The UK retained the EU Detergent Regulation (EC) 648/2004 after Brexit, so the current UK rules are harmonised with that original EU regulation. However, the UK government can now modify or update its own regulations independently from the EU, which might lead to some divergences over time. There are also ongoing revisions expected by 2027 to 2028, focusing on product safety and sustainability, like emphasising the biodegradability of detergent components.

Detergents placed on the EU market must comply with a comprehensive set of requirements designed to protect human health, ensure environmental safety, and facilitate the free movement of goods across EU member states.

CERTLabel offers comprehensive regulatory and market representation support within this product area. Please feel free to arrange a time to discuss your requirements at: www.reviewmyproject.com.

The biodegradability of surfactants is a core requirement under the EU Detergents Regulation. This regulation ensures that surfactants used in detergents are environmentally safe by mandating that they must be ultimately biodegradable before being placed on the EU market. There is a legal requirement to demonstrate ultimate biodegradability through testing. Testing requirements will vary depending on your ingredients and product scenario.

The EU Detergents Regulation sets out comprehensive requirements for the labelling and ingredient disclosure of detergents to protect consumers, support emergency response, and ensure transparency.

Key Labelling Requirements:

• Product Identification
  • The label must display the product name and trade name.
  • The name, full address, and telephone number of the responsible party (manufacturer or importer) must be included.
• Contact Information
  • An address, email, and telephone number for obtaining ingredient information, especially for medical personnel, must be present.
  • The label must provide a website address where a full ingredient list is accessible to consumers.

The online ingredients list for detergents sold in the EU must comply with the requirements set out in Regulation (EC) No 648/2004 (Detergents Regulation), specifically Annex VII D.

The following information must be included:

1. All ingredients present in the product, listed in descending order of concentration, using either INCI names (International Nomenclature of Cosmetic Ingredients) or widely recognised chemical names.
2. For certain ingredient classes, disclosure is required if present above 0.2% by weight:

• Phosphates
• Phosphonates
• Anionic surfactants
• Cationic surfactants
• Amphoteric surfactants
• Non-ionic surfactants
• Oxygen-based bleaching agents
• Chlorine-based bleaching agents
• EDTA and its salts
• NTA (nitrilotriacetic acid) and its salts
• Phenols and halogenated phenols
• Paradichlorobenzene
• Aromatic hydrocarbons
• Aliphatic hydrocarbons
• Halogenated hydrocarbons
• Soap
• Zeolites
• Polycarboxylates

3. The following must be listed irrespective of their concentration:

• Enzymes
• Disinfectants
• Optical brighteners
• Perfumes

4. Preservation agents must be listed irrespective of their concentration, using INCI names where possible.
5. Allergenic fragrances that are present at concentrations exceeding 0.01% by weight must be listed using their INCI names. The list of allergenic fragrances is defined in Annex III, Part 1 of the Cosmetics Regulation (EC) No 1223/2009.
6. The list must be freely accessible to the public, without login requirements, and kept up to date. The website address where the list can be found must appear on the packaging.
7. Perfumes, essential oils, or colouring agents are considered single ingredients and should be listed as such.

• Ingredient Listing
  • Ingredients are disclosed in weight percentage ranges:
    • Less than 5%
    • 5% to less than 15%
    • 15% to less than 30%
    • 30% and more.
• Fragrance Allergens
  • Allergenic fragrances listed in Annex III of the Cosmetics Products Regulation must be named on the label if present above 0.01% by weight.
  • Perfumes must be declared generically if present; specific allergens must be named if they exceed the threshold.
• Dosage and Usage Instructions
  • For laundry detergents, the label must include recommended dosage by water hardness and wash cycle, measuring cup capacity, and the estimated number of standard loads.
• Hazard Information
  • If the detergent is classified as hazardous, the label must comply with the CLP Regulation (EC No 1272/2008), including hazard symbols and precautionary statements.

