free-movement clause allowing national phosphate rules for other detergents, and new Articles 15(1), 16 and 18 on safeguard measures, the Commission review and penalties including detention of consignments.
- 2009-06-27 (amendment): **Commission Regulation (EC) No 551/2009 in force: first surfactant derogation in Annex V** — Annexes V and VI were replaced: the Guerbet alcohol ethoxylate surfactant with CAS number 147993-59-7 was granted a derogation for bottle washing, cleaning-in-place and metal cleaning until 27 June 2019, and the list of banned or restricted surfactants in Annex VI stayed empty.
- 2009-04-20 (amendment): **Regulation (EC) No 219/2009 in force: committee procedure updated** — The comitology omnibus regulation replaced Article 12 on the committee assisting the Commission; Regulation (EU) No 259/2012 later deleted its paragraph 3 when the adaptation of the annexes moved to delegated acts.
- 2009-01-20 (amendment): **Regulation (EC) No 1336/2008 in force: alignment with the CLP Regulation** — The word preparation was replaced by mixture throughout the regulation, and the CLP references in Articles 9(1) and 11(1) were adopted with application from 1 June 2015.
- 2007-01-12 (applies): **New Annex VII labelling and ingredient rules apply** — Article 1(2) of Regulation (EC) No 907/2006 applies: allergenic fragrances above 0,01 % must be declared however they are added, the packaging must carry the website address of the ingredient list, the public list uses INCI nomenclature, and industrial and institutional detergents may replace the labelling and website duties by technical or safety data sheets.
- 2006-07-11 (amendment): **Commission Regulation (EC) No 907/2006 in force: Annex III test methods** — The Commission regulation of 20 June 2006, published in OJ L 168 on 21 June 2006, replaced Annex III and added ISO 10708:1997 as a sixth ultimate biodegradability test method for poorly soluble surfactants; its new Annex VII applied from 12 January 2007.
- 2005-10-08 (in-force): **Regulation (EC) No 648/2004 enters into force** — Adopted on 31 March 2004 and published in OJ L 104 on 8 April 2004, the regulation entered into force on 8 October 2005 and applied directly in all Member States, repealing Directives 73/404/EEC, 73/405/EEC, 82/242/EEC, 82/243/EEC and 86/94/EEC and Recommendation 89/542/EEC on the same day.

## DetR in plain terms

The Detergents Regulation (DetR), formally Regulation (EC) No 648/2004, is the EU's dedicated law for placing detergents and surfactants for detergents on the market. It harmonises five things: the biodegradability of surfactants, restrictions or bans on surfactants on biodegradability grounds, the additional labelling of detergents including fragrance allergens, the information manufacturers must hold for the competent authorities and medical personnel, and the limits on phosphates and other phosphorus compounds in consumer laundry and automatic dishwasher detergents (Art. 1). Because it is a regulation it entered into force and applied directly in every Member State on 8 October 2005, the day it repealed the five detergent directives of 1973 to 1986 and Recommendation 89/542/EEC (Art. 17 and Art. 19).

The regulation sits on top of the general chemicals rules rather than replacing them: its information and labelling duties are without prejudice to REACH, to the classification, labelling and packaging rules of the CLP Regulation and to the poison-centre notification of Article 45 CLP (Art. 9(1) and Art. 11(1)). Its days are now counted: Regulation (EU) 2026/405 on detergents and surfactants entered into force on 22 March 2026 and repeals it with effect from 23 September 2029 (Regulation (EU) 2026/405, Art. 35 and Art. 37).

> **Official text**
> Read the regulation on EUR-Lex: [Regulation (EC) No 648/2004 (CELEX 32004R0648)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32004R0648), or the [consolidated text of 1 June 2015](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004R0648-20150601) that includes the fragrance-allergen labelling, the CLP alignment and the phosphorus limits. The successor is [Regulation (EU) 2026/405 (CELEX 32026R0405)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R0405).

## Scope

A detergent is any substance or mixture containing soaps or other surfactants intended for washing and cleaning processes, in any form, liquid, powder, paste, bar, cake or moulded piece, and marketed for household, institutional or industrial use. The regulation adds four groups that count as detergents in their own right: auxiliary washing mixtures for soaking, rinsing or bleaching, laundry fabric softeners, cleaning mixtures for all-purpose and surface cleaning, and other cleaning and washing mixtures (Art. 2(1)). Washing means the cleaning of laundry, fabrics, dishes and other hard surfaces (Art. 2(2)), so soap and shower gel for the body are cosmetic products under Regulation (EC) No 1223/2009 instead. A surfactant is an organic substance or mixture with surface-active properties, hydrophilic and hydrophobic groups, and the ability to reduce the surface tension of water, form monolayers, emulsions or micelles and adsorb at water-solid interfaces (Art. 2(6)).

