Adopted in February 2026 and applicable from 23 September 2029, the Detergents and Surfactants Regulation (DSR) replaces a 22-year-old framework and makes the Digital Product Passport mandatory for every detergent and end-user surfactant placed on the EU market. Here is what changes, what stays the same, and what manufacturers should be doing now.
On 11 February 2026, the European Parliament and the Council adopted Regulation (EU) 2026/405 — the Detergents and Surfactants Regulation (DSR). Published in the Official Journal of 2 March 2026, the DSR replaces the 22-year-old Regulation (EC) 648/2004 and introduces a mandatory Digital Product Passport (DPP) for every detergent and end-user surfactant placed on the EU market from 23 September 2029.
For an industry quietly governed by the same framework since the year iPods and Facebook first appeared, this is a substantial reset. Like the Batteries Regulation, the recast Construction Products Regulation, and the forthcoming ESPR textile delegated act, the DSR anchors product information in a persistent, machine-readable carrier visible to consumers before purchase. Here is what changes, what stays the same, and what manufacturers should be doing now.
What Changes Versus the Old Detergents Regulation
Regulation 648/2004 ran to 19 articles; the DSR has 37 articles and 8 annexes, with entirely new chapters on conformity assessment, digital labelling, refill operations, customs verification — and, at its centre, the Digital Product Passport. The headline shifts: an animal-testing ban (in force since 22 March 2026); a much wider scope that pulls in four product groups the old law largely ignored; a dedicated regime for detergents containing micro-organisms; and a stepwise tightening of biodegradability rules out to 2034. The surfactant biodegradability thresholds and phosphate limits themselves are carried over unchanged. The fifth — and by far the biggest — change is the one the rest of this article is about: the Digital Product Passport.
The Digital Product Passport. From 23 September 2029, every detergent and end-user surfactant on the EU market needs a DPP — a machine-readable record, reachable from a QR code on the pack and visible before purchase, registered in a central EU registry. It is the focus of the rest of this article.
See it in action
Want to see what a DPP system looks like in practice?
Explore our interactive demo of a working DPP system — the tool that creates and fills passports, not a passport itself. It's built for furniture makers and readily adaptable to detergents, with UNTP verifiable credentials and role-based access. A detergent-specific demo is available on request.
Explore the DPP System Demo →Which Products Are Now in Scope
The DSR's definition of "detergent" is broader than the old one. Six familiar categories carry over; four are newly captured — brands selling these were largely outside Regulation 648/2004 and are squarely inside this one. Select any card for the legal basis.
NEW marks the four categories the DSR brings into scope that largely fell outside Regulation 648/2004. Each product, formulation and variant in any of these categories needs its own DPP from 23 September 2029.
The Compliance Timeline (2026–2034)
The DSR was adopted on 11 February 2026 and published in the OJ L of 2 March 2026. The roadmap below bundles every dated milestone across three tracks — the DSR core regulation, the delegated and implementing acts the Commission still has to adopt, and the DPP system and infrastructure.
DSR roadmap 2026–2034. One timeline; colour marks the track.
DSR core delegated act DPP system main application
The implication is unambiguous: although the Article 21(10) implementing act that fixes the DPP's fundamental technical requirements has not yet been adopted — and its application is set no earlier than 18 months after entry into force, with CEN-CENELEC JTC24 standardisation work as a precondition — there is more than enough fixed in the regulation to start now. Plan for 2029, and watch the consultation timeline in case the effective DPP date slips later.
The Digital Product Passport at the Core
The DSR's DPP shares its architecture with the regimes already taking shape under the Batteries Regulation, the Construction Products Regulation and the ESPR: a persistent data carrier on the product links — via a Unique Product Identifier — to a structured record hosted by the economic operator or a Digital Product Passport Service Provider (DPP-SP), and registered in the central EU DPP registry. What makes the detergent DPP concrete is the exact set of fields it must carry and the rules it must satisfy — gathered below into one cheat sheet.
