Selling cleaning products in the EU means satisfying three separate frameworks at the same time. The Detergents Regulation governs what has to appear on the pack and how biodegradable your surfactants must be. The CLP Regulation governs hazard classification, labelling, the UFI and the poison centre notification. And if the product claims to kill germs, the Biocidal Products Regulation takes over with an authorisation requirement that dwarfs the other two.
Brands entering this market from cosmetics or from outside the EU usually get the CLP part half right and miss the detergent specific obligations entirely, because those live in a regulation nobody mentions until an inspector does. This guide sets out what applies, in the order you need it.
Key takeaways
- Regulation (EC) 648/2004 sets detergent specific rules on surfactant biodegradability, ingredient labelling and the ingredient data sheet for medical personnel.
- Surfactants must reach ultimate biodegradability of at least 60%, evidenced by supplier test data held in your file.
- The pack must list ingredient classes in weight ranges, plus preservatives by name and fragrance allergens above 0.01%.
- A website ingredient data sheet must be available, and a full formulation must be available to medical personnel.
- CLP applies in full, so classified detergents need hazard labelling, a UFI and an Annex VIII poison centre notification.
- Liquid laundry capsules have their own packaging and formulation requirements, introduced after a wave of child poisonings.
- An antibacterial or disinfectant claim moves the product into the biocidal regime with a product authorisation requirement.
The detergent specific layer
Regulation (EC) 648/2004 is short but consequential. It applies to detergents and to cleaning preparations containing surfactants, which covers laundry liquid, dishwashing products, all purpose cleaners, bathroom sprays and most of what a household cleaning range contains.
Biodegradability
Every surfactant in a detergent placed on the EU market must meet the ultimate biodegradability threshold set in the regulation, generally 60% within the specified period. You do not run these studies yourself. Your surfactant supplier holds the data and should provide it on request, and the evidence belongs in your technical file. Where a surfactant fails, the regulation provides a derogation route for industrial and institutional use only, not for consumer products.
Ingredient labelling
Detergent labelling does not follow the cosmetic model. Instead of a full descending order ingredient list, the pack declares ingredient classes present above 0.2% in weight bands, using the categories set out in the regulation, such as anionic surfactants, non-ionic surfactants, phosphonates, polycarboxylates, EDTA and its salts, optical brighteners and enzymes.
Two categories are always declared by name where present: preservatives, and fragrance allergens present above 0.01%. This is why cleaning product labels list limonene, linalool and citral in a way cosmetic packs list them differently.
| Requirement | Source | Where it appears |
|---|---|---|
| Surfactant biodegradability evidence | Detergents Regulation | Technical file, not the label |
| Ingredient classes in weight bands | Detergents Regulation | Pack label |
| Preservatives and fragrance allergens by name | Detergents Regulation | Pack label |
| Ingredient data sheet | Detergents Regulation | Website, plus full formulation to medical personnel |
| Hazard pictograms, statements, UFI | CLP Regulation | Pack label |
| Poison centre notification | CLP Annex VIII | Submitted before placing on the market |
| Safety data sheet | REACH | Supplied to professional customers and on request |
The ingredient data sheet obligation catches small brands most often. The regulation requires a data sheet listing ingredients to be available, typically on a website address printed on the pack, and a complete formulation to be made available to medical personnel on request. A generic contact page is not enough, and it is a straightforward thing for an inspector to check from a desk.
The CLP layer
Unlike cosmetics, detergents are not excluded from CLP. A cleaning product that is classified as hazardous carries the full chemical label and the notification obligations that go with it:
- Classification of the mixture, usually driven by surfactant irritancy, alkalinity or acidity, solvent content and fragrance materials.
- Hazard labelling with pictograms, signal word, hazard statements and precautionary statements, translated for every market.
- A UFI code on the label, generated from the composition and your company VAT number.
- An Annex VIII poison centre notification in each Member State where the product is placed on the market.
- Packaging measures, including child resistant fastenings and tactile warnings where the classification requires them.
The step by step workflow is the same one described in notifying a hazardous mixture, and the label rules are covered in CLP label requirements. If you are importing finished cleaning product from outside the EU, the obligations attach to you as importer, as set out in importing chemicals into the EU.
Liquid laundry capsules carry additional requirements introduced after serious accidents involving children. These cover the packaging, the solubility of the film, the presence of a bittering agent and the opacity of the outer packaging. If your range includes capsules or pods, treat them as a separate compliance project rather than as a format of your laundry liquid.
