In the previous articles I shared with you what the new EU Detergents Regulation is about and what has actually changed compared to the previous rules.
Now comes the question most people quietly ask themselves:
“Does this actually apply to us?”
In many cases the answer is simple. If your company places detergents on the EU market in any way, the regulation probably concerns you. What changes is not whether it applies but how it applies depending on your role in the supply chain.
Let’s look at the most common situations.
If You Manufacture Detergents
If your company manufactures detergents and sells them in the EU, you carry the primary responsibility. This means the product must comply with the regulation before it is placed on the market.
In practice this usually means ensuring that:
- surfactants meet biodegradability requirements;
- product composition documentation exists and is maintained;
- ingredient and safety information is accessible;
- compliance documentation can be provided when requested.
Under the new regulation there is also a stronger expectation that product information exists in a structured and accessible digital form.
If You Import Detergents into the EU
I can tell you from my own experiences that importers often underestimate their responsibility. Legally, the importer becomes responsible for ensuring that the detergent entering the EU market complies with EU rules.
That means importers should verify things such as:
- whether the product meets EU detergent requirements
- whether proper documentation exists
- whether labels and product information follow EU rules
- whether a responsible economic operator is clearly identified
Let's look at one practical case to make it clearer: Imagine you're a detergent manufacturer outside the EU and selling your detergent in Europe under your brand name.
If something is wrong with this product, authorities will often first contact the importer established in the EU. That importer must then be able to demonstrate compliance.
If You Sell Detergents Under Your Own Brand (Private Label)
Another very common situation I can think off for this case. Let's consider a company ordering detergents from a manufacturer and selling them under its own brand name.
Even though the company did not manufacture the product, the brand owner often becomes responsible for ensuring the product complies with EU requirements.
Private label companies should therefore be confident that:
- the formulation complies with EU requirements.
- compliance documentation exists and can be obtained
- product information is accurate.
- responsibilities between brand owner and manufacturer are clearly defined.
One useful exercise I suggest is to review the agreement with the manufacturer and ask a simple question: »Who is responsible for what if authorities ask for compliance information?«
Many companies discover that this was never clearly defined.
If You Sell Detergents Online
Online sales are receiving increasing attention from regulators.
Why?
Because non-compliant products sometimes enter the EU market through online platforms. