What Ingredient Information Must Be in a Detergent Digital Product Passport?

When does the Detergent DPP apply?

Regulation (EU) 2026/405 entered into force on 22 March 2026 and generally applies from 23 September 2029.¹

That date matters because the Regulation replaces the previous detergents regime and introduces the Digital Product Passport as part of the new product-information architecture.

There are transitional provisions for products already placed on the market under the previous rules. Those transitional provisions should not be read as changing the general 23 September 2029 application date for the new regime.

The key point for product-data teams is therefore straightforward:

The ingredient-related DPP requirements are adopted law now, but they generally apply from 23 September 2029.

This is different from an ESPR product group that is still waiting for its final delegated act. The detergent passport data model already exists in adopted sector legislation.

For the broader category position, see Detergent and Surfactant Digital Product Passport Requirements.

Which products are in scope for this ingredient question?

The DPP provisions apply to detergents and end-user surfactants within the scope of Regulation (EU) 2026/405.¹

For this article, the useful distinction is not simply consumer versus professional product. It is whether the product is a detergent or end-user surfactant covered by the Regulation, and whether any of the specific information exceptions or conditions apply.

That becomes particularly important for:

• industrial or institutional detergents
• surfactants
• detergents containing intentionally added microorganisms
• products with carry-over preservatives that trigger relevant labelling requirements.

The DPP is normally associated with a specific product model. It is therefore better to think in terms of a controlled formulation and model record than a loose category-wide ingredient list.

What ingredient information is actually required in the DPP?

Annex VI Part A sets out the mandatory passport information. The ingredient-specific requirements can be reduced to two core fields, with important conditions around each.¹

That table captures the main reason this topic deserves its own page. A broad statement such as "the detergent DPP contains ingredients" is directionally right but not precise enough for implementation.

Intentionally added substances: what does that mean for the passport?

The adopted DPP requirement is framed around substances intentionally added.

That wording matters.

It means the safest public interpretation is not "every chemical that can be detected in the finished product". The passport rule is tied to what has been intentionally introduced into the formulation, plus the specific carry-over preservative treatment described in Annex VI.

The Regulation also links substance identification to Article 18(3) of the CLP Regulation. In practical data terms, that means an ingredient record needs a controlled substance identity rather than only a supplier nickname or internal shorthand.

For a product-data team, a useful source record would normally be capable of retaining:

• the substance identity used for regulatory purposes
• the product model or formulation to which it belongs
• the source document that supports the substance record
• whether it is intentionally added
• whether a carry-over preservative rule applies
• whether the SDS exception applies to that product context
• the date and version of the evidence.

That is a data-governance recommendation, not an additional legal field list.

Does the DPP have to list every ingredient?

The Regulation uses the phrase full list of substances intentionally added. It is therefore reasonable to describe the passport as containing a comprehensive intentionally-added-substance list.

It is not safe to shorten that to "every ingredient" without qualification because that phrase can imply:

• every impurity
• every reaction product
• every trace contaminant
• every substance detectable by laboratory analysis
• every piece of composition information held elsewhere in technical documentation.

Those are not equivalent propositions.

Are concentration values required in the Detergent DPP?

Not as a mandatory Annex VI ingredient field.

This is an easy place to mix two legal information systems.

The Regulation's ingredients data sheet in Annex IV groups ingredients into percentage ranges, unless an exact concentration is given. That is part of the separate detergent technical/composition documentation architecture.¹

Annex VI, which defines the mandatory DPP dataset, requires the substance list but does not repeat those concentration ranges as a mandatory passport field.

So the safe distinction is:

DPP REQUIREMENT Full list of intentionally added substances, subject to the stated conditions and exception.

REQUIRED / AVAILABLE UNDER ANOTHER LEGAL INFORMATION SYSTEM Concentration ranges and other composition detail in the ingredients data sheet where that regime applies.

A business may choose to expose additional information through the data carrier, but Article 21 requires additional information to be clearly separated from the information required by the Regulation.¹

Microorganisms: when does the requirement apply?

