News Brief
On March 2, 2026, the EU Detergents and Surfactants Regulation (EU) 2026/405 was officially published in the Official Journal of the European Union, marking the completion of the legislative work to replace the two-decade-old (EC) No 648/2004. This revision represents the most significant regulatory overhaul for the detergent industry in nearly 20 years. The new regulation enters into force on March 22, 2026, and will be fully applicable starting September 23, 2029, providing the industry with a three-and-a-half-year transition period.
Key Implementation Timeline
March 22, 2026: The regulation officially takes effect, starting the 42-month transition countdown.
September 23, 2029: Full mandatory enforcement begins; the old regulation is repealed, and all new products entering the market must comply with new requirements, particularly the Digital Product Passport (DPP).
Before September 23, 2029: Products already on the market under the old regulation may be sold indefinitely.
September 23, 2029 – September 22, 2030: Products placed on the market under the old regulation during this specific window may only be sold until September 22, 2030.
Comparison: Regulation (EC) No 648/2004 vs. Regulation (EU) 2026/405
Comparison Dimension | Old Regulation (EC) No 648/2004 | New Regulation (EU) 2026/405 |
Regulatory Scope | Limited to traditional chemical detergents and surfactants. | Explicitly includes microbial products (e.g., probiotics, enzymes) with 9 specific safety requirements; regulates "refill" sales with dedicated safety and labeling rules. |
Biodegradability | Only targets surfactants. | Adds water-soluble polymer films (mandatory by March 23, 2032) and high-concentration organics (≥10% by March 23, 2034). |
Animal Testing | Not explicitly prohibited. | Strictly prohibited for meeting new regulatory requirements; only historical data from before March 22, 2026, is permitted. |
Labeling Rules | All information must be printed on physical packaging. | Introduces digital labels, allowing some info to move online while keeping critical safety data (UFI, manufacturer info, allergens, dosage) on the physical label. |
Digitalization | Requires paper labels and ingredient lists only. | Mandatory Digital Product Passport (DPP) via QR code, containing full ingredients, DoC, and product codes, accessible for 10 years. |
Compliance Review | No unified document; focus on ingredient disclosure. | Mandatory "Internal Production Control (Module A)"; requires a full technical file and signed Declaration of Conformity (DoC) integrated into the DPP. |
Non-EU Manufacturer Obligations | No clear mandate for authorized representatives. | Must designate an EU Authorized Representative who carries enhanced verification and communication responsibilities. |
Major Regulatory Trends
The EU is shifting from a simple "ingredient access" model to a "digitally-driven, full-lifecycle traceability" system.
Digitalization of Supervision: The Mandatory DPP
The Digital Product Passport (DPP) is the core innovation of this regulation. A clear, durable data carrier (like a QR code) must be printed on packaging as the official gateway to compliance info. From September 2029, customs will automatically verify the DPP as a prerequisite for product entry. Labeling will follow a "Physical + Digital" layered mode, keeping critical safety warnings in the official language of the point of sale.
Procedural Compliance: Mandatory Internal Production Control (Module A)
Unlike the old "check upon request" model, the new rule mandates an "Internal Production Control (Module A)" procedure. Manufacturers must build detailed technical files (formulas, safety assessments, test reports) during R&D and sign a Declaration of Conformity (DoC). This DoC is a legal endorsement bound to the product via the DPP; creating the DPP implies full legal liability for the manufacturer.
Supply Chain Accountability
Manufacturers: Hold primary responsibility for compliance, technical files, DoC, and DPP creation.
Non-EU Manufacturers: Must appoint an EU Authorized Representative to manage technical files and verify DPP/label validity.
Importers/Distributors: Must verify the existence of the DPP and technical files before listing products. Any private labeling or modification shifts "Manufacturer" obligations onto them.
Refill Operators: Must ensure refill equipment meets the same safety and labeling standards as pre-packaged goods.
Action Recommendations for Businesses
Formula Audit: Review microbial content, high-concentration organics, and polymer films to assess if upgrades are needed for biodegradability standards.
System Construction: Begin understanding EU DPP data formats and prepare management systems to integrate QR codes into packaging design.
Authorized Representative: Non-EU manufacturers should immediately begin screening and signing EU representatives to ensure compliance by 2029.
Technical Backups: Organize lab data and safety reports according to the new "Module A" requirements to ensure technical file integrity.
While the transition period lasts three and a half years, building digital systems and adjusting formulas is no small feat. Companies should act early to avoid entry barriers in 2029.
For more information or assistance, please feel free to contact us at customer@reach24h.com.
