EU Detergent & CLP Regulation Guide: 2025 Compliance Update

The European Union is launching a comprehensive update of the rules surrounding detergents. The “Proposal for a Regulation of the European Parliament and of the Council on detergents and surfactants”, published as COM(2023) 217 final, aims to modernize and eventually replace the existing Regulation (EC) No 648/2004. Detergents and surfactants should be able to circulate freely within the EU market, while ensuring the highest level of protection for human health and the environment.

The new regulation addresses key challenges of the old regulation, particularly in the areas of innovation and information requirements. A 2019 review identified issues such as duplicate provisions caused by overlaps with other chemicals legislation, including the Classification, Labelling and Packaging (CLP) Regulation.

The old regulation also failed to adequately cover innovative products such as microbial cleaners or sustainable solutions like refill systems. Moreover, in the absence of digital support, labels were often overloaded with unclear and repetitive text.

The new regulation therefore relies on streamlined legal requirements and digital solutions. At its core are digital labels and a product passport system. This means:

• More transparency: Information will be easier to understand for both consumers and market surveillance authorities
• Clear requirements: For the first time, specific rules will be introduced for detergents containing microorganisms
• Consistent environmental protection: Strict requirements for the biodegradability of surfactants and clear limits for phosphates and other phosphorus compounds will help protect our waters

Additionally, in December 2024, the Regulation (EU) 2024/2865 was adopted, modernizing the CLP framework. For the first time, it allows digital labels and expandable label formats for chemical products, and it establishes clear deadlines and formatting requirements. Although it was not specifically designed for detergents, it paves the way for digital communication of chemical product information.

Detergents Regulation (EC No 648/2004) vs CLP Regulation (EC No 1272/2008)

The CLP Regulation can be seen as a general librarian. It determines how each “book” (chemical product) is generally classified and made accessible, including in digital form. The Detergents Regulation takes on the role of a subject librarian for a specific section (detergents). It applies the general rules and adds specialized features such as the “Product Passport.” This ensures that even in cases of refills or purely digital information, everything remains easy to find, understandable, and safe to access — just like in a well-organized, user-friendly digital catalog.

Overview of Relevant EU Regulations:

Image: Own illustration by info.link; Note: Without guarantee, not legally binding

Why Compliance Matters: Mitigating Risks, Securing Advantage

Like its predecessor, the new Detergents Regulation is legally binding across all EU member states. However, compliance is more than a legal obligation. It offers strategic benefits.

Those Who Do Not Comply Risk a Lot

• No market access: Non-compliant products can be stopped at EU borders
• Financial penalties: Significant fines may be imposed
• Product recalls: Products may need to be withdrawn from the market, which is costly and damages the brand image
• Loss of trust: The reputation of the brand can suffer in the long term

A key element: the new Digital Product Passport (DPP) will act as a digital gatekeeper. Products that do not meet the requirements will be systematically excluded from the EU market.

Thinking Ahead Creates an Advantage

Those who act early and proactively embrace the new regulation stand to gain on multiple levels:

• Secure market access: Cleaning products remain fully available across the EU.
• Greater trust: Transparent, digital product information strengthens consumers’ ability to make informed choices and builds brand loyalty.
• Clear competitive edge: Companies that respond quickly and demonstrate responsibility clearly set themselves apart.
• More efficient operations: Digital labels and product passports reduce manual effort, automate compliance, and speed up internal processes.
• Sustainability as the new norm: Refill models and safe, eco-friendly formulations not only improve environmental performance but also prepare the company for a greener future.

What’s Changing: What Cleaning Brands Need to Know Now

The new EU Detergents Regulation introduces extensive changes, and cleaning product manufacturers must adapt their processes accordingly. The aim of these updates is to create more transparency, simplify compliance, and provide clear answers to the demands of a modern market.

The Digital Product Passport (DPP)

At the heart of the new framework is the Digital Product Passport (DPP).

• A digital ID for every product: Every cleaner or surfactant sold in the EU will require its own digital product passport.
• All relevant data in one place: The passport includes all compliance-relevant information.
• Accessible to authorities and users: Customs, market surveillance authorities, and end users will have direct access to this information.
• Digital access control: The DPP becomes the central gatekeeper for market access and makes compliance checks more efficient than ever before.

A New Focus on Digital Labeling

In addition to the DPP, digital labeling is becoming a key element.