Not every detergent needs microorganism information.

The passport field is triggered where microorganisms have been intentionally added. In that case Annex VI requires the DPP to identify all intentionally added microorganisms by:

• taxonomic genus
• taxonomic species
• strain name or identification code.¹

The wider Regulation contains much more detailed rules for detergents containing microorganisms, including technical and safety requirements. Those broader requirements should not all be copied into the DPP simply because they exist in the same Regulation.

For example, technical documentation and microorganism-specific provisions can deal with matters such as strain deposition, methods and microbiological performance evidence. The mandatory passport field itself is narrower.

This is another example of the core rule:

DPP information is one regulatory layer. It is not the complete technical file.

For product-data architecture, microorganism attributes should therefore be conditional rather than hard-coded as required for every detergent model.

The Safety Data Sheet exception

Annex VI creates a specific boundary for industrial or institutional detergents and surfactants.¹

The requirement to include the intentionally added substance list in point (h) does not apply to those products where equivalent information is provided by means of a Safety Data Sheet in accordance with Article 31 of REACH.

That does not mean the DPP "replaces the SDS".

It means the Regulation recognises that an equivalent information route can already exist for those products and avoids requiring the same substance list again in the DPP in that defined situation.

The operational distinction should be stored explicitly:

A robust system should therefore keep the passport field requirement separate from the supporting or alternative regulatory document.

The DPP is not the detergent's entire composition file

Several information layers can coexist under the Regulation.

DPP information

Annex VI Part A defines the mandatory Digital Product Passport dataset. For ingredient purposes, that includes the intentionally added substance list and conditional microorganism information.¹

Ingredients data sheet

Annex IV contains the ingredients data sheet and includes composition information such as percentage ranges and other details. This is not the same thing as the mandatory DPP dataset.¹

Safety Data Sheet

For products within the relevant REACH SDS route, the Safety Data Sheet is a separate legal information system. Annex VI itself recognises that route through the industrial/institutional detergent and surfactant exception.¹

Labelling information

The Regulation also has separate labelling rules. Some labelling information can be included digitally and Annex VI Part B allows certain labelling information to be included in the DPP. That should not be confused with the mandatory ingredient fields in Part A.¹

The practical lesson is not to merge all four layers into one giant "DPP ingredients" object.

Model-level context

Article 21 links the DPP to a specific model of detergent or end-user surfactant.¹

That matters for formulation data. If a business uses one commercial name across materially different formulations, it should not assume that one undifferentiated ingredient record will satisfy a model-linked passport architecture.

Where other Union law requires a DPP at batch or item level, Regulation (EU) 2026/405 allows alignment with that level. But the detergent regime itself demonstrates that a DPP does not have to be item-level by default.

For the cross-category principle, see Digital Product Passport Requirements by Product Category.

Is the ingredient information public?

Do not assume that every DPP field is automatically public to every actor.

Article 22 establishes free access to the DPP according to the actor's access rights and says consumers and other end users cannot be required to register or provide a password to access the DPP.¹

However, Article 21 also requires a Commission implementing act to allocate which actors have access to which data and to specify other technical details.¹

The safe current position is therefore:

• the access architecture is adopted and role-based
• consumers and end users have a no-registration/no-password access route
• the detailed actor-by-data allocation remains an implementation detail to be set under the Regulation.

Do not convert "the DPP can be accessed by consumers" into "every ingredient datum is necessarily public".

See Who Can See What in a Digital Product Passport for the wider access question.

What product-data teams should prepare

The adopted law is specific enough to support practical preparation without inventing extra DPP fields.

Prepare now

A stable model and formulation relationship Know which formulation belongs to which detergent or end-user surfactant model.

Controlled substance identities Do not rely on free-text ingredient descriptions if the regulatory identity can be controlled.

Intentional-addition status Be able to distinguish intentionally added substances from other forms of presence.

Carry-over preservative logic Capture the evidence that determines whether the preservative must be listed.

