EU Detergents Regulation (EU) 2026/405: what changes for surfactants

The regulation was adopted on 11 February 2026 and gives industry a long runway: the substantive obligations bite in September 2029, and stock already on the market keeps a sell-through window into 2030. Two biodegradability duties sit outside that date and arrive later.

Article 1 sets rules for the free movement of detergents and surfactants in the internal market. The definition of a detergent in Article 2 now expressly includes micro-organisms, which closes the gap left by (EC) No 648/2004 for probiotic and enzyme-plus-culture cleaning products. Refill sales and distance sales are covered explicitly, and obligations are allocated across manufacturers, authorised representatives, importers and distributors.

It does not affect the application of REACH, CLP or the Biocidal Products Regulation. A surfactant with an antimicrobial claim still needs its own biocidal pathway; detergent compliance and biocidal authorisation remain separate tracks.

Article 4 keeps ultimate aerobic biodegradability as the core duty for surfactants and for surfactants contained in detergents. Annex I Part A defines the pass criteria: at least 60 % mineralisation in 28 days in a CO₂ evolution, manometric respirometry, closed bottle or MITI test, or at least 70 % in a DOC die-away or modified OECD screening test. Pre-adaptation is not allowed and the 10-day window principle is not applied.

Tests must be run by laboratories working to GLP under Directive 2004/10/EC or accredited under Regulation (EC) No 765/2008. That raises the evidential bar: screening data from a non-GLP, non-accredited laboratory will not carry a dossier.

Two further biodegradability duties phase in later. Films and polymers within films must meet Annex I Part B by 23 March 2032. Other organic substances intentionally added at 10 %w/w or more of the total mass excluding water, other than surfactants and films, must meet Annex I Part C by 23 March 2034, unless a derogation in Part D applies. Surfactants used as approved biocidal disinfectant actives are exempt from Article 4(1) under the conditions in Article 4(2).

Article 21 introduces the biggest operational change. Before placing a detergent or end-user surfactant on the market, the manufacturer must create a digital product passport for that specific model, stating that compliance has been demonstrated and carrying at least the data in Annex VI Part A. The passport must be accurate, complete, up to date, available in the languages of the Member States where the product is sold, and kept available for 10 years from placing on the market, including after insolvency or liquidation.

The passport is reached through a data carrier linked to a persistent unique product identifier. The carrier must be printed on the label, the packaging or the accompanying documents for bulk, must be indelible and machine readable, must be present at refill stations, must be visible before purchase and must be accompanied by wording such as "Please scan for more comprehensive information on the product".

Passports are registered in a Commission registry (Article 24), and customs authorities verify them through the EU Customs Single Window (Article 25) from 23 September 2029 or from the date the interconnection is operational, whichever is later.

Every detergent and surfactant made available in individual packaging or through refill needs a label (Article 17), carrying the information in Annex V Part A. Consumer laundry detergents, consumer automatic dishwasher detergents and consumer surface detergents additionally need dosage information under Annex V Part B.

Article 18 allows a digital label, but only in addition to a physical label: information in Parts A and B must be duplicated physically, information in Part C may be digital only, and a small set of Part A items (product identity and related points) must stay physical. Article 19 sets the quality rules for digital labels: searchable, accessible across common browsers and assistive technology, available for 10 years, language choice not tied to geolocation, and no tracking of usage beyond what is strictly necessary.

Ingredient disclosure moves into the technical documentation as an ingredients data sheet, which must identify the product, the responsible operator and the ingredients. The manufacturer must also make an ingredients data sheet for emergency health response available where surfactants are supplied directly to consumers or other end-users.

Detergents containing intentionally added micro-organisms must comply with Annex II. Strains must be deposited with an International Depository Authority, identified by whole genome sequence analysis and named to genus, species and strain level. Genetically modified micro-organisms are not permitted.

Seven pathogens must be absent, including Escherichia coli, Staphylococcus aureus, Salmonella spp and Pseudomonas aeruginosa. Strains must remain susceptible to the major antibiotic classes apart from intrinsic resistance. Products need a plate count of at least 1 × 10⁵ CFU per millilitre or gram at placing on the market, a minimum shelf life of 18 months and at least 1 × 10⁴ CFU per millilitre or gram at end of shelf life, plus a documented safety risk assessment and substantiation of every performance claim.

Article 7 requires compliance to be established with non-animal test methods validated at Union or international level, and prohibits placing on the market detergents and surfactants whose final formulation, ingredients or combinations of ingredients have been subject to animal testing to meet the requirements of the regulation.

Data acquired before 22 March 2026 may still be used. Derogations are possible only in exceptional circumstances, by Commission implementing decision, where a safety concern arises about an ingredient, potentially after consulting ECVAM.

The date is distant, but the gating item is data. Biodegradability studies to GLP or accreditation take months to schedule and run, and every passport entry depends on having that evidence and the ingredient identity settled first.

Environmental data is stated per grade. NEXOVANT F Eco reached 74.7 % ThCO₂ in 28 days under OECD 301B (GLP), which clears the 60 % CO₂ evolution criterion in Annex I Part A with margin and comes from a GLP study rather than a screening run. F Pro is under final assessment. Aquatic toxicity is reported as registered EC50 values under OECD 201 (algae, 72 h) and OECD 202 (Daphnia magna, 48 h), and the CLP classification is stated per grade. NEXOVANT is non-mutagenic under OECD 471 (GLP).

For disinfectant applications, SYLVAXIS is DIN EN 1276 compliant and currently at TRL 4. Note that Article 4(2) exempts approved biocidal disinfectant actives from the surfactant biodegradability duty under defined conditions, while biocidal authorisation itself remains a separate pathway.