• Essential information stays on-pack: Safety warnings and usage instructions will remain mandatory on the physical label.
• Additional details go online: Supplementary information can be made available digitally.
• Ideal for new sales models: Especially in refill systems, much of the labeling can be handled digitally.
• Less clutter, more clarity: Overloaded labels are becoming a thing of the past. Instead, users will get up-to-date and easily accessible information.

Image: Online survey for professionals and industry users, European Commission (2023)

The graphic shows results from a stakeholder survey on detergent labeling in the EU. It presents responses to the question: “To what extent do you believe the following information could be removed from the packaging label of a detergent and instead be provided via a digital label?”. The findings are clear: most respondents agree that the product name and safety-relevant information should remain on the physical packaging. In contrast, many believe that ingredient lists and manufacturer details could be made available digitally. A hybrid solution, combining essential on-pack information with extended online content, is frequently favored by a wide range of stakeholders.

More Environmental Protection. More Responsibility.

The regulation also strengthens requirements related to biodegradability and environmental safety.

• Strict standards remain in place: Surfactants must continue to meet high biodegradability criteria.
• Limits on phosphorus compounds: The use of phosphates and related substances is clearly restricted in order to protect aquatic ecosystems.

Less Bureaucracy. Greater Efficiency.

Finally, information obligations are being streamlined. For example, the requirement to provide a substance data sheet for hazardous cleaning products is being removed. This significantly reduces administrative burden and supports a clearer, more efficient regulatory framework.

Responsibilities Across the Entire Supply Chain

The revised EU Detergents Regulation clearly defines who is responsible for what within the supply chain. In some cases, it also expands existing obligations. Manufacturers, importers, and distributors share the responsibility for ensuring that detergents and surfactants are safe and compliant from the initial development phase to the end user.

Manufacturers: Responsibility from the Very Beginning

Manufacturers hold the primary responsibility for ensuring that their detergents and surfactants meet all new requirements.

• Product safety and compliance: This includes thorough assessments, especially for new product types such as formulations containing microorganisms.
• Technical documentation: All relevant records (composition, test reports, evidence of compliance) must be retained for at least 10 years.
• Digital Product Passport (DPP):
• • Mandatory for new products: The DPP will become obligatory for all newly marketed detergents and surfactants 30 months after the regulation enters into force.
  • Transitional periods: Products already on the market or introduced shortly after the regulation takes effect may benefit from transitional provisions.
  • Technical requirements: The DPP must be machine-readable, structured, and searchable. It must be based on open standards and fully compatible with other EU product passports, such as those under the Ecodesign for Sustainable Products Regulation.
  • Data carrier linking to product information: All compliance information must be linked to a unique product identifier via a data carrier (such as a QR code), attached directly to the product or its packaging.
  • Central EU registry: Every DPP must also be referenced in the central EU registry being developed under the Ecodesign framework.
• Ongoing Market Surveillance:
• • Carry out spot checks and inspections
  • Evaluate customer feedback and complaints
  • Respond immediately in case of problems, including recalls or product withdrawals
  • Notify national authorities without delay

Importers: Control Before Market Entry

Importers play a crucial role in ensuring that products from non-EU countries meet all EU requirements before entering the market.

• Compliance verification: This includes checking whether the manufacturer has completed all assessments, whether the CE marking (if applicable) is present, and whether the DPP and digital labelling are available.
• Labelling and documentation: The importer’s name and contact details must appear on the product. Technical documentation must be retained for 10 years.
• Market surveillance: Importers must actively participate in market monitoring, including incident reporting and assisting with corrective measures.

Distributors: Due Diligence at the Point of Sale

Distributors also carry responsibility when making products available on the market.

• Verification obligation: Before selling, they must check that the CE marking, physical label, and digital label are properly in place.
• Storage and transport: Products must not be compromised in their compliance due to improper storage or handling.
• Reporting obligations: In case of suspected non-compliance or risk, distributors must inform the manufacturer (or importer) and the relevant market surveillance authorities without delay and assist with recalls or corrective actions.

Shared Responsibility Across the Supply Chain

All economic operators along the value chain share core responsibilities:

• Cooperation with authorities: Active support is required during inspections, recalls, or when information is requested.
• Data retention: All relevant documentation must be kept for at least 10 years to ensure traceability and product safety.

Labeling Essentials: What Goes Where?

The new EU Detergents Regulation fundamentally changes how ingredients and labelling information must be presented for cleaning products. The focus shifts toward a clearer, digital-first approach without eliminating essential on-pack information.