The EU Detergents Regulation sets strict restrictions on hazardous substances in detergents to protect human health and the environment. These requirements are harmonized across the EU, ensuring a high level of safety and environmental protection.

1. Phosphates and Phosphorus Compounds

• Phosphates in Laundry and dishwasher Detergents.
• Scope:These limits apply only to consumer products, not to industrial or institutional detergents.
• Purpose:These restrictions are designed to reduce eutrophication in water bodies, a major environmental concern caused by phosphorus pollution.

2. Other Hazardous Substances

• General Hazardous Chemicals:Detergents containing substances classified as hazardous under the CLP Regulation must be appropriately classified, labelled, and packaged before being placed on the market.
• Notification Requirements:Products classified as hazardous must be notified using the harmonised Poison Control Notification (PCN) before being marketed in any EU country.
• Ingredient Restrictions:The regulation imposes limits or bans on substances known to pose risks to health or the environment.

3. National and Additional Requirements

Some EU countries may have additional restrictions or notification requirements for hazardous and non-hazardous detergents and the European Commission continues to review and potentially lower limits on hazardous substances.

4. Safety Assessment and Compliance

Manufacturers must provide detailed ingredient and safety data to authorities and medical personnel upon request. Every ingredient in a detergent must undergo a safety assessment to ensure it does not pose undue risk to consumers or the environment.

The EU has taken a decisive stance on animal testing in the context of detergents. The Detergents Regulation implements a general ban on animal testing for detergents and their ingredients, aligning with the EU’s broader commitment to phase out animal testing in chemicals legislation.

Key Points of the Ban

• Prohibition of Animal Testing:
  • Detergents and surfactants placed on the EU market must not be tested on animals. This applies to both finished products and their ingredients.
  • The ban includes both marketing and performance of animal tests within the EU.
• Alternative Methods:
  • Only non-animal (alternative) testing methods, validated and adopted at the EU level, are permitted for demonstrating product safety.
  • The use of historical animal test data is allowed, but new animal testing for detergents and surfactants is prohibited.
• Exceptional Circumstances:
  • The regulation allows for narrow exemptionsin exceptional cases, subject to EU approval, if no alternative methods exist and there is a compelling safety reason.
  • Such exemptions are expected to be rare and tightly controlled.

Implications for Manufacturers

• Compliance:
  • Only detergents and cleaning products whose ingredients have been tested using alternative, non-animal methods are permitted on the EU market.

Non-EU manufacturers must also comply, with an EU-based representative ensuring adherence to the regulation.

National Authorities in each EU member state are responsible for enforcing the regulation. Key enforcement features include:

• Market Surveillance: Authorities monitor compliance at all stages.
• Digital Product Passport: The revised regulation introduces a digital product passport, required for each batch of detergent, to facilitate traceability and compliance checks at borders and in the market. This passport must be archived for at least 10 years after the product’s first market entry.
• Border Controls: Products imported from outside the EU must have an EU-based importer or authorized representative to ensure compliance and cooperate with authorities. The digital passport will be checked at EU borders, including for online sales.
• Enforcement Actions: Authorities can issue enforcement notices, require product withdrawals, or impose penalties for non-compliance. Serious breaches can result in criminal sanctions, including fines and imprisonment in some member states.
• Safeguard Clause: If a specific detergent poses a risk to health or the environment, national authorities may provisionally ban it and must notify the European Commission, providing scientific justification. The Commission coordinates further action across the EU.
• Notification to Poison Centres: Hazardous detergents must be notified to national poison centres before being marketed, using the harmonised format via the ECHA portal. This supports rapid emergency response and consumer safety.

Additional National Requirements: Some member states may impose extra documentation, language requirements, or registration on national portals, which must be observed alongside EU-wide rules.

You are welcome to arrange a complimentary initial consultation with our team to discuss your requirements and explore how we can assist you in meeting your product legislative obligations. Please visit www.reviewmyproject.com to book a convenient time for us to talk.