The Path to a Compliant DPP
Article 8(2) sets out the core obligation in one sentence: before placing a product on the market, the manufacturer draws up the technical documentation and runs the conformity assessment, then creates the DPP, makes the data carrier available, and references the DPP in the central register. Operationally, that is three phases every product must pass through before 23 September 2029 — with one obligation running in parallel throughout.
The three-phase flow, chronologically — completed before the first making-available of each product from 23 September 2029 (Art 8(2) + Art 21(1) + Art 24(1)), with one obligation running in parallel throughout.
Technical documentation + conformity
- Compose the technical documentation (Annex IV 2.2)
- Complete the Module A self-declaration
Create the DPP & make it available online
- Create the DPP (Art 21) — 9 mandatory rubrics (Annex VI Part A)
- Place the data carrier (QR): physical + online + refill context (Art 21(4))
- Arrange the DPP-SP back-up (Art 21(12)(c))
Register upload
- Upload the UPI + UOI to the ESPR register (Art 24(1))
- The register returns a unique registration identifier (Art 24(2))
- For free circulation via customs: store the commodity code
The conformity assessment is "internal production control" — Module A (Annex IV). No notified body, no third-party certification: manufacturers compose the technical documentation and self-declare. The administrative simplicity is real, but the burden of getting the technical documentation right sits squarely with the manufacturer, and it cannot be delegated to an authorised representative (Art 9(5)).
What Stays the Same
Surfactant biodegradability thresholds are unchanged. The Annex I, Part A criteria — ≥60% mineralisation within 28 days, or ≥70% via DOC die-away — carry over from 648/2004 verbatim, using the same OECD test methods, so existing supplier certificates remain valid.
Phosphate limits are unchanged. Article 6 and Annex III retain the 648/2004 thresholds (0.5 g P per standard dose for consumer laundry detergents; 0.3 g P for consumer automatic dishwasher detergents). A Commission report due in 2028 may propose stricter limits, but the current numbers stand.
REACH, CLP and BPR continue to apply. Article 1(2) is explicit: the DSR is without prejudice to REACH, CLP and the BPR. DSR obligations stack on top of, not in place of, the existing chemicals regime — IUCLID remains the REACH channel, the ECHA Poison Centres (PCN) portal the route to national poison centres, and the SDS the downstream document.
Refill Stations, Distance Selling, Customs
Three operational features will reshape distribution. Refill sales get explicit encouragement as a waste-prevention measure (Art 12, Art 17(2)) — the physical label and data carrier must be handed over at each refill, with broader detail allowed in the digital-label layer. Distance selling is in scope (Art 20): every online listing — own shop or marketplace — must show the Article 17 label information and a copy of the data carrier or UPI before purchase, with the manufacturer responsible even where a marketplace controls the UI. And from 23 September 2029 customs verify the unique registration identifier against the central registry at the border via the EU Single Window (Art 25), so importers need the registry entry in place at import — not later.
What's Still Being Written
The DSR is a framework: a substantial amount of detail still sits in implementing and delegated acts the Commission has yet to adopt — things not yet on the timeline, but awaiting a date. Build schema-flexibly for that reason. The live monitoring list:
What Manufacturers Should Be Doing Now
Even with the implementing act pending, there is more than enough clarity to start. The lesson from the Batteries Regulation rollout is unambiguous: organisations that left preparation to the last twelve months ran into a scarcity of DPP service providers, price increases and waiting lists. Some pragmatic interventions manufacturers can already do:
Audit the portfolio against the new scope. Every fabric refresher, rinse aid, pre-treatment product, fragrance booster and fruit-and-vegetable wash that previously sat outside 648/2004 is now in scope — as is every variant of every laundry, dishwashing and surface detergent. Each needs its own DPP.