What Must Remain on the Physical Label

Although the new regulation strongly integrates digital tools, certain key information must still appear directly on the packaging of detergents and surfactants. This includes:

• Product identification: The marketed product name and a type or batch number (or another unique identifier) for traceability.
• Manufacturer or responsible party details: The name, registered trademark or brand, and a postal address serving as the main contact point for the manufacturer or the responsible person placing the product on the EU market. An email address should also be provided.
• Safety and usage instructions: Essential warnings, first aid instructions (if required), and all legally mandated statements related to health and environmental protection. These must be clearly highlighted and easily readable.
• Allergens and preservatives:
• • A clear statement about allergenic fragrances if present above a specified concentration threshold (e.g. 0.01%).
  • Preservatives (such as antioxidants or antimicrobial agents), if used in the formulation and considered relevant.
• Specific usage instructions: For household cleaning products, such as laundry detergents or dishwasher tablets, standardised dosing instructions must remain on the label to help prevent overuse and protect the environment.
• CE marking: The CE marking must be visible, legible, and permanently affixed to the label or packaging as proof of compliance with EU harmonisation requirements.
• Language: All mandatory label information must be available in the official language(s) of the EU member state in which the product is being marketed.

This concept ensures that the most important information remains readily accessible, even without a smartphone or internet connection, while digital channels can be used to provide additional detail.

Image: AISE (2023)

The illustration shows a typical detergent label containing numerous mandatory statements about allergens, surfactants, and hazards, supplemented by online information. Highlighted are problematic duplications, inconsistencies, and complex technical terms. It becomes clear that current labels are often overloaded and difficult to interpret. In particular, the inconsistent presentation of allergens and ingredients leads to confusion.

What Can Be Provided Digitally

Under the new proposal, the requirement to include a full list of ingredients on the physical label will generally no longer apply. This marks a significant step toward simplified packaging and reduced redundancy. Instead, the complete list of ingredients must now be made digitally accessible for nearly all products.

• Ingredient list: Components must be listed in descending order by weight, using recognized nomenclature systems such as INCI or IUPAC. Each entry must also include its function (for example, “anionic surfactant” or “enzyme”).
• Detailed information: Additional data such as extended warnings, first aid measures (if not already required on the physical label), product passport data, or information on environmental and sustainability aspects may also be provided digitally.

Technical Requirements for Digital Ingredient Information and Labels

Digital content, including ingredient lists and additional product information, must comply with clear technical and accessibility standards:

• Accessibility and availability:
• • Must be freely accessible at all times, without registration, downloads, the provision of personal data, or consent to cookies.
  • Must be searchable, structured, and machine-readable, enabling easy use by consumers and professionals alike.
  • Must be mobile-optimized, with short loading times and no need for special software or geoblocking. It must be accessible in every EU member state where the product is sold.
  • Information must be presented clearly, logically, and separately from advertising or other commercial content.
  • Content must be freely accessible to all users within the Union, including authorities, and remain available for at least 10 years from the date the product is placed on the market, unless other EU legislation requires a longer period.
  • Access to the information must require no more than two clicks.
  • Digital labels must be retrievable using commonly available digital technologies, compatible with all major operating systems and browsers, including on mobile devices.
• Language: Information must be provided in the official language(s) of the EU member state where the product is marketed.
• Updates: Changes to the product formulation must be updated digitally without delay.
• Data protection and security: The use of digital labels must not collect personal data or track user behavior.
• Link to the DPP: Where applicable, the digital label must be connected to the product’s Digital Product Passport.
• Durability and readability of the data carrier: The data carrier (e.g. QR code) must be visible, legible, and permanently affixed to the product, its packaging, or refill station. A short, user-friendly instruction on how to access the digital content should be placed nearby.

Digital tools such as info.link demonstrate how these requirements can be put into practice. They allow manufacturers to present comprehensive information on ingredients, functions, and safety data in a structured and user-friendly way.

By scanning a QR code placed on the packaging, consumers are taken directly to a mobile-optimized page that contains all required information — transparent, free of charge, and without the need for registration. Solutions like these show that providing product information digitally is not only a regulatory obligation but also a genuine added value for users.

Digital Labelling: Specific Use Cases and Requirements

The new regulation introduces greater flexibility. Certain information may now be provided exclusively through digital means.

Image: LIDL refills pilot, Packaging Gateway (2022)

Permissible Digital-Only Scenarios, e.g. Refills

Fully digital labelling is explicitly permitted for cleaning products offered to end users in refill formats. This approach supports waste reduction and promotes circular economy models.