Regulation (EU) No 259/2012 added the two consumer categories that carry extra duties: a consumer laundry detergent is a laundry detergent placed on the market for use by non-professionals, including in public laundrettes, and a consumer automatic dishwasher detergent is one placed on the market for use in automatic dishwashers by non-professionals (Art. 2(1a) and (1b)). An industrial and institutional detergent is one for washing and cleaning outside the domestic sphere, carried out by specialised personnel using specific products (Art. 2(12)).

The duties fall on the manufacturer, defined as the natural or legal person responsible for placing a detergent or surfactant on the market: a producer, an importer, a packager working for his own account, or anyone changing the characteristics of the product or creating or changing its labelling. A distributor who changes nothing is not a manufacturer, except where he acts as an importer (Art. 2(10)). Placing on the market is the first making available on the Union market, and import into the Union customs territory is deemed placing on the market (Art. 2(9)). Manufacturers must be established within the Community and are responsible for conformity (Art. 3(2) and (3)).

Surfactants that are biocidal active substances used as disinfectants are exempt from the biodegradability annexes II, III, IV and VIII when they are listed or authorised under the biocides rules, and the detergent that contains them is labelled as containing a disinfectant (Art. 3(1)). The article still cites Directive 98/8/EC, but that directive was repealed with effect from 1 September 2013, and references to it are construed as references to the Biocidal Products Regulation and read in accordance with the correlation table in its Annex VII (Regulation (EU) No 528/2012, Art. 96). In practice you therefore check the exemption against Regulation (EU) No 528/2012 today, and Regulation (EU) 2026/405 writes the same exemption out in its terms, covering the Union list of approved active substances and Annex I to that regulation, the review programme under Commission Delegated Regulation (EU) No 1062/2014 and constituents of disinfectants allowed under its Article 55 (Regulation (EU) 2026/405, Art. 4(2)).

## What you must do

### Biodegradability of surfactants

Surfactants, and detergents containing them, may be placed on the market without further biodegradability limits when they meet the Annex III criteria for ultimate aerobic biodegradation (Art. 4(1)). Annex III sets a pass level of at least 60 % mineralisation within 28 days in one of six tests, with EN ISO 14593:1999, the CO2 headspace test, as the reference method, and allows two DOC die-away methods with a 70 % pass level where the surfactant's physical characteristics justify it (Annex III, points A and B). Tests must be run under the Annex I standards, EN ISO/IEC 17025 or the principles of good laboratory practice (Art. 7).

Where a surfactant fails Annex III, manufacturers of industrial or institutional detergents, or of surfactants for them, may apply for a derogation to the competent authority of the Member State and the Commission, with a technical file containing the Annex II primary biodegradability results, which must reach at least 80 %, and the Annex IV complementary risk assessment (Art. 4(2), Art. 4(3) and Art. 5). The Commission grants derogations for low-dispersive, specific industrial or institutional uses where the environmental risk is small compared with the socio-economic benefit, and lists them in Annex V; surfactants refused a derogation go into Annex VI (Art. 6). Annex V held one entry, a Guerbet alcohol ethoxylate for bottle washing, cleaning-in-place and metal cleaning, until 27 June 2019; Annex VI is empty (Annex V and Annex VI, as replaced by Regulation (EC) No 551/2009).

### Phosphorus limits

Since 30 June 2013 a consumer laundry detergent may not be placed on the market if its total phosphorus content is 0,5 g or more in the recommended quantity for the main cycle of a standard washing machine load in hard water, and since 1 January 2017 a consumer automatic dishwasher detergent may not be placed on the market if its total phosphorus content is 0,3 g or more in the standard dosage (Art. 4a and Annex VIa). The dishwasher limit stood because the Parliament and Council did not decide otherwise on the basis of the Commission's review by 31 December 2016 (Art. 16). Member States may keep or lay down national phosphate rules for detergents the annex does not cover, such as hand dishwashing liquids or industrial products (Art. 14(2)). Regulation (EU) 2026/405 carries both limits forward in its Annex III and asks the Commission to assess further reductions and new product categories by 23 March 2028 (Regulation (EU) 2026/405, Art. 6, Art. 34(2) and Annex III).

