{
  "type": "problem",
  "slug": "detergent-product",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/detergent-product/",
  "markdown": "https://www.conphora.com/solutions/problem/detergent-product.md",
  "title": "We want to sell a detergent or cleaning product",
  "description": "Selling a detergent in the EU: who the manufacturer is, surfactant biodegradability, the Detergents Regulation label, CLP labels, the 2029 change.",
  "answer": "Detergents and cleaning products follow Regulation (EC) No 648/2004: surfactants must meet the biodegradability criteria, the label must list content ranges, enzymes, perfumes, preservatives and allergens, and medical staff can ask for an ingredient datasheet. The mixture must also be classified and labelled under the CLP Regulation. Settle who the manufacturer is, collect the surfactant evidence, then build both labels.",
  "theme": {
    "id": "chemicals-materials",
    "label": "Chemicals and materials"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    },
    {
      "id": "importer",
      "label": "Importer"
    }
  ],
  "regulations": [
    "DetR"
  ],
  "path": [
    "regulation-library",
    "knowledge-articles"
  ],
  "trigger": "You launch a cleaning product, washing liquid or dishwasher tablet under your own brand, or import one from outside the EU",
  "keep": null,
  "why": [
    {
      "text": "Regulation (EC) No 648/2004 covers detergents: any substance or mixture containing soaps or other surfactants intended for washing and cleaning, in any form, for household, institutional or industrial use, including pre-wash and bleaching mixtures, fabric softeners and cleaning mixtures (Article 2(1)). Detergents and surfactants must meet the conditions and limits of the Regulation and its annexes when placed on the market (Article 3(1)).",
      "sources": [
        1
      ]
    },
    {
      "text": "The Regulation puts the responsibility on one person. The manufacturer is the person responsible for placing the detergent on the market; a producer, an importer, a packager working for its own account and anyone changing the characteristics or creating or changing the labelling is deemed to be a manufacturer, while a distributor who changes nothing is not, unless it acts as an importer (Article 2(10)). The manufacturer must be established in the Community and is responsible for conformity (Article 3(2) and (3)). Surfactants that meet the criteria for ultimate aerobic biodegradation in Annex III may be placed on the market without further limitations (Article 4(1)), and the manufacturer holds the test results at the disposal of the authorities (Article 9(1) and (2)).",
      "sources": [
        1
      ]
    },
    {
      "text": "The detergent label has its own content. The pack gives the product name, the name, full address and telephone number of the party responsible, and where the ingredient datasheet can be obtained (Article 11(2)). Annex VII A sets the content statement: weight ranges for listed constituents added above 0.2 %, enzymes, disinfectants, optical brighteners and perfumes irrespective of concentration, preservatives, allergenic fragrances above 0.01 %, and the website address where the full ingredient list can be obtained. Consumer laundry and dishwasher detergents also carry dosage information (Article 11(4) and Annex VII B). Medical personnel receive an ingredient datasheet on request, without delay and free of charge (Article 9(3)).",
      "sources": [
        1
      ]
    },
    {
      "text": "Hazard labelling comes from the CLP Regulation (EC) No 1272/2008. Manufacturers, importers and downstream users classify mixtures before placing them on the market (Article 4(1)), and suppliers label and package hazardous mixtures before placing them on the market (Article 4(4)). The label includes the supplier details, the nominal quantity for packs made available to the general public, product identifiers and, where applicable, pictograms, signal words and hazard and precautionary statements (Article 17(1)), in the official languages of the Member States concerned (Article 17(2)). Packaging for the general public must not attract children or imitate food, feed, medicinal or cosmetic products (Article 35(2)). Member States appoint bodies to receive information for emergency health response under Annex VIII (Article 45(1)).",
      "sources": [
        2
      ]
    },
    {
      "text": "A new regulation is on its way. Regulation (EU) 2026/405 on detergents and surfactants repeals Regulation (EC) No 648/2004 with effect from 23 September 2029 and applies from that date, except Article 4(3) and (4) (Articles 35 and 37). It was published on 2 March 2026 and entered into force on the twentieth day after publication (Article 37). Article 4(3) and (4) set later deadlines of their own: films and polymers within films must meet new biodegradability requirements by 23 March 2032, and certain other organic substances by 23 March 2034. Detergents placed on the market before 23 September 2029 in compliance with the old Regulation may continue to be made available indefinitely; those placed after 22 September 2029 and before 23 September 2030 may be made available until 23 September 2030 (Article 36). The disinfectant rule in Article 3(1) of the old Regulation still cites Directive 98/8/EC, which Regulation (EU) No 528/2012 repealed from 1 September 2013; references to it are read as references to that Regulation (Article 96 of Regulation (EU) No 528/2012).",
      "sources": [
        3,
        4
      ]
    }
  ],
  "steps": [
    {
      "name": "Settle who the manufacturer is",
      "text": "Under the Detergents Regulation the manufacturer is the person responsible for placing the product on the market. An importer, a packager working for its own account and anyone who changes the product or creates its labelling counts as the manufacturer, and the manufacturer must be established in the EU.",
      "item": "regulation-library"
    },
    {
      "name": "Collect the surfactant evidence",
      "text": "Every surfactant must meet the criteria for ultimate aerobic biodegradation in Annex III. Get the test results from the surfactant supplier and keep them, with documentation that you may rely on them, at the disposal of the authorities."
