Detergent and Surfactant Digital Product Passport Requirements

What products are covered?

The Detergents and Surfactants Regulation applies broadly to detergents and surfactants placed on the Union market.¹

For the Digital Product Passport specifically, Article 21 uses a more precise scope: the manufacturer creates a DPP before placing a detergent or end-user surfactant on the market.¹

An end-user surfactant is a surfactant made available on the market to professional users or consumers.¹

That wording is safer than saying every surfactant anywhere in an upstream supply chain automatically receives the same passport obligation.

What is a detergent under the Regulation?

The Regulation's definition covers substances, mixtures, micro-organisms or combinations intended for functions including:

• cleaning fabrics, dishes or surfaces
• soaking, pre-washing, rinsing or bleaching
• modifying the feel or odour of fabrics in processes complementary to washing
• supporting the cleaning process when used with laundry or automatic dishwasher detergent.¹

The law also contains product-specific rules for areas such as detergents containing micro-organisms, refill and industrial/institutional use. Those provisions matter when deciding what information and exceptions apply.

A scope edge case matters for distributors and importers. Under Article 13(c), an importer or distributor is treated as a manufacturer where it makes a surfactant that was not intended for end users available to end users. That can move responsibility with the commercial route, not only with who originally produced the surfactant.

When does it apply?

So the 23 September 2029 date is not simply a technical-project target. It is the general application date in Article 37.¹

Transitional provisions

Article 36 preserves two routes:

• detergents and surfactants placed on the market before 23 September 2029 in compliance with Regulation (EC) No 648/2004 as applicable on 22 September 2029 may continue to be made available indefinitely
• products placed on the market after 22 September 2029 and before 23 September 2030 in compliance with the old Regulation may continue to be made available until 23 September 2030.¹

That does not remove the need to prepare the new DPP architecture. It prevents the transition from being reduced to a simplistic "all stock changes overnight" message.

What information does the detergent DPP contain?

Article 21 requires at least the information in Annex VI Part A. Part B is optional.¹

The ingredient rule needs a qualifier

Annex VI Part A(h) requires a full list of substances intentionally added in the detergent or surfactant, with specified carry-over preservatives also included where the legal conditions are met.¹

But point (h) does not apply to industrial and institutional detergents, or to surfactants, where equivalent information is provided through a safety data sheet under REACH Article 31, so not every detergent DPP publishes every ingredient in every circumstance (how the SDS exception works).¹

Micro-organism information

Where micro-organisms are intentionally added, Annex VI requires their taxonomic identification at genus, species and strain name or code.¹

That sits alongside separate substantive rules in Annex II for detergents containing micro-organisms. Those substantive safety/biodegradability requirements should not be collapsed into the passport data list.

Identifiers and the data carrier

Article 21 requires the DPP to be connected through a data carrier to a persistent unique product identifier.¹

Article 23 then links the data carrier, unique product identifier and unique operator identifiers to the standards applicable under ESPR.¹

The Regulation does not turn the words "unique product identifier" into a universal legal requirement to use a particular commercial identifier such as GTIN in every case.

The data carrier must, under Article 21:

• be printed or physically present on the label or packaging, or on accompanying documents if transported in bulk, in accordance with the future technical implementing act
• be indelible
• be positioned so it can be automatically processed
• be present on the refill station for products made available through refill
• be accompanied by wording such as "Please scan for more comprehensive information on the product"
• be visible before purchase, including where applicable in distance sales.¹

Unlike the Batteries Regulation, the Detergents Regulation does not itself lock the public explanation to "QR code = DPP". The Commission implementing act will determine one or more carriers and their presentation.

For the cross-category identity question, see Barcodes and Product Identifiers: What You Need.

Is the detergent DPP model, batch or item-level?

Article 21 says the passport corresponds to a specific model of detergent or end-user surfactant.¹

The Regulation defines a model through characteristics including the same manufacturer and trade name, the same content and manufacturing processes, relevant classification and a type number or other group identifier.¹

There is an interoperability exception. If other Union law requires the DPP for the same product to correspond to batch or item level, the detergent DPP may be issued at that level instead.¹

So the architecture is:

model-level by default, with batch/item alignment where another applicable Union DPP obligation requires it.

That is different from the Battery Passport's model + individual-lifecycle structure.

See Model, Batch or Item Level for a Textile Passport on granularity.

Who can see what?

Article 21 says the DPP must be accessible to:

• consumers or other end-users
• market surveillance authorities
• customs authorities
• the Commission
• other economic operators

in accordance with access rights to be laid down through the Article 21(10) implementing act.¹

So the law already identifies actor classes, but the detailed allocation of who sees exactly which passport data is an implementation dependency.

It would be wrong to copy the Battery Passport's Annex XIII field-by-field access structure into detergent passports. The categories have different law.

The future implementing act must address, among other matters:

• the data carrier or carriers
• carrier layout and positioning
• standards
• which actors have access to which DPP data
• which actors may create or update information.¹

As at 1 September 2026, the current verification did not identify an adopted Article 21(10) technical implementing act.

For the wider question, see Who Can See What in a Digital Product Passport.

Registry, storage and persistence

The passport is not simply a record stored in the EU DPP Registry.

Article 22 requires an interoperable, open-standards and machine-readable design, with data stored by the responsible economic operator or an authorised provider. It also sets persistence and access principles.¹

Article 24 requires relevant identifiers to be uploaded to the DPP Registry before the product is placed on the market. The same Registry architecture is established under ESPR.¹²

The Registry became operational on 20 July 2026.³

The distinction is:

• Registry: registration, identifiers and regulatory/customs integration
• DPP data layer: the fuller product information maintained by the responsible operator or service provider.