### Information for the authorities and for medical personnel

Manufacturers must hold at the disposal of the competent authorities the results of the Annex III tests and, for surfactants in a derogation request, the Annex II and Annex IV technical files, and must have documentation showing that the tests were performed correctly and that they may use the results (Art. 9(1) and (2)). For every mixture covered by the regulation they must keep an ingredient datasheet per Annex VII C, listing all ingredients in decreasing order of weight within the bands 10 % or more, 1 % to below 10 %, 0,1 % to below 1 % and below 0,1 %, with the common or IUPAC name, the INCI name where available, the CAS number and the European Pharmacopoeia name, and hand it without delay and free of charge to any medical personnel who ask, or to a public body the Member State has designated; the recipients keep it confidential and use it only for medical purposes (Art. 9(3) and Annex VII C).

### Labelling

The consumer packaging must show, legibly, visibly and indelibly, the name and trade name of the product, the name or trade mark, full address and telephone number of the party responsible for placing it on the market, and the address, email address where available and telephone number from which the datasheet can be obtained; the same information goes on the documents accompanying bulk transport (Art. 11(2)). The contents are declared per Annex VII A: eighteen constituent classes, from phosphates, phosphonates and the anionic, cationic, amphoteric and non-ionic surfactants to bleaching agents, EDTA, NTA, phenols, hydrocarbons, soap, zeolites and polycarboxylates, shown in the bands below 5 %, 5 % to below 15 %, 15 % to below 30 % and 30 % and more where added above 0,2 %; enzymes, disinfectants, optical brighteners and perfumes whenever added; preservatives by their common nomenclature; and allergenic fragrances above 0,01 % by name, using the cosmetics nomenclature (Art. 11(3) and Annex VII A). The packaging also carries instructions for use and special precautions, and the website address where the ingredient list can be obtained.

Consumer laundry detergents add the Annex VII B dosage information: recommended quantities in millilitres or grams for a standard load in soft, medium and hard water, the number of standard loads per package in medium-hard water, 4,5 kg of dry fabric for heavy-duty and 2,5 kg for light-duty detergents, and the capacity and markings of any measuring cup; consumer automatic dishwasher detergents state the standard dosage for the main cycle in a fully loaded 12 place settings dishwasher (Art. 11(4) and Annex VII B). Where a Member State requires labelling in its national language, manufacturers and distributors must comply for the contents and dosage information (Art. 11(5)). Detergents intended for use in the industrial and institutional sector and not made available to members of the general public may replace the Annex VII A labelling by technical data sheets, safety data sheets or a similar appropriate means, provided the equivalent information is given (Annex VII A).

### The public ingredient list

Manufacturers must publish the ingredient datasheet on a website, without the weight bands and CAS numbers, using INCI names or, failing those, the European Pharmacopoeia, common or IUPAC name, the words parfum and colorant for perfumes and colouring agents, and the allergenic fragrances above 0,01 % by name. Access may not be restricted, the content must be kept up to date, and the site must link to a table of correspondence between INCI names, Pharmacopoeia names and CAS numbers. Industrial or institutional detergents and their surfactants are exempt where a technical or safety data sheet is available (Annex VII D).

### Obligations by role

The manufacturer, whoever places the product on the market, carries the biodegradability, testing, documentation, datasheet, labelling, dosage, website and phosphorus duties (Art. 3, Art. 4, Art. 4a, Art. 9 and Art. 11). An importer is deemed a manufacturer and is the Community-established responsible party the regulation demands (Art. 2(9), Art. 2(10) and Art. 3(2)). A distributor that sells the product unchanged is not a manufacturer, but one that repackages, relabels, private-labels or imports takes on the whole manufacturer role, and every distributor must respect national language requirements (Art. 2(10) and Art. 11(5)).

