Part 2 – Labelling requirements for detergents and surfactants
The EU Detergents Regulation 2026/405 introduces new provisions aimed at ensuring greater transparency, traceability and chemical safety across the entire supply chain.
In this second article of our series dedicated to the new regulatory framework for detergents, we take a closer look at the new labelling requirements, focusing in particular on:
- the introduction of the digital label
- new mandatory labelling elements
- integration with the Digital Product Passport (DPP)
- requirements for refill and dispensing stations
- implications for manufacturers, importers and distributors
Understanding these requirements is essential to ensure regulatory compliance and proper management of Safety Data Sheets (SDS) within company processes.
Labelling requirements under the new Detergents Regulation
Under the new regulation, detergents and surfactants must be accompanied by a label and a data carrier providing access to the Digital Product Passport (DPP).
These requirements also apply to products:
- distributed through refill stations
- marketed within the professional supply chain
- placed on the European market
General label requirements
The label must be:
- clear and easily understandable
- accessible to enforcement authorities
- written in one or more languages easily understood in the Member State where the product is sold
These provisions strengthen the link between labelling information, CLP classification and SDS documentation, making digital compliance management systems increasingly necessary.
Mandatory label elements for detergents and surfactants
The regulation introduces a detailed list of information that must appear on the label.
Product identification information
The label must always include:
- Batch number or traceability identifier
- UFI (Unique Formula Identifier)
- Product name and trade mark
Economic operator information
The label must include:
- Name, address, email and phone number of the manufacturer
- Name, address, email and phone number of the importer, where applicable
These elements are essential for product traceability across the chemical supply chain.
Instructions for use and limitations
The label must include:
- instructions for use
- special precautions, where applicable
- indication of professional-use-only, where relevant
Chemical components to be declared on the label
The regulation specifies which categories of substances must be declared.
In particular, the content of:
- components listed in Annex V Part A (phosphates, phosphonates, surfactants, EDTA, etc.) in the following concentration ranges:
- <5%
- 5–15%
- 15–30%
- 30%
It must also indicate the presence of:
- enzymes
- microorganisms
- optical brighteners
- fragrances
Preservatives and allergens: when they must be declared
The regulation introduces new declaration conditions.
Preservatives
They must be indicated when:
- the concentration is >0.0015%
- or when they lead to classification as a treated article under the BPR
If the preservative is already included on the label due to CLP requirements, it does not need to be duplicated.
Allergens
They must be declared when:
- present in concentrations >0.01%
- and listed in Annex V Part D
Again, if they are already indicated due to CLP labelling, they do not need to be repeated.
Detergents containing microorganisms
When a product contains microorganisms, the label must include additional information:
- indication that the product must not be used on food-contact surfaces
- shelf-life information
- specific instructions for use
- any special precautions
Physical label and digital label
One of the most important innovations of the regulation is the introduction of the digital label.
In particular, labelling formats for detergents and surfactants fall into two categories:
- physical label
- digital label with replication of information on the physical label
Where a digital label is used, the physical label may contain only part of the required information.
Information that may appear only on the digital label
Certain elements may be provided exclusively through the digital label:
- composition information related to surfactants, phosphates, phosphonates and soap
- complete labelling information for products distributed via refill stations, except preservatives and allergens, which must always appear on the physical label
- dosage information for laundry detergents, provided it is summarized in a simplified table on the physical label
Information that must appear on the physical label
Some information cannot be provided only digitally:
- batch number or traceability identifier
- manufacturer details (name, address, email and phone number) and importer, where applicable
- product name and trade mark
FAQ – New detergent labelling rules
Does the digital label replace the physical label?
Not entirely.
The digital label may replace the physical label:
- for detergents and surfactants sold through refill stations
- when labelling requirements concern only surfactants, phosphates, phosphonates and soap
However, preservatives and allergens must always appear on the physical label.
What changes compared to Regulation (EC) No 648/2004?
Key changes include:
- introduction of a batch number for traceability
- new conditions for declaring preservatives and allergens
- a data carrier enabling access to the Digital Product Passport
- additional information requirements for products containing microorganisms
- indication of professional use, where applicable
Who is responsible for providing compliant labelling?
Several economic operators have obligations.
EU manufacturer
Responsible for ensuring compliance of the label with the regulation.
Importer
Must ensure that products placed on the EU market meet all labelling requirements.
Distributor
Must verify that the product is accompanied by compliant labelling before placing it on the market, unless the detergent or surfactant is repackaged.
Digitalising compliance: the role of SDS management software
The introduction of:
- digital labels
- the Digital Product Passport
- enhanced traceability requirements
makes manual compliance management increasingly complex.
Chemical companies and detergent manufacturers are therefore adopting software solutions for automated SDS management and CLP labelling, enabling them to:
- generate up-to-date regulatory documentation
- manage compositions and classifications
- automate multilingual labelling
- integrate DPP and regulatory data
The X.648 Detergents Module of EPY X
X.648 Detergents Module of EPY X SDS automation software allows companies to manage the requirements of the EU Detergents Regulation (Regulation (EC) No. 648/2004) in a structured way and be fully prepared for the next regulatory developments.
Free Webinar: Insights into the New EU Detergents Regulation
To explore the new X.648 module and the detergents regulatory framework, we have organized a dedicated webinar: “EU Detergents Regulation: regulatory framework, new obligations and automated compliance solutions.”
đź“… March 25, 2026
During the session, one of our experts from the EPY Regulatory Team will guide you through:
- the regulatory framework of the new detergents regulation
- the key differences compared to the current legislation
- how to automate compliance using the new EPY X detergents module
🎯 Participation is free.
👉 Register now: https://webinar.epy.it/en/product/eu-detergents-regulation-regulatory-framework-new-obligations-and-automated-compliance-solutions/
If you work in regulatory affairs or HSE, this webinar is an update you should not miss.
Next article in the series
In the third and final article, we will explore one of the most innovative aspects of the regulation:
The Digital Product Passport (DPP) for detergents and chemical products.