Map the supplier data flow. If your supplier chain cannot deliver the data the DPP needs — full constituent lists, carry-over preservatives, allergenic-fragrance declarations, biodegradability test reports — that is a blocker, not a paperwork detail (Art 8(7)). Start the supplier conversation in 2027 at the latest.
Pick a DPP architecture that survives. Build versus buy is genuinely two paths: full outsource to a DPP service provider, or self-hosted backend with a mandatory service-provider back-up. The ten-year availability requirement — surviving insolvency — makes the back-up non-negotiable. The hosting choice depends on whether the DPP is a compliance overhead or a brand touchpoint.
Design schema-flexibly. The DSR DPP is a minimum set in 2029; future delegated acts (Art 30(2)) and the anticipated ESPR extension (recital 47) will add fields. A modular, versioned schema costs little now and avoids a rebuild later.
The DSR is, in the legislator's own framing (recital 2), a simplification: one DPP replacing scattered information requirements across REACH, CLP, BPR and 648/2004. Whether it lands as simplification or overhead depends on implementation. Brands that treat the DPP as a brand channel rather than a compliance tax tend to come out ahead.
Frequently Asked Questions
When does the Digital Product Passport become mandatory for detergents?
From 23 September 2029, the main date of application of Regulation (EU) 2026/405. From that date every detergent and end-user surfactant placed on the EU market must have a DPP, a machine-readable data carrier, and a reference in the central EU registry. The animal-testing ban already applies from 22 March 2026, and biodegradability extensions follow in 2032 and 2034. The Article 21(10) implementing act that fixes the DPP's technical specifications is still pending and could move the effective DPP date later.
Which products are newly in scope compared to the old Detergents Regulation?
Regulation (EU) 2026/405 extends the definition of "detergent" to four categories that largely fell outside Regulation (EC) 648/2004: detergents with intentionally added micro-organisms; products that support cleaning when used with a laundry or dishwasher detergent (rinse aids, pre-treatment products, fragrance boosters); products that modify the feel or odour of fabrics (fabric refresheners); and products for fruit and vegetable surfaces. Stain removers, scent boosters and fruit-and-vegetable washes are now squarely in scope.
What must a detergent DPP actually contain?
At minimum, nine rubrics from Annex VI Part A: product identification (trade name, Unique Product Identifier, packaging image); manufacturer contact details plus the Unique Operator Identifier; the DPP service provider reference; a traceability identifier; a sole-responsibility statement; the HS/CN commodity codes; a declaration of compliance with cross-references; the list of intentionally added constituents (per CLP identification rules); and micro-organism taxonomy where present. It does not contain the full formulation, the production process, or the biodegradability test reports — those live in the technical documentation.
Can a manufacturer self-host the DPP, or is a service provider required?
Self-hosting is permitted (Art 22(e)), but only alongside a back-up hosted by a Digital Product Passport Service Provider (DPP-SP). The reason is Article 21(2)(g): the DPP must remain available for ten years from placing on the market — including if the manufacturer goes into insolvency, liquidation or termination. The DPP-SP back-up is therefore non-negotiable regardless of the hosting choice.
What stays the same under the new regulation?
The surfactant biodegradability thresholds (≥60% mineralisation in 28 days, or ≥70% via DOC die-away) carry over verbatim with the same OECD test methods, so existing supplier certificates remain valid. The phosphate limits are unchanged. And REACH, CLP and BPR continue to apply in full — the DSR stacks on top of the existing chemicals regime rather than replacing it.
Will the ESPR also cover detergents on top of the DSR?
Possibly. Recital 47 of the DSR explicitly anticipates that the Ecodesign for Sustainable Products Regulation (ESPR) could in the medium term bring detergents within its scope, adding ecodesign requirements on top of the DSR baseline. Both regimes share the same data-carrier and register architecture, so a schema-flexible DPP design today covers the ESPR extension scenario without a rebuild.
Working on DSR readiness for your detergent or surfactant portfolio? Reach out at info@regenstudio.world.