However, even in refill scenarios, a minimum set of information must still be provided physically — either directly on the refill station or on the reusable container. For all refilled cleaning products, the following details must appear physically:

• Identification of the substance or mixture (e.g. product name)
• Name or registered trade name/brand of the manufacturer or the person responsible for placing the product on the EU market
• Postal address (serving as the central contact point) and an email address for communication
• Allergen labelling (if relevant and above the threshold concentration)

In the case of laundry detergents intended for consumers, standardised dosing instructions must always remain physically on the label, even in refill formats.

Languages, Formatting, and Accessibility: Making Information Available to Everyone

The new regulation places strong emphasis on ensuring that product information — whether physical or digital — is clear and accessible to all users across the EU.

Language Requirements

All mandatory information — including the product name, safety instructions, allergen declarations, and manufacturer contact details — must be provided in the official language or languages of the EU member state where the product is made available to end users. Manufacturers must ensure that their systems can manage and deliver content in multiple languages, depending on the requirements of each target market.

Formatting Standards

• Physical labels: All information must be visible, easily readable, and permanently affixed. Safety and usage instructions must be clearly highlighted, without distraction from branding or design elements. While no minimum font size is prescribed, legibility must always take top priority.
• Digital labels: Digital content must be accessible immediately, directly, and without detours — not hidden behind multiple clicks or mixed with advertising. The layout should be logically structured, user-friendly, and ideally visually aligned with the physical label.

Ensuring Accessible Design

A key new element is the clear requirement that information must be understandable and accessible to all users, including people with disabilities. While the regulation does not define specific technical standards like those outlined in the EU Accessibility Act, it clearly expects that digital information platforms (such as those accessed via QR codes) follow current best practices for web accessibility. These include, among others:

• Compatibility with screen readers
• Scalable font sizes
• Clear and intuitive navigation
• High contrast between text and background

Physical labels should also contribute to accessibility, for example by avoiding hard-to-read color combinations or excessively small text. This holistic approach ensures that safety and usage information is available to everyone — an important step toward stronger consumer protection.

How to Implement Digital Labeling and Stay Compliant

Transitioning to digital labeling requires a systematic approach, integrating new technologies and processes into your existing operations. Here’s a practical guide for implementation:

1. Choose Your Digital Access Method

Decide on the data carrier that best suits your products and supply chain. Common options include:

• QR Codes: Widely recognized and easily scannable by smartphones. Ideally, QR codes should follow the new global GS1 Digital Link standard, which is set to replace barcodes from 2027. Read more in our comprehensive guide to the GS1 Digital Link. QR codes should also be accompanied by hyperlinks, discussed bellow, in case of scanning difficulties.
• Hyperlinks: A short, easily typable URL printed below the QR code used if scanning is not possible or desired.
• NFC Tags: Offer tap-and-go convenience, but require NFC-enabled devices. The technical hurdles and need for additional instructions make this option less desirable.

Ensure your chosen method is visibly, legibly, and indelibly placed on the product, its packaging, or, for refill formats, on the refill station itself. It must be clear to the end-user before purchase.

2. Develop a Robust Platform for Your Digital Label

This will be the central hub for your digital label content and Digital Product Passports. The portal must:

• Be mobile-friendly and load quickly.
• Provide instant, free, and 24/7 access without requiring registration, downloads, or personal data/cookie consent.
• Support multiple EU languages as required by your markets.
• Present information clearly and logically, separated from marketing content.
• Be well-organised to allow users to quickly find specific details.
• Adhere to web accessibility standards (screen reader compatibility, scalable text, high contrast) to cater to vulnerable groups.

The image shows an example of a robust platform that ensures compliance: With info.link, legally compliant digital labels can be created and linked to future-ready QR codes.

Scan the QR code to view the interactive detergent example!
Or visit the short link: info.link/jq720

3. Integrate Data Management Systems

To ensure that information is always up to date, the digital labelling system must be seamlessly connected to internal data management systems such as ERP (Enterprise Resource Planning) or PLM (Product Lifecycle Management). Any changes to product composition, safety data, or compliance status must be reflected immediately in the digital interface.
Each digital code or label refers to a specific model (product type), since the regulation has, as of June 2025, moved away from the original batch-specific DPP requirement in favor of a more practical model-based approach.

4. Ensure Data Protection and Security

Tracking, analyzing, or using data on how digital labels are accessed is strictly prohibited, except for the sole purpose of making the information available. Manufacturers must implement robust data protection measures to comply with the GDPR and prevent unauthorized data collection.