### The successor regulation from 23 September 2029

Regulation (EU) 2026/405 was signed on 11 February 2026, published on 2 March 2026 and entered into force on 22 March 2026. It applies from 23 September 2029, when it repeals Regulation (EC) No 648/2004, except its Article 4(3) and (4), which apply immediately and require films and polymers within films to meet biodegradability criteria by 23 March 2032 and other organic substances added at 10 % or more by 23 March 2034 (Regulation (EU) 2026/405, Art. 4, Art. 35 and Art. 37). The new act widens the definition of detergent to substances, mixtures or micro-organisms intended to clean, soak, rinse, bleach, soften or scent fabrics, dishes or surfaces, sets requirements for detergents containing micro-organisms, limits animal testing, keeps the phosphorus limits, and adds obligations of manufacturers, authorised representatives, importers and distributors, supply through refill, general and digital labelling, distance-sales rules, a digital product passport with customs controls, and the market surveillance procedures of the new legislative framework (Regulation (EU) 2026/405, Art. 2(1), Art. 5, Art. 7, Art. 8 to Art. 29). Products placed on the market before 23 September 2029 under the old rules may be made available indefinitely; products placed on the market between 23 September 2029 and 22 September 2030 under the old rules may be made available until 23 September 2030 (Regulation (EU) 2026/405, Art. 36).

## Enforcement and penalties

Each Member State appoints the competent authorities and notifies the Commission of its approved laboratories (Art. 8). The authorities may apply all necessary control measures to detergents on the market, using the Annex VIII reference methods, without obliging manufacturers to repeat or pay for tests already passed at an approved laboratory (Art. 10). A Member State that believes a compliant detergent still presents a risk to human or animal health or the environment may provisionally withdraw, recall or restrict it and must inform the other Member States and the Commission, which decides within ninety days (Art. 15). Member States lay down effective, proportionate and dissuasive penalties, may empower the authorities to prevent the making available of non-compliant detergents and surfactants, and must allow the detention of non-compliant consignments (Art. 18). Market surveillance follows Regulation (EU) 2019/1020, which lists the regulation in its Annex I.

In Denmark the regulation applies directly and is supervised by Miljøstyrelsen's chemicals inspection, Kemikalieinspektionen, under the chemicals act (lov om kemikalier, lovbekendtgørelse nr. 1200 of 25 September 2025). The supervisory authority must have an unlawful situation ended and may order the responsible party to stop sales, warn users, remedy the cause, recall or destroy the product (§ 48). Infringing an EU regulation on substances, mixtures or articles covered by the act is punished with a fine unless a higher penalty is due under other legislation (§ 59(1)(1)), and the penalty rises to imprisonment of up to two years where the infringement is intentional or grossly negligent and has harmed or endangered the life or health of people or domestic animals, has harmed or endangered the environment, or has obtained or was intended to obtain an economic advantage, including through savings (§ 59(2)). The supervisory authority, or the police on its behalf, may seize unlawful substances, mixtures and articles under the rules of Chapter 74 of the Administration of Justice Act (§ 48 b), companies can be held criminally liable (§ 60), and the limitation period for that liability is five years (§ 61).

## How Conphora helps

Conphora monitors DetR and its successor and maps your detergents against the requirements, flagging gaps in the biodegradability evidence, the Annex VII A contents declaration and fragrance allergens, the ingredient datasheet and website list and the phosphorus limits before they become enforcement problems. The platform helps you build and keep the documentation the competent authorities may ask for and alerts you when a requirement starts or stops, such as the switch to Regulation (EU) 2026/405 on 23 September 2029 and the digital product passport that comes with it.

[See how Conphora works](/how-it-works) · [See plans and pricing](/pricing)

