Core Regulatory Changes and New Requirements
Regulation (EU) 2026/405 expands and updates the existing rules governing detergents in several key areas:
- Expanded Scope of Regulation
The new regulation goes beyond traditional detergent products. It explicitly brings detergents containing microbial ingredients (such as probiotic detergents), refill sales, and online sales within its scope. This ensures that emerging products and sales models are subject to the same high standards for health and environmental protection.
- Stricter Biodegradability Standards
To minimize the negative impact of detergents on aquatic ecosystems, the new regulation introduces stricter ultimate aerobic biodegradation standards. Crucially, the biodegradability testing requirements have been significantly expanded:
- Water-Soluble Films and Polymers within Films: Must meet new biodegradability standards (effective March 23, 2032).
- High-Concentration Organic Substances: Organic substances present at ≥10% w/w (excluding water) must also comply with biodegradability standards (effective March 23, 2034).
- Comprehensive Updates to Labeling Rules
Labeling requirements have been modernized to enhance consumer safety awareness and ease of use:
- Physical Labels: Must contain essential safety and health information, contact details, usage instructions, hazard information, details on fragrance allergens and preservatives, and simplified dosage instructions.
- Unique Formula Identifier (UFI): Must be added to the general labeling requirements as specified in Annex V.
- Digital Labeling Option: Introduces digital labels (e.g., accessible via a QR code), allowing manufacturers to provide certain non-core formulation information digitally. The European Commission will adopt delegated acts by October 1, 2028, to define acceptable IT solutions.
- Fragrance Allergens: Information disclosure requirements are now aligned with the EU Cosmetics Regulation (EC) No 1223/2009.
- Introduction of the Digital Product Passport (DPP)
This is one of the most forward-looking measures in the new regulation. Manufacturers must create a Digital Product Passport (DPP) for detergents and end-user surfactants. The DPP will contain product information listed in Annex VI and will be linked to a unique identifier in the EU registry. This not only improves supply chain transparency but also greatly facilitates verification by customs and market surveillance authorities.
- Prohibition of Animal Testing
The regulation explicitly states that compliance must be demonstrated using non-animal testing methods validated at the EU or international level. The placing on the market of detergents and surfactants that have been the subject of animal testing on the final formulation or ingredients to meet the requirements of this regulation is generally prohibited, with very limited exceptions.
How Will Businesses Be Impacted?
The new regulation will have a profound impact on all economic operators placing detergents and surfactants on the EU market, including manufacturers, importers, distributors, and online retailers.
Businesses will need to re-evaluate their product formulations, paying particular attention to the biodegradability of high-concentration organic substances and water-soluble packaging films. Concurrently, companies must invest in digital infrastructure to meet the requirements for the Digital Product Passport (DPP) and potential digital labels. Furthermore, compliance assessment procedures and technical documentation requirements have been updated (as outlined in Annex IV), requiring businesses to ensure their internal processes can adapt to these changes.
Critical Implementation Timeline
To give the industry sufficient time to adjust, the regulation establishes a phased transition period:
| Key Milestone | Date | Details |
| Entry into Force | March 22, 2026 | The regulation enters into force on the 20th day following its publication in the Official Journal of the EU. |
| Full Application | September 23, 2029 | Fully replaces Regulation (EC) 648/2004; new rules become mandatory. |
| Film / Polymer Biodegradability | March 23, 2032 | Biodegradability requirements for water-soluble films and their internal polymers take effect. |
| High-Concentration Organics Biodegradability | March 23, 2034 | Biodegradability requirements for organic substances at ≥10% w/w take effect. |
Transitional Arrangements: Products placed on the market before September 22, 2029, that comply with the old Regulation (EC) No 648/2004 can continue to be made available on the market indefinitely. Products placed on the market between September 22, 2029, and September 23, 2030, that comply with the old regulation can remain on the market until September 23, 2030.
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