5. Provide Alternative Access Channels

To account for digital barriers or technical outages, manufacturers must ensure that the information provided via digital labelling is also available upon verbal or written request, free of charge and independent of a purchase. This ensures continued access even when the digital label is temporarily unavailable.

By following this systematic approach, manufacturers can fully comply with the new digital labelling requirements while benefiting from greater transparency and operational efficiency.

Getting Ready: Resources, Systems, and Team Coordination

To meet the full requirements of the new EU Detergents Regulation by the compliance deadline, companies will need a comprehensive strategic plan — covering personnel, IT infrastructure, legal review, and internal workflows.

IT Infrastructure Checklist

• Digital label platform: Tools to create and manage
• • Unique QR codes or other data carriers for each product or product batch
  • Robust, mobile-optimized digital labels that include ingredient lists, safety information, and Digital Product Passports for consumers, authorities, and business partners
• System integration: Seamless connection of the digital labelling platform with existing ERP (Enterprise Resource Planning) and PLM (Product Lifecycle Management) systems to synchronize product data, formulations, and batch information in real time
• Data security and protection: Powerful solutions for real-time updates, secure archiving (at least 10 years), and full GDPR compliance

Legal and Regulatory Review

• Gap analysis: Detailed assessment with legal counsel or external consultants to identify discrepancies between current processes and new requirements
• Ongoing monitoring: Establishment of a process to continuously monitor updates, clarifications, and guidance issued by EU and national authorities
• Documentation obligation: Planning for secure long-term retention of all technical and compliance documentation for a minimum of 10 years

Processes and Training

• SOP adjustments: Revision of Standard Operating Procedures (SOPs) related to product labelling, IT management, traceability, corrective actions, and communication with market surveillance authorities
• Employee training: Comprehensive training on new compliance requirements, digital labelling, reporting procedures, and handling consumer inquiries regarding digital tools
• Internal audits: Simulation of regulatory inspections to verify accessibility and accuracy of both physical and digital data

External Support

For companies that prefer not to develop their own platform, external solutions such as info.link are available. Such platforms are specifically designed to meet EU regulatory requirements and enable fast, simple publication of all necessary product information in digital form. Users gain immediate access to a clearly structured, ad-free interface available in multiple EU languages, optimized for mobile devices and compatible with all major browsers and operating systems.

Smart Market Surveillance, Simpler Compliance

Digital labelling enables authorities to access compliance data in real time and in a standardized format.

Key Benefits for Industry and Authorities

For companies:

• More efficient compliance processes
• Reduced administrative workload
• Greater focus on innovation

For authorities:

• Faster, harmonized enforcement
• Improved consumer protection
• Resources can be directed toward high-risk areas

Digitalization as a Driver of Sustainable Transformation

The introduction of DPPs and digital labels forces companies to modernize their IT systems, centralize product information, and enable real-time updates. This modernization not only automates compliance, but also improves operational efficiency, reduces costs, and opens up new opportunities for stronger customer engagement through richer product information and greater transparency.

Importantly, digitalization aligns perfectly with the EU's environmental goals. Digital product information supports circular economy models such as refill systems and reusable packaging by reducing the need for physical labels. It also enables robust tracking of sustainability data across the supply chain, supports ESG reporting, and builds consumer trust through transparent communication of ingredients and environmental impacts.

How digitalization supports sustainability:

• Promotes circular systems (e.g. refillable, reusable packaging)
• Enables transparent communication of environmental and ingredient data
• Supports stronger ESG reporting and supply chain transparency
• Empowers consumers to make informed and sustainable purchasing decisions

Strategic Advantage Through Change

Early and comprehensive implementation of these requirements ensures compliance and positions companies as innovative, transparent, and responsible players.

Implementing digital compliance now means:

• Real-time updates reduce recall and regulatory risks
• The brand image is strengthened as forward-looking and trustworthy
• Alignment with the Green Deal and Digital Single Market can open access to EU funding and ease market entry

The EU Detergents Regulation shows how significantly regulatory expectations for product information are evolving — and how important it is to invest early in digital solutions that not only meet today’s obligations but are ready for what comes next.

info.link enables centralized management of all legally required information and can be easily adapted to changes in legal frameworks or product composition — without technical complexity or disruption to the flow of information. Whether accessibility requirements, language-specific content delivery, or integration with the Digital Product Passport are needed, a flexible platform structure ensures long-term compliance and reduces operational burden. In addition, users can benefit from many further integrations that add real value.