    },
    {
      "name": "Classify the mixture under CLP",
      "text": "Classify the product as a mixture before placing it on the market. If it is hazardous, the label needs the supplier details, the nominal quantity for consumer packs, product identifiers, pictograms, signal word and hazard and precautionary statements, in the official languages of each country of sale.",
      "item": "knowledge-articles"
    },
    {
      "name": "Build the detergent label and the website list",
      "text": "For consumer packs, give the product name, your name, full address and telephone number, the content ranges of the listed constituents above 0.2 %, enzymes, disinfectants, optical brighteners, perfumes and preservatives whatever their concentration, allergenic fragrances above 0.01 %, and the website with the full ingredient list. Laundry and dishwasher detergents also need dosage information."
    },
    {
      "name": "Prepare the datasheet and the packaging checks",
      "text": "Have an ingredient datasheet ready to give medical personnel on request, free of charge. Check the CLP packaging rules: no design that attracts children or imitates food or cosmetics, and child-resistant fastenings or tactile warnings where the classification requires them."
    },
    {
      "name": "Plan for the new regulation from 2029",
      "text": "Regulation (EU) 2026/405 replaces the Detergents Regulation and applies from 23 September 2029. Products that comply with the old rules and are placed on the market before that date may continue to be made available. Those placed in the following year, before 23 September 2030, may be made available until 23 September 2030."
    }
  ],
  "documents": [
    {
      "name": "Biodegradability test results for every surfactant",
      "from": "The surfactant supplier or a laboratory",
      "ground": "Regulation (EC) No 648/2004 Article 4(1) and Article 9(1)–(2)"
    },
    {
      "name": "Ingredient datasheet for medical personnel",
      "from": "The manufacturer",
      "ground": "Regulation (EC) No 648/2004 Article 9(3) and Annex VII C"
    },
    {
      "name": "CLP classification of the mixture and the label artwork",
      "from": "The manufacturer",
      "ground": "Regulation (EC) No 1272/2008 Articles 4 and 17"
    }
  ],
  "risks": [
    {
      "title": "The manufacturer carries the responsibility",
      "text": "Manufacturers of detergents shall be established in the Community and are responsible for the conformity of the detergents with the Regulation and its annexes (Regulation (EC) No 648/2004 Article 3(2) and (3)).",
      "source": 1
    },
    {
      "title": "Authorities can control products on the market",
      "text": "Member States' competent authorities may apply all necessary control measures to detergents placed on the market to ensure compliance (Regulation (EC) No 648/2004 Article 10(1)).",
      "source": 1
    },
    {
      "title": "Hazardous mixtures need CLP labels before sale",
      "text": "Member States maintain official controls so that substances and mixtures are not placed on the market unless they have been classified, labelled, notified and packaged in accordance with the CLP Regulation (Regulation (EC) No 1272/2008 Article 46(1)).",
      "source": 2
    }
  ],
  "faq": [
    {
      "q": "We buy a finished detergent and put our brand on it. Are we the manufacturer?",
      "a": "Yes. Any person creating or changing the labelling of a detergent is deemed to be a manufacturer (Regulation (EC) No 648/2004 Article 2(10)). A distributor who changes nothing is not, unless it acts as an importer."
    },
    {
      "q": "Must the full ingredient list be on the pack?",
      "a": "No. The pack shows content ranges and the classes listed in Annex VII A, plus the website address where the full list of ingredients can be obtained (Regulation (EC) No 648/2004 Annex VII A). Allergenic fragrances above 0.01 % must be listed on the pack."
    },
    {
      "q": "Which language must the label be in?",
      "a": "The CLP label must be in the official language or languages of each Member State where the mixture is placed on the market, unless that State provides otherwise (Regulation (EC) No 1272/2008 Article 17(2)). For the detergent particulars, Member States may require their national language (Regulation (EC) No 648/2004 Article 11(5))."
    },
    {
      "q": "Our cleaner also disinfects. Is that a different set of rules?",
      "a": "Surfactants that are biocidal active substances used as disinfectants are exempt from the biodegradability annexes and the detergent follows the labelling for disinfectants in Annex VII A (Regulation (EC) No 648/2004 Article 3(1)). That Article cites Directive 98/8/EC, read as Regulation (EU) No 528/2012 (Article 96). A biocidal product needs an authorisation (Article 17(1)), which this page does not cover."
    },
    {
      "q": "Do liquid laundry capsules have special rules?",
      "a": "Yes. Where a liquid consumer laundry detergent is in a soluble packaging for single use, the additional requirements of section 3.3 of Annex II to the CLP Regulation apply (Regulation (EC) No 1272/2008 Article 35(2))."
    }
  ],
  "sources": [
    {
      "title": "Regulation (EC) No 648/2004 on detergents (consolidated text of 1 June 2015)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02004R0648-20150601",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures (consolidated text of 1 July 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02008R1272-20260701",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2026/405 on detergents and surfactants, and repealing Regulation (EC) No 648/2004",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32026R0405",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) No 528/2012 concerning the making available on the market and use of biocidal products",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32012R0528",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "language-requirements",
    "which-role-are-we",
    "cosmetic-product-launch",
    "small-product-label",
    "new-regulation"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-04",
  "notice": "General information, not legal advice."
}