New regulation (eu) 2026/405 on detergents

Part 1 – Obligations of economic operators

On 2 March 2026, Regulation (EU) 2026/405 on detergents was published, repealing Regulation (EC) No 648/2004 and comprehensively redefining the European regulatory framework applicable to detergents and surfactants.

Regulation (EU) 2026/405 establishes the new legal requirements that must be fulfilled in order to place detergents and surfactants on the European market.

The new regulatory framework goes beyond a technical update. It introduces an extended responsibility architecture across the entire supply chain, clearly defining roles, documentation obligations, digital traceability, and long-term data retention requirements.

This technical series is structured into three in-depth articles:

• Part 1 – Obligations of Economic Operators
• Part 2 – Labelling Obligations (Physical and Digital)
• Part 3 – Digital Product Passport (DPP) for Detergents

In this first article, we analyze in practical terms what changes for manufacturers, importers, distributors, authorised representatives, and re-packagers, with a focus on organisational impact and process digitalisation.

Why regulation 2026/405 is strategic for chemical companies

The new Regulation pursues two primary objectives:

1. Strengthening the protection of human health and the environment
2. Updating and simplifying labelling and information management in light of technological developments

The introduction of the Digital Product Passport (DPP) marks a structural shift: compliance will no longer be purely documentary, but digital, structured, and traceable.

For companies, this means:

• Revision of SDS documentation workflows
• Integration between CLP, REACH, and detergents compliance management
• Automation of 10-year data retention processes
• Continuous compliance control across the supply chain

What are the obligations of manufacturers under regulation (eu) 2026/405?

The manufacturer is primarily responsible for ensuring that the detergent or surfactant complies with Regulation (EU) 2026/405.

Only products compliant with the new Regulation — which formally repeals Regulation (EC) No 648/2004 — may be placed on the market.

The manufacturer’s obligations include:

1. Providing the technical documentation required under Annex IV of the Regulation.
2. Creating the Digital Product Passport (DPP) for the detergent or surfactant, ensuring the presence of a data carrier on the product granting access to the DPP, and registering the reference in the Digital Product Passport registry.
3. Retaining both the technical documentation and the DPP for at least 10 years after the product has been placed on the market.
4. Ensuring that the detergent is labelled in compliance with the Regulation (to be analysed in Part 2).
5. Taking corrective measures in cases of non-compliance (bringing the product into conformity, maintaining a complaints register, withdrawal or recall) and informing other economic operators without undue delay.
6. Providing the ingredient data sheet for detergents or surfactants not subject to PCN notification requirements.
7. Cooperating with national authorities (including communication of corrective measures and provision of information upon request).
8. Making communication channels publicly accessible via their website (e.g. telephone, email, dedicated contact section).

This requires structured management of:

• Formulation data
• Surfactant biodegradability assessments
• Evidence of compliance with environmental requirements
• Links with CLP classification and Safety Data Sheets (SDS)

The mandatory 10-year retention period makes a traceable and auditable digital system essential.

Authorised representative: scope of mandate

The manufacturer may appoint an authorised representative to carry out tasks defined in a written mandate, including:

• Verification of labelling and DPP and registration submission
• Retention of documentation
• Provision of information to competent authorities upon request

However, the mandate cannot transfer the manufacturer’s core obligations, including:

• The obligation to ensure product compliance
• The obligation to draw up the technical documentation

Non-EU manufacturers are not exempt from the Regulation: they must provide the authorised representative or importer with all information and documentation necessary to demonstrate compliance with Regulation (EU) 2026/405.

What are the obligations of importers and distributors?

Before placing a detergent or surfactant on the market, importers and distributors must ensure that the product complies with the Regulation.

This means that, beyond verifying the presence of the DPP, technical documentation, and compliant labelling, they must also:

• Ensure that storage and transport conditions do not compromise product compliance
• Provide the ingredient data sheet
• Adopt corrective measures and consider not making the product available on the market in case of non-compliance
• Verify compliance prior to placing the product on the market

Furthermore, the obligations of the manufacturer apply to importers and distributors where they:

a) Place a detergent or surfactant on the market under their own name or trademark;
b) Modify a product already placed on the market in a way that may affect its compliance; or
c) Make a surfactant available to end users when it was not originally intended for final users.

Re-Packaging activities

Distributors and importers who repackage products under their own name, without assuming full manufacturer obligations, may also be required to:

• Indicate their details (name, trademark, postal and electronic address) on the product, preceded by the wording “(re)packaged by”;
• Retain a sample of the original labelling information for 10 years after the product has been placed on the market;
• Retain the reference to the unique DPP identifier for detergents or surfactants intended for consumers for 10 years after placing on the market.

Date of application and transitional period

Regulation (EU) 2026/405 will apply from 23 September 2029, at which point Regulation (EC) No 648/2004 will be repealed.

Detergents and surfactants placed on the market before 23 September 2029 and compliant with Regulation (EC) No 648/2004 (applicable until 22 September 2029) may continue to be made available on the market without time limitation.

Products placed on the market between 23 September 2029 and 23 September 2030 in compliance with Regulation (EC) No 648/2004 (as applicable on 22 September 2029) may continue to be made available until 23 September 2030.

Practical impacts of regulation (eu) 2026/405 for companies

Regulation 2026/405 is not merely a legislative update.

It represents a paradigm shift toward:

• Structured digital compliance
• Full supply chain traceability
• Integration between REACH, CLP, and detergents regulation
• Centralised technical documentation management

The new regulatory framework introduces a broad and structured adaptation period and allows unlimited sell-through of existing stock. The EPY team is already integrating all provisions of the new Regulation into EPY software solutions.

Preparing today means reducing risk tomorrow

The transitional period is generous, but organisational complexity is significant.

Now is the right time to:

• Verify compliance with Regulation (EC) No 648/2004
• Digitalise documentation management
• Integrate SDS and DPP management systems

The EPY X Detergents Module enables structured management of current Detergents Regulation obligations and prepares your organisation for the upcoming regulatory evolution.

👉 Want to understand whether your current system is ready for Regulation 2026/405?
Request a demo of our SDS and detergents compliance management software.

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