The biocidal trap
Cleaning and disinfecting are different activities in EU law. A product that cleans is a detergent. A product that claims to kill bacteria, viruses or mould is a biocidal product in product type 2, and it needs an authorisation under Regulation (EU) 528/2012 before it is placed on the market, with the active substance sourced from a supplier on the approved list.
The claims that trigger this are familiar from the shelf: kills 99.9% of bacteria, antibacterial surface spray, mould remover with disinfectant action. The same analysis we set out for hand sanitiser as cosmetic or biocide applies here, with the product type changed.
Note that removing visible mould stains is a cleaning claim, while preventing mould from returning is a biocidal one. The line is narrower than most marketing teams expect, and it applies to your website and marketplace listings as much as to the bottle.
What is changing
The detergents framework has been recast to modernise rules that predate online retail, refill stations and detergents containing microorganisms. The direction of travel includes a digital product passport carrying the ingredient information that currently sits on the label, specific provisions for refill sales, and a route for microbial cleaning products.
Transition periods apply, so both frameworks will be relevant for a period, and the practical advice is to keep your ingredient data in a structured form that can feed either. If you are planning artwork now, check the current position before printing, because this is a moving target. Keeping track of exactly this kind of change is what a regulatory monitoring subscription is for.
A launch checklist
- Collect surfactant biodegradability evidence and fragrance documentation from suppliers.
- Classify the mixture under CLP and decide the packaging measures that follow.
- Build the label with both the detergent ingredient declaration and the CLP hazard block.
- Generate the UFI and submit the poison centre notification for each market.
- Publish the ingredient data sheet and set up the medical enquiry route.
- Prepare the safety data sheet, as described in our safety data sheet guide.
- Check that the online listing carries the information required by the GPSR, covered in GPSR technical documentation.
- Review every claim for biocidal wording before it goes live.
Bringing it all together
Cleaning products are a good business to be in and a bad one to improvise. The detergent rules are cheap to satisfy if you collect supplier data early, and expensive to retrofit once you have printed labels that lack the ingredient declaration or the data sheet address. The CLP rules are the same ones that apply to any chemical mixture, and the poison centre notification is a hard gate: without it the product cannot legally be placed on the market, and marketplaces increasingly ask for the UFI before they will list.
The one decision that changes the size of the project is the disinfectant claim. Decide it deliberately, because it is the difference between a labelling exercise and a multi year authorisation.
Lexora classifies cleaning product mixtures, prepares CLP labels and safety data sheets, generates UFIs and files poison centre notifications across the EU. Start with a poison centre notification, or take the whole chemical package with the CLP compliance suite.
Frequently asked questions
Do cleaning products need a poison centre notification in the EU?
Yes, where the mixture is classified for health or physical hazards. Annex VIII of CLP requires a notification before the product is placed on the market, and the resulting UFI code has to appear on the label. Unlike cosmetics, detergents are fully within the scope of CLP.
What has to be listed on a detergent label?
Ingredient classes present above 0.2% in the weight bands set by the Detergents Regulation, preservatives by name, and fragrance allergens present above 0.01% by name. The pack must also carry a website address where the full ingredient data sheet can be consulted, alongside the CLP hazard elements where the product is classified.
Are all surfactants allowed in EU detergents?
Only those meeting the ultimate biodegradability requirement, generally 60%, evidenced by test data from the supplier. A surfactant that fails can be used in industrial and institutional products through a derogation procedure, but not in consumer detergents.
When does a cleaning product become a biocidal product?
When it is presented as killing or controlling harmful organisms, for example antibacterial, disinfectant, virucidal or mould preventing claims. That places it in product type 2 under Regulation (EU) 528/2012 and requires a product authorisation with an approved active substance source before it can be sold.
Do I need a safety data sheet for a consumer cleaning product?
You need one for supply to professional and downstream users, and distributors will ask for it. For a hazardous mixture sold to the general public with adequate label information, a safety data sheet does not have to be handed to the consumer, but it must be provided on request to business customers.
What is different about laundry capsules?
They carry additional requirements covering the soluble film, the presence of a bittering agent, the opacity of the outer packaging and the closure, introduced after accidents involving children. Treat capsules as a separate compliance workstream rather than as another format of an existing liquid.
