Ultimo aggiornamento 16 June 2026

Detergents Regulation (EU) 2026/405

A Practical Guide to Understanding What’s Changing

The new European regulatory framework for detergents and surfactants has been published: the Regulation (EU) 2026/405, which replaces the historic Regulation (EC) No. 648/2004. The new text is not merely a formal update; rather, it introduces a more modern framework that is more closely aligned with the structure of recent European product regulations and places greater emphasis on traceability, the digitization of information, and the roles of economic operators.

Businesses still have time to comply, as the rule will not take effect immediately.

However, time is of the essence because the new regulation could have significant implications: who it applies to, which products it covers, what the transition periods are, and which changes will truly impact the operations of manufacturers, importers, and distributors.

What is Regulation (EU) 2026/405?

Regulation (EU) 2026/405 establishes the new European framework for the placing on the market of detergents and surfactants for detergents, and, more generally, for the management of related information and compliance obligations. The objective is twofold: on the one hand, to ensure the functioning of the internal market, and on the other, to ensure a high level of protection for human health and the environment.

Compared to the past, the new text more clearly highlights four key areas. The first is sustainability, which continues to be reflected in requirements related to biodegradability and the management of environmental impact. The second is the digitization of information, through tools such as digital labeling and digital product passports. The third is clarity regarding obligations throughout the supply chain, with a more explicit allocation of responsibilities among manufacturers, importers, distributors, and, where applicable, authorized representatives. The fourth isthe updating of the regulatory framework with regard to product innovation, including to cover cases that have become established on the market over the years but which the old regulation did not adequately address.

Because it replaces Regulation (EC) No. 648/2004

For over twenty years, Regulation (EC) No. 648/2004 served as the central framework for the detergents sector in the European Union. Over time, however, the market has changed: new formulation solutions have emerged, there has been a greater focus on the responsibility of economic operators, and the European regulatory framework has evolved toward more integrated models of traceability, market surveillance, and digital documentation.

Regulation (EU) 2026/405 was therefore adopted to modernize the system. In particular, it addresses in a more structured manner aspects that were not covered—or were only partially covered—in Regulation (EC) No 648/2004, such as the treatment of detergents containing microorganisms, the use of the digital product passport, and a stronger focus on market surveillance, with obligations more evenly distributed among supply chain operators. It is therefore not merely “a new text,” but a shift in regulatory approach.

Effective Date

Regulation (EU) 2026/405 was published in the Official Journal of the European Union on March 2, 2026. It is scheduled to enter into force on March 22, 2026, that is, on the twentieth day following its publication.

Effective Date

Although the regulation formally enters into force in March 2026, its general application will begin on September 23, 2029. This transition period has been established to allow economic operators to analyze the new framework, adapt their documentation, internal processes, and information flows, and, where necessary, their product portfolios.

Transitional timeline

The new regulation includes a significant transitional regime, which companies will need to read carefully in order to properly plan the transition from Regulation (EC) No. 648/2004 to the new framework.

Detergents and surfactants already placed on the market before September 23, 2029, provided they comply with Regulation (EC) No. 648/2004, may continue to be made available on the market without a specific time limit. This means that stock already present in the distribution chain prior to the general application date may continue to circulate.

A second transitional period is also provided for: detergents and surfactants placed on the market after September 22, 2029, and before September 23, 2030, provided they comply with Regulation (EC) No. 648/2004 in the version applicable as of September 22, 2029, may remain on the market until September 23, 2030. This measure is designed to manage the transition for products that have not yet entered distribution by the date of application of the new regulation but still comply with the old framework.

In addition to these general rules, the regulation also sets specific deadlines for certain provisions, particularly those related to biodegradability. Therefore, when interpreting the text in practice, it will not be sufficient to focus solely on the date of September 23, 2029: it will be necessary to review each article individually to determine whether different effective dates apply.

To what and to whom does EU Regulation 2026/405 apply?

Affected products

Regulation (EU) 2026/405 applies to detergents, surfactants for detergents, and surfactants contained in detergents placed on the market in the Union. The scope therefore remains focused on products intended for washing and cleaning processes, but has been updated to better reflect technical developments in the sector.

One of the most significant new developments is the focus on detergents containing microorganisms. This is an important point because it clearly signals the legislature’s intent to include even the most innovative formulations within the regulatory framework—formulations that were not subject to such a structured regulatory regime under the previous system. For companies that develop or market these products, the new regulation therefore represents not just a terminological update, but a concrete expansion of the scope of regulatory oversight.

From an operational standpoint, this means that the scope will not be limited to “traditional” detergents, but will also include products that, due to their composition or mode of operation, require a more modern interpretation of the applicable rules. In this sense, Regulation 2026/405 is consistent with the goal of adapting European regulations to product innovation and new market entry models.

Businesses involved

The new regulation directly affects all major economic operators in the supply chain. It therefore applies not only to those who physically manufacture the detergent, but also to all parties who, in various capacities, are involved in its placing on the EU market or its subsequent distribution.

First, this includes manufacturers established in the European Union, who remain the key players in ensuring product compliance: formulation, technical requirements, mandatory information, labeling, and digital tools largely fall within their sphere of responsibility.

