This article reflects the regulatory framework available in October 2026 and will be updated when the European Commission adopts the technical implementing rules for detergent Digital Product Passports.
Detergents are among the first product categories for which the European Union has established a specific Digital Product Passport obligation.
The new Regulation (EU) 2026/405 on detergents and surfactants introduces updated requirements for products sold across the EU, covering areas including biodegradability, labelling, refill sales, microorganisms and digital product information.
From 23 September 2029, manufacturers will be required to create a Digital Product Passport before placing a detergent or an end-user surfactant on the EU market.
Unlike sectors where DPP requirements will be introduced through product-specific delegated acts under the ESPR, the obligation for detergents is already established directly within sector-specific legislation. The essential dataset and responsibilities are defined, while further technical details will be introduced through an implementing act.
The obligation covers:
• detergents placed on the EU market;
• surfactants intended to be made available directly to end-users.
The distinction is important. The Regulation does not impose the same DPP requirement on every surfactant supplied exclusively as an upstream industrial input. However, a surfactant made available directly to an end-user falls within the scope.
The obligation applies before the product is placed on the market. The manufacturer must create the passport and assume responsibility for the product’s compliance with the Regulation.
Where the manufacturer is established outside the European Union, the Regulation also establishes responsibilities for the importer or authorised representative. Distributors and online marketplaces will need access to the product identifier or a digital copy of the data carrier so that the passport can be made available before purchase.
The minimum dataset is already defined in Annex VI of Regulation (EU) 2026/405.
The Digital Product Passport must include:
• the product’s trade name and unique product identifier;
• a clear image of the packaging or label;
• the manufacturer’s contact information and unique operator identifier;
• where applicable, information about the importer or authorised representative;
• the DPP service provider hosting the passport’s backup copy;
• information enabling the detergent or surfactant to be traced;
• a statement that the passport has been issued under the manufacturer’s sole responsibility;
• applicable commodity codes;
• confirmation that compliance with the Regulation has been demonstrated;
• a complete list of intentionally added substances;
• the taxonomic classification of any intentionally added microorganisms.
The passport may also include the product’s labelling information and other data provided voluntarily by the economic operator.
For industrial and institutional detergents, and for surfactants accompanied by an equivalent safety data sheet under REACH, the complete list of substances does not have to be repeated in the DPP under the conditions established by the Regulation.
This means that preparing a detergent DPP will require companies to connect information that may currently sit across formulation records, compliance documentation, packaging files, product databases and supplier systems.
The detergent DPP must normally correspond to a specific product model.
It does not necessarily need to be created for every individual bottle or package. However, the Regulation allows the passport to be issued at batch or item level when another applicable piece of EU legislation requires that level of granularity.
Each passport must be connected to a persistent unique product identifier through a data carrier. The identifier provides the reference point linking the physical product with its digital information.
Companies will therefore need to establish how models are defined across formulations, sizes, packaging formats and markets, and determine when a product change requires a new identifier or passport.
The data carrier must be printed or otherwise physically present:
• on the product label or packaging;
• on accompanying documentation when the product is transported in bulk;
• at the refill station when the detergent or surfactant is sold through refill.
It must be indelible, readable by digital devices and visible before purchase. This requirement also applies to distance and online sales, where the offer must display a digital copy of the data carrier or the product’s unique identifier.
The data carrier must be accompanied by wording such as:
“Please scan for more comprehensive information on the product.”
Consumers and other end-users must be able to access the relevant DPP information free of charge and without creating an account or providing a password.
Where other EU legislation requires information to be provided through a data carrier, companies should use a single data carrier rather than adding separate codes for each regulatory framework. The same principle applies if another regulation also requires a DPP for the product.
The Regulation introduces both Digital Product Passports and digital labelling, but the two concepts perform different functions.
The Digital Product Passport connects the product with structured information on identification, traceability, compliance, economic operators and composition. It is mandatory for detergents and end-user surfactants within scope.
A digital label is a way of providing certain labelling information electronically. Where companies use one, it must remain accessible for ten years, work across commonly used browsers and operating systems, and provide searchable information in the relevant languages.
The same data carrier may provide access to both systems. Companies should therefore design the consumer interface so that mandatory DPP data, digital labelling information and any voluntary content remain clearly organised and distinguishable.
Although the obligation is introduced through the Detergents and Surfactants Regulation, its technical architecture is connected to the common European framework established under the Ecodesign for Sustainable Products Regulation.
Detergent passports will use common principles for:
• unique product and operator identifiers;
• data carriers;
• interoperability;
• access rights;
• data exchange;
• passport persistence;
• registration and customs controls.
Before placing a covered product on the market, the relevant economic operator will need to upload its unique product identifier and unique operator identifier to the EU DPP Registry. The Registry will then return a unique registration identifier.
The Registry does not replace the passport or store the complete product dataset. It records the identifiers needed to support discovery, regulatory controls and customs verification. More information is available in Renoon’s guide to the EU Digital Product Passport Registry.
The Regulation also requires detergent DPP data to be based on open standards and provided in interoperable, structured, searchable and transferable formats without vendor lock-in.
The technical implementing act will still define elements such as the permitted data carriers, their positioning, the standards to be used and the detailed access rights. However, companies already have enough information to begin preparing the underlying processes.
Priorities include:
Map which detergents and surfactants are placed on the EU market, which are supplied directly to end-users and which economic operator acts as manufacturer, importer or authorised representative.
Determine how products are differentiated across formulations, packaging sizes, markets and intended uses. Connect each model with a stable identifier that can be used across internal systems, packaging and the future DPP Registry.
Identify where the information required by Annex VI currently sits. This may include formulation management systems, safety documentation, packaging files, ERP or PIM systems and supplier records.
Assess whether the complete list of intentionally added substances and any microorganisms can be produced at product-model level and maintained as formulations change.
The data carrier must remain available across physical packaging, distance sales, bulk transport and refill stations. Companies should map how the same product identity will be published consistently across these touchpoints.
Assign responsibility for creating, reviewing and updating each field. The passport must remain accurate, complete and available for ten years, so the implementation cannot depend on a one-time data upload.
The chosen system should support open standards, Registry integration, backup copies, multilingual information, differentiated access rights and future regulatory updates.
The 2029 deadline does not only introduce a new consumer-facing QR code. It requires companies to connect product identification, formulation data, regulatory documentation, packaging and market-access processes within a maintainable digital structure.
The companies best positioned for implementation will be those that begin by organising the underlying data and responsibilities, before the remaining technical specifications become applicable.
Renoon supports detergent and surfactant companies in structuring product data, defining identifiers, connecting existing systems and preparing Digital Product Passports aligned with the new regulatory framework.
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