## Sources

- [Regulation (EC) No 648/2004 on detergents, consolidated text of 1 June 2015 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004R0648-20150601)
- [Regulation (EC) No 648/2004 as published in OJ L 104, 8 April 2004 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32004R0648)
- [Document information, dates and relationships for CELEX 32004R0648 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32004R0648)
- [Commission Regulation (EC) No 907/2006 adapting Annexes III and VII (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006R0907)
- [Regulation (EC) No 1336/2008 adapting Regulation (EC) No 648/2004 to the CLP Regulation (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008R1336)
- [Regulation (EC) No 219/2009 adapting acts to the regulatory procedure with scrutiny (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009R0219)
- [Commission Regulation (EC) No 551/2009 adapting Annexes V and VI (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R0551)
- [Regulation (EU) No 259/2012 on phosphates and other phosphorus compounds in consumer detergents (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012R0259)
- [Regulation (EU) 2026/405 on detergents and surfactants, repealing Regulation (EC) No 648/2004 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R0405)
- [Procedure 2023/0124(COD), detergents and surfactants (EUR-Lex)](https://eur-lex.europa.eu/procedure/EN/2023_124)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)
- [Regulation (EC) No 1223/2009 on cosmetic products (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1223)
- [Chemicals legislation, detergents section (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/sectors/chemicals/chemicals-legislation_en)
- [Commission welcomes political agreement on product safety for detergents, 11 June 2025 (European Commission)](https://single-market-economy.ec.europa.eu/news/commission-welcomes-political-agreement-product-safety-detergents-single-market-2025-06-11_en)
- [Vaske- og rengøringsmidler (Miljøstyrelsen)](https://mst.dk/erhverv/sikker-kemi/kemikalier/fokus-paa-saerlige-produkter/vaske-og-rengoeringsmidler)
- [Faktaark: Vaske- og rengøringsmidler (Miljøstyrelsen)](https://mst.dk/erhverv/sikker-kemi/kemikalier/regler-og-handlingsplaner/faktaark-om-kemikaliereglerne/faktaark-vaske-og-rengoeringsmidler)
- [Faktaark: Vaske- og rengøringsmidler, kommende regler (Miljøstyrelsen)](https://mst.dk/erhverv/sikker-kemi/kemikalier/regler-og-handlingsplaner/faktaark-om-kemikaliereglerne/faktaark-vaske-og-rengoeringsmidler-kommende-regler)
- [Bekendtgørelse af lov om kemikalier, lovbekendtgørelse nr. 1200 af 25. september 2025 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2025/1200)

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

## Sources

- [Regulation (EC) No 648/2004 on detergents, consolidated text of 1 June 2015 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004R0648-20150601)
- [Regulation (EC) No 648/2004 as published in OJ L 104, 8 April 2004 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32004R0648)
- [Document information, dates and relationships for CELEX 32004R0648 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32004R0648)
- [Commission Regulation (EC) No 907/2006 adapting Annexes III and VII, fragrance allergens and the ingredient website (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32006R0907)
- [Regulation (EC) No 1336/2008 adapting Regulation (EC) No 648/2004 to the CLP Regulation (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008R1336)
- [Regulation (EC) No 219/2009 adapting acts to the regulatory procedure with scrutiny (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32009R0219)
- [Commission Regulation (EC) No 551/2009 adapting Annexes V and VI, surfactant derogation (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R0551)
- [Regulation (EU) No 259/2012 on phosphates and other phosphorus compounds in consumer laundry and automatic dishwasher detergents (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012R0259)
- [Regulation (EU) 2026/405 on detergents and surfactants, repealing Regulation (EC) No 648/2004 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R0405)
- [Procedure 2023/0124(COD), detergents and surfactants, from proposal to publication (EUR-Lex)](https://eur-lex.europa.eu/procedure/EN/2023_124)
- [Regulation (EU) 2019/1020 on market surveillance and compliance of products, Annex I (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32019R1020)
- [Regulation (EC) No 1223/2009 on cosmetic products, definition of cosmetic product (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32009R1223)
- [Chemicals legislation, detergents section with the Commission FAQ and guidelines (European Commission, DG GROW)](https://single-market-economy.ec.europa.eu/sectors/chemicals/chemicals-legislation_en)
- [Commission welcomes political agreement on product safety for detergents in the Single Market, 11 June 2025 (European Commission)](https://single-market-economy.ec.europa.eu/news/commission-welcomes-political-agreement-product-safety-detergents-single-market-2025-06-11_en)
- [Vaske- og rengøringsmidler (Miljøstyrelsen)](https://mst.dk/erhverv/sikker-kemi/kemikalier/fokus-paa-saerlige-produkter/vaske-og-rengoeringsmidler)
- [Faktaark: Vaske- og rengøringsmidler (Miljøstyrelsen)](https://mst.dk/erhverv/sikker-kemi/kemikalier/regler-og-handlingsplaner/faktaark-om-kemikaliereglerne/faktaark-vaske-og-rengoeringsmidler)
- [Faktaark: Vaske- og rengøringsmidler, kommende regler under forordning (EU) 2026/405 (Miljøstyrelsen)](https://mst.dk/erhverv/sikker-kemi/kemikalier/regler-og-handlingsplaner/faktaark-om-kemikaliereglerne/faktaark-vaske-og-rengoeringsmidler-kommende-regler)
- [Bekendtgørelse af lov om kemikalier, lovbekendtgørelse nr. 1200 af 25. september 2025 (Retsinformation)](https://www.retsinformation.dk/eli/lta/2025/1200)

_Reviewed 2026-09-24 by Conphora compliance team_