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Digital product passport for detergents: from when, and with which data?

As of · sourced from primary law · not legal advice · Auf Deutsch lesen

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This English version was prepared with AI from the German page. No native speaker or lawyer has read it. Found a mistake? Write to office@proofpass.eu.

The short answer

From 23 September 2029. Then the manufacturer creates a digital product passport for every detergent model before placing it on the market (Art. 8(2), Art. 21(1) Regulation (EU) 2026/405). It holds at least the information in Annex VI, Part A, including all intentionally added substances. The Regulation has been in force since 22 March 2026 (Art. 37).

Art. 8(2) and 21(1) Regulation (EU) 2026/405

Legal basis: the new Detergents Regulation

Regulation (EU) 2026/405 on detergents and surfactants was published in the Official Journal on 2 March 2026. It applies from 23 September 2029, except Article 4(3) and (4) on biodegradability (Art. 37). On the same day it repeals Regulation (EC) No 648/2004 (Art. 35). The passport covers detergents and end-user surfactants.

So detergents do not get their passport through the ESPR. The ESPR working plan COM(2025) 187 left detergents, paints and lubricants out. Technically, though, the Detergents Regulation refers to the ESPR: identifiers and registry are the same. The basics are in the guide Digital product passport: deadlines and product groups.

Timeline with status

StepDateStatusProvision
Publication in the Official Journal2 March 2026bindingOJ L 2026/405
Entry into force (twentieth day after publication)22 March 2026bindingArt. 37
Implementing act on data carrier, layout, accessopen, applies at least 18 months after entry into forceplannedArt. 21(10)
Passport duty, repeal of Regulation (EC) No 648/200423 September 2029bindingArt. 35, Art. 37
Goods under the old rules placed on the market from 23 September 2029 to 22 September 2030 may be made availableuntil 23 September 2030bindingArt. 36(2)

What the passport must contain

The passport corresponds to a specific model, is accurate, complete and up to date, is available in the language required by the Member State and remains available for ten years from placing on the market (Art. 21(2)). Part A of Annex VI requires:

  • trade name, unique product identifier and a colour image of the packaging or label
  • name, postal and electronic address and telephone number of the manufacturer and, where applicable, of the importer or authorised representative, with the manufacturer’s unique operator identifier
  • the digital product passport service provider hosting the back-up copy
  • the identification allowing traceability, and commodity codes where applicable
  • an indication that the passport is issued under the sole responsibility of the manufacturer, and the statement of compliance
  • the full list of intentionally added substances under Article 18(3) CLP, including carry-over preservatives where they must be on the label
  • all intentionally added micro-organisms with genus, species and strain name or code

Professional cleaners and the safety data sheet

The substance list does not apply to industrial and institutional detergents or to surfactants where the equivalent information is in the safety data sheet under Article 31 REACH (Annex VI, Part A, last paragraph). If you supply professional cleaners, your safety data sheet then has to be in good order. The rules are in the guide When is a safety data sheet required?.

The data carrier is on the label or packaging, for bulk goods in the accompanying documents, for refills at the station. It carries the statement “Please scan for more comprehensive information on the product” or a similar one (Art. 21(4)). A digital label is possible alongside on a voluntary basis (Art. 18, Art. 19).

What you can do today

  • Keep a list per formulation of the intentionally added substances, as Article 18(3) CLP requires.
  • Have colour images of the label or packaging per model.
  • Check whether your professional products fall under the safety data sheet exception.
  • Plan space on the label for a data carrier with its statement.
  • Watch for the implementing act under Article 21(10). On 11 November 2026 we did not find it on EUR-Lex.

Further reading

Frequently asked questions

Does the passport also apply to bulk cleaners for professional use?

Yes, it applies to all detergents. Only the substance list under Annex VI, Part A, point (h) is not required for industrial and institutional detergents where the safety data sheet contains the equivalent information.

Do I have to retrofit goods placed on the market before 23 September 2029?

No. They may continue to be made available indefinitely if they comply with Regulation (EC) No 648/2004 (Art. 36(1) Regulation (EU) 2026/405).

May I still place goods under the old rules on the market after 23 September 2029?

For one year, yes. Goods that comply with Regulation (EC) No 648/2004 and are placed on the market after 22 September 2029 but before 23 September 2030 may be made available until 23 September 2030 (Art. 36(2) Regulation (EU) 2026/405). After that, newly placed goods follow only the new Regulation with the passport.

Does the passport replace the label?

No. The passport comes on top. A digital label may carry part of the labelling under Articles 18 and 19; the physical label stays.

With ProofPass

ProofPass does not create a detergent passport under Annex VI. Today it delivers your safety data sheet to every recipient, with proof of delivery and an archive of every version, and gives each product a permanent address with a QR code. The substance list for the passport stays in your formulation software.

The terms and legal notices are in German, and the German version is binding.

Sources

As of 11 November 2026. The legal text in force prevails. This page is not legal advice; sources are given above.