In addition to manufacturers, the regulation applies to importers—that is, entities that introduce detergents from third countries into the EU market. This issue is particularly relevant for these companies, as the new framework strengthens oversight of imported products and requires greater attention to the availability of documentation and compliance information prior to marketing.

Distributors are also involved and can no longer be viewed as entirely peripheral to compliance. The structure of the regulation is, in fact, in line with the most recent European model, under which those who make the product available on the market must also ensure that the required information is provided and that the marketed product complies with formal requirements.

For non-EU operators, the role of the authorized representative is also significant, as it aligns with the goal of strengthening points of contact with EU authorities and the need to establish clear lines of responsibility throughout the supply chain. This aspect will be particularly important for non-European brands that wish to continue accessing the EU market with an organizational structure compliant with the new rules.

Another aspect that should not be overlooked concerns the operators involvedin the importation of products from third countries andtheir release for free circulation. The new regulatory framework is, in fact, more closely aligned with the logic of market controls and the traceability of product information, making the link between regulatory compliance, access to the EU market, and the availability of information—including in digital format—more significant.

In summary, Regulation (EU) 2026/405 applies to a wide range of entities: manufacturers, importers, distributors, operators who introduce detergents from third countries, and, in the cases provided for, authorized representatives and entities involved in dealings with the authorities. For this reason, even before analyzing the detailed technical requirements, every company should ask itself a preliminary question: what is my role in the supply chain, and what obligations arise from it?

The main changes compared to Regulation (EC) No. 648/2004

1. Microorganisms: Explicit Inclusion in the Regulatory Scope

One of the most notable changes in Regulation (EU) 2026/405 is the explicit inclusion of detergents containing microorganisms within the scope of the regulation. This represents a significant change from Regulation (EC) No. 648/2004.

Detergents containing microorganisms must comply with specific conditions, as set forthin Annex II, which concern, among other things, the characteristics of the strain used and the product’s minimum shelf life. This makes compliance more technical and requires a careful review of the applicable criteria, especially in cases where the microorganism directly contributes to the detergent’s function.

2. Greater focus on the market and economic actors

A second fundamental change concerns the overall logic of the regulation, which is based on market principles that differ from those of the 2004 framework.

Regulation (EU) 2026/405 takes a more decisive step toward the model established by the most recent European product regulations: obligations are no longer concentrated solely on the manufacturer but are distributed throughout the entire supply chain, with a clearer allocation of responsibility among the various economic operators.

This means that manufacturers, importers, distributors, and other parties involved in bringing the product to the EU market must be regarded as active participants in the compliance system. The regulation therefore reinforces the logic of market surveillance, making the relationship between documentation, the identification of the economic operator, and the accessibility of information to the authorities more structured. In other words, a compliant product is no longer merely a “well-designed” product, but also one supported by an organizational and documentation framework consistent with the new European system.

Authorized representative

For operators based outside the European Union, one of the most significant changes is the role of the authorized representative. The regulation stipulates that non-EU manufacturers may place detergents and surfactants on the EU market provided they appoint an entity established in the EU to act as a point of contact and provide support regarding compliance matters.

This role is not merely a formality. Under the new regulation, the authorized representative helps ensure more effective communication with the competent authorities, ensures the availability of relevant documentation, and strengthens the presence of a clearly identifiable point of contact within the EU market. For non-European trademarks, therefore, compliance can no longer be managed indirectly or in an unstructured manner.

Release for free circulation

Another particularly interesting point for importers concerns the link between regulatory compliance and release for free circulation. According to the official information available on the new regulation, it appears that, for detergents and surfactants entering the EU from third countries, the reference to the digital product passport must also be available for customs inspections.

This is a very important point because it directly links customs issues to digital documentation. It is no longer just a matter of having technical information available “downstream,” but of making the product identifiable and verifiable as soon as it enters the EU market. For importers, this means they need to better coordinate supply chains, technical documentation, and digital compliance tools.

Conclusions

Regulation (EU) 2026/405 marks an important milestone for the detergents sector. It does not merely repeal and replace the Regulation (EC) No. 648/2004, but it introduces a more up-to-date framework designed to better respond to market developments, the digitization of information, and the growing focus on the accountability of economic operators.

For businesses, the key points to keep in mind are clear: the explicit inclusion of detergents containing microorganisms within the regulatory scope, a greater emphasis on the roles and obligations of manufacturers, importers, distributors, and authorized representatives, the link between compliance and release for free circulation, and above all the introduction of the digital product passport as a new central tool for accessing and managing information.

Although the regulation will generally take effect on September 23, 2029, the work involved begins much earlier. Companies will need to determine whether and how their products fall within the new scope of application, correctly identify their role in the supply chain, review document flows, and prepare for a more structured management of technical and digital information.

That is why the right time to start is not in 2029, but now: with a technical review of the regulations, a well-reasoned gap analysis, and a compliance plan that aligns with your business model.

If your company manufactures, imports, or distributes detergents, Chemicals Consulting can assist you with:

• technical training for the regulatory, quality, export, and sales teams;
• regulatory impact analysis on products and corporate roles;
• Consulting support to help interpret regulatory requirements, transitional provisions, and operational changes.

To learn more about this topic or assess your company’s readiness, please contact us: addressing these issues in advance will help reduce risks and ensure you’re fully prepared when the new regulation takes full effect.