SDS route and applicability For industrial/institutional products and surfactants, record whether the Annex VI(h) exception is actually supported by an equivalent SDS.

Conditional microorganism data For products containing intentionally added microorganisms, keep genus, species and strain information structured and linked to the correct model.

Evidence provenance Retain the source, version, date and owner for the data that feeds the passport.

Keep separate

Keep percentage bands, broader technical evidence and SDS content available in the regulatory record without automatically publishing all of it as mandatory DPP data.

See Is Your Product Data Ready for a DPP? and Passport Evidence: How We Know, and What a Blank Means for the wider data-readiness and product-evidence questions.

Common misconceptions

"The Detergent DPP lists every chemical in the product"

Too broad. The adopted requirement is a full list of intentionally added substances, with specific treatment for carry-over preservatives and a defined SDS exception.

"The DPP must publish the concentration of every ingredient"

Not as a mandatory Annex VI field. Percentage ranges sit in the separate Annex IV ingredients data sheet.

"Every detergent must provide microorganism data"

No. The DPP microorganism field applies when microorganisms are intentionally added.

"The DPP replaces the Safety Data Sheet"

No. The SDS remains a separate legal information mechanism. The Regulation uses it as an alternative route for equivalent substance information in a defined industrial/institutional detergent and surfactant case.

"If information is required somewhere in the Regulation, it belongs in the DPP"

No. Annex VI defines the mandatory passport dataset. Other annexes and provisions contain technical documentation, labelling and safety requirements that remain separate unless the DPP rule incorporates them.

Direct questions

Does the Detergent DPP list every ingredient?

It requires a full list of substances intentionally added, subject to specific conditions and an SDS exception for defined industrial/institutional detergent and surfactant cases. That is more precise than saying "every ingredient".

What does "intentionally added substance" mean here?

For the DPP, it is the legal category used by Annex VI to define the substance list. It should not be expanded by assumption to every trace substance or impurity detectable in the finished product.

Are concentration values required in the DPP?

Not as mandatory Annex VI ingredient fields. The Regulation's separate ingredients data sheet contains percentage ranges.

Does the DPP replace the Safety Data Sheet?

No. The SDS is a separate legal information system. In a defined industrial/institutional detergent and surfactant case, an SDS providing equivalent information can remove the need to repeat the Annex VI(h) substance list in the DPP.

Does every detergent need microorganism information?

No. The passport must identify microorganisms when they are intentionally added.

Is all ingredient information public?

Do not assume so. The Regulation establishes free access according to access rights, while detailed actor-by-data allocation is to be specified through implementation rules.

When does the Detergent DPP apply?

Regulation (EU) 2026/405 generally applies from 23 September 2029.

What would change this page?

Re-check this resource if the Commission adopts the Detergent DPP implementing act under Article 21 that specifies detailed carrier, access and update arrangements, or if Annex VI or the relevant ingredient/microorganism provisions are amended.

This is a regulatory information resource, not personalised legal advice. Product scope and obligations should be checked against the law applying to the specific product and operator.

Sources and legal basis

Primary source

• Regulation (EU) 2026/405 on detergents and surfactants, especially Articles 21 to 25 and 37, Annex II, Annex IV, Annex V and Annex VI. Current DPP Registry implementation

  View official source

• Commission Implementing Regulation (EU) 2026/1778 on the Digital Product Passport Registry. Canonical context - Detergent and Surfactant Digital Product Passport Requirements - Digital Product Passport Requirements by Product Category - Who Can See What in a Digital Product Passport - Is Your Product Data Ready for a DPP? - Passport Evidence: How We Know, and What a Blank Means

  View official source

https://eur-lex.europa.eu/eli/reg_impl/2026/1778/oj

Canonical context

• Detergent and Surfactant Digital Product Passport Requirements
• Digital Product Passport Requirements by Product Category
• Who Can See What in a Digital Product Passport
• Is Your Product Data Ready for a DPP?
• Passport Evidence: How We Know, and What a Blank Means