Digital product passport for detergents: what goes into it
By law, the digital product passport of a laundry gel holds nine groups of data. They are listed in Annex VI to the new Detergents Regulation, Regulation (EU) 2026/405 on detergents and surfactants. You already hold most of this information: the trade name, the manufacturer’s address, the list of ingredients. What changes is where it is kept, and the requirement that it be correct for every model from the day that model is placed on the market.
The obligation applies from 23 September 2029. That is almost three years away, but formulations, labels and contracts with importers are slow to change. Below we set out exactly what the Regulation requires and what you can start on now.
Who has to create the passport for a laundry or cleaning product?
Article 21(1) of Regulation (EU) 2026/405 leaves no doubt: before placing a detergent or end-user surfactant on the market, the manufacturer creates a digital product passport for that product. The Regulation was signed on 11 February 2026, published in the Official Journal of the European Union on 2 March 2026, and applies from 23 September 2029 (Article 37). It repeals the old Regulation (EC) No 648/2004.
The passport is created per model (Article 21(2)(a)). A 1.5-litre laundry gel made to one formulation has one passport, and the individual bottles do not get their own. The only exception is where another EU act requires a passport at batch or item level. In that case the passport under the Detergents Regulation may be issued at the same level (Article 21(7)).
The rules cover household and professional products, as well as end-user surfactants, meaning surfactants that reach consumers or professional users. Surfactants sold only between companies as a raw material do not get a passport. By creating the passport, the manufacturer assumes responsibility for the product’s compliance (Article 21(9)), so this is not a task to hand over to the agency that designs its labels.
What must a detergent passport contain?
Annex VI, Part A to Regulation 2026/405 sets out the minimum content of a detergent passport in nine points. Manufacturers already hold much of it in their technical documentation. We have grouped the nine points into five lines:
- the trade name, the unique product identifier and a colour image of the packaging or label, clear enough to identify the model;
- the name, postal and email address and telephone number of the manufacturer and, where applicable, of the importer or authorised representative, together with the manufacturer’s unique operator identifier;
- a reference to the digital product passport service provider hosting the back-up copy of the passport, and an identification of the product that allows traceability;
- an indication that the passport is issued under the sole responsibility of the manufacturer, the product’s commodity code under the Combined Nomenclature, and a statement that compliance with the Regulation has been demonstrated;
- a full list of intentionally added substances and of all intentionally added micro-organisms, with their taxonomic classification (genus, species and strain).
The substance list is the point that will take the most work. It has to be complete, and the ingredients printed on today’s label will not be enough. Carry-over preservatives, the ones that enter the product through its raw materials, must also be listed where they are subject to labelling. Industrial and institutional detergents are exempt from this point when the same information is already provided in a safety data sheet under REACH. The other eight points still apply to them.
The physical label stays, and a digital label is optional
A detergent’s digital product passport does not replace its physical label. Article 17 of Regulation 2026/405 requires a label on every product sold in individual packaging or through refill. Consumer laundry detergents, consumer automatic dishwasher detergents and consumer detergents for surfaces must also carry dosage information on that label.
Separately from the passport, the Regulation introduces a digital label (Articles 18 and 19). It is not mandatory. A manufacturer that chooses to use one can duplicate the label information online, and some data may then appear on the digital label only. Annex V, Part C lists which: the content of anionic, cationic, amphoteric and non-ionic surfactants, phosphates, phosphonates and soap. Anything that concerns health, safety and basic instructions for use stays in print.
The digital label must be accessible through the same data carrier as the passport (Article 19(1)(d)). In practice, the packaging carries a single QR code that leads to the passport and, where there is one, the digital label. The Regulation requires the code to be indelible, visible before purchase and accompanied by the statement ‘Please scan for more comprehensive information on the product’ or a similar statement (Article 21(4)).
If the packaging already carries a code under another EU act, for example under the packaging rules, no second code is added. Article 21(5) requires a single data carrier for the information required by this Regulation and by other EU law.
Refill stations and online sales have their own rules
The Detergents Regulation deals explicitly with the two sales channels where the buyer does not hold the original packaging.
For refill, the seller gives the buyer the physical label and the data carrier for every container it refills (Article 17(2)). The code itself must also be displayed on the refill station (Article 21(4)(d)). For a shop that sells detergents from refill dispensers, that means a label printer next to the dispenser and data that always match the product in the tank.
For distance sales, the offer has to show the label information and a digital copy of the data carrier or of the unique product identifier (Article 20). The economic operator placing the product on the market must supply that copy to distributors and online marketplaces free of charge, within five working days of a request (Article 21(12)). If you sell through other companies’ online shops, expect that deadline to find its way into your contracts.
Imported detergents clear customs with an identifier from the EU registry
Every detergent passport is entered in the EU registry set up under the Ecodesign for Sustainable Products Regulation (EU) 2024/1781. Before placing a product on the market, the economic operator uploads its unique product identifier and unique operator identifier to the registry and receives a unique registration identifier in return (Article 24).
For products imported from outside the EU, that identifier is a condition of customs clearance. Customs authorities release the goods for free circulation only after checking that the unique registration identifier and the commodity code match the data stored in the registry (Article 25(3)). The check runs automatically through the interconnection between the registry and the EU Customs Single Window Certificates Exchange System, from 23 September 2029 or from the date the interconnection becomes operational, whichever is later.
An EU importer of private-label cleaning products has to make sure the passport exists before the goods reach the border. If the factory is in Türkiye or China, the contract should settle who enters the data and who keeps it up to date.
Goods made under the old rules can stay on the shelf for a transition period
Regulation 2026/405 has a transition period that is easy to miss. Article 36 divides products that comply with the old Regulation (EC) No 648/2004 into two groups.
A product placed on the market before 23 September 2029 that complies with Regulation (EC) No 648/2004 may continue to be sold indefinitely. A product placed on the market on or after that date but before 23 September 2030 that still complies with the old rules may be sold until 23 September 2030.
So goods without a passport that are placed on the market under the old rules once the new regime has started can stay on the shelf only until 23 September 2030. That year leaves time to sell through stock and use up old labels, but any model you still plan to sell in 2031 will need a passport regardless.
What is still undecided about the detergent passport?
The technical details of the detergent passport are still missing. Article 21(10) of Regulation 2026/405 requires the Commission to adopt an implementing act covering the data carrier, its layout and position, the applicable standards, access rights, and who may enter and update which data. The act will apply no earlier than 18 months after it enters into force. As of late October 2026 we had found no published draft.
The content of the passport, on the other hand, is already set out in the Regulation itself. That means you can start on three things now:
- An inventory of the models you will sell after September 2029, with their formulations and every market where each will be sold. The passport must be available in the language or languages required by each Member State where the product is sold (Article 21(2)(e)).
- A full substance list for each formulation, including carry-over preservatives. For most manufacturers this is the longest job, because it depends on data from raw material suppliers.
- A decision on the digital label. If you want the phosphate and surfactant data to appear on the digital label only, plan for it together with the new packaging design.
To show what ingredients, dosage, hazards and the registry entry look like in a real passport, we have built a sample passport for a laundry gel.
A detergent passport is a 10-year commitment
A detergent’s digital product passport must remain available for 10 years from the date the product is placed on the market, even if the manufacturer becomes insolvent or ceases activity in the EU (Article 21(2)(g)). That is why the Regulation also requires a back-up copy held by a digital product passport service provider (Article 21(12)(c)).
Given that requirement, the provider is worth choosing carefully. The DigitalProductPassport platform publishes every passport in all 24 official EU languages, stores the data in the EU, and lets you export it in full if you decide to change systems. What we offer detergent manufacturers is described in our solution for laundry and cleaning products. The Regulation itself is covered on our Detergents Regulation page, and if you would like to go through your models with us, get in touch.