See EU DPP Registry: Where Passport Data Actually Lives.

The common Registry layer is no longer a future assumption. Commission Implementing Regulation (EU) 2026/1778 was published on 17 July 2026, entered into force on 6 August 2026 and expressly covers detergents and end-user surfactants under Regulation (EU) 2026/405. The Registry itself became operational on 20 July 2026.

That does not mean the detergent-specific technical layer is finished. Article 21(10) still has to settle the detailed carrier, access and update rules for detergent DPPs. Automated customs Single Window verification is also a separate later step: it begins on 23 September 2029 or when the interconnection is operational, whichever is later.

Article 21(10) also creates a useful implementation buffer. As a general rule, its implementing act must allow at least 18 months between entry into force and application, subject to the Regulation's stated exceptions. Businesses can prepare the adopted data model now without pretending the final carrier and permissions design is already known.

Required under other law or other parts of this Regulation

A detergent business already has obligations that are not synonymous with "DPP fields".

Examples include:

• biodegradability requirements
• requirements for detergents containing micro-organisms
• phosphate/phosphorus limits
• CLP classification/labelling where applicable
• REACH safety data sheets where applicable
• biocidal-products rules where applicable
• physical/digital labelling duties
• ingredient data sheets for appointed bodies in relevant cases.¹

Some of those information systems interact with the DPP. They do not all become public or mandatory passport data merely because they exist elsewhere.

The Annex VI Part A(h) SDS exception is a good example of why the legal boundary matters.

What businesses can prepare now

PREPARE

Identify which products are detergents and which surfactants are end-user surfactants. Do not build the DPP workflow around an overly broad "all surfactants" assumption.

Define the legal model. Keep model identity aligned to formulation/content, manufacturer, trade name, manufacturing process, relevant classification and group identifier.

Structure product and operator identity. Prepare UPI and UOI relationships without assuming one commercial coding system is universally mandated.

Map Annex VI Part A. Create governed data for trade name, model image, operator details, traceability, compliance references, commodity code where applicable, intentionally added substances and micro-organisms where applicable.

Build an evidence path for ingredient data. Know which source supports each intentionally added substance and whether the SDS exception applies.

Plan for refill and distance sales. The carrier has explicit visibility and refill-station requirements.

Separate passport data from adjacent regulatory records. Do not make every SDS or technical document a public DPP field.

WATCH

• the Article 21(10) DPP technical implementing act
• final carrier type, layout and positioning
• detailed access-right allocation
• technical standards and lifecycle-management rules adopted under the ESPR framework
• Registry and customs implementation
• any changes to the Annex VI dataset before application.

IMPLEMENTATION DETAIL STILL PENDING

The core model-level DPP obligation and Annex VI dataset are already adopted.

What remains materially pending is the technical implementing layer, especially carrier specifications, field access and who may create or update data.

What this regime shows about DPPs

The Detergents and Surfactants Regulation demonstrates an adopted model-level passport centred partly on ingredients/substances and compliance.

That contrasts with the Battery Passport's hybrid lifecycle architecture and the Toy DPP's safety/conformity model.

There is no single universal product-information template.

Open questions and implementation pending

As at 1 September 2026:

1. The Article 21(10) technical implementing act remains to be adopted.
2. The detailed actor-to-data access matrix is therefore not yet final.
3. One or more specific data carriers, their layout and positioning remain to be fixed through that act.
• Registry implementation arrangements are adopted and the Registry is operational. The detergent-specific Article 21(10) carrier, access and update rules remain pending, while customs Single Window verification follows its own 2029-or-later operational trigger.
4. Businesses must preserve the Annex VI Part A(h) SDS exception rather than treating all professional formulations identically.

Readiness activity is already visible in industry workshops and vendor demonstrations, but that is evidence of preparation, not proof that a current implementation already conforms to the final Article 21(10) technical specification.

Direct questions

When does the detergent DPP apply?

Regulation (EU) 2026/405 generally applies from 23 September 2029.¹

Does every surfactant need the same DPP?

The DPP obligation in Article 21 is for detergents and end-user surfactants. The Regulation defines an end-user surfactant as one made available to professional users or consumers.¹

Is the detergent DPP model-level?

Yes, by default. It corresponds to a specific model. It may follow batch or item level where another applicable Union DPP rule requires that level.¹

What ingredient information is included?

Annex VI Part A includes a full list of intentionally added substances and qualifying carry-over preservatives, subject to the specific SDS exception for industrial/institutional detergents and surfactants where equivalent information is provided under REACH.¹

Does the passport include micro-organisms?

Where micro-organisms are intentionally added, the mandatory dataset includes genus, species and strain name or code.¹

Is the carrier definitely a QR code?

The Regulation requires a machine-processable data carrier but leaves one or more carrier types and detailed presentation to the Article 21(10) implementing act. Do not universalise the Battery QR rule.¹

How we know

Material claims were checked against the adopted Regulation and current official DPP infrastructure material on 1 September 2026.

Primary and official sources

• Regulation (EU) 2026/405 on detergents and surfactants, especially Articles 2, 8, 21-24, 35-37 and Annex VI
  EU law
• Regulation (EU) 2024/1781 (ESPR), horizontal DPP system and Registry architecture
  EU law
• European Commission, DPP Registry now live, 20 July 2026
  European Commission
• European Commission, Digital Product Passport implementation overview:
  European Commission

https://single-market-economy.ec.europa.eu/single-market/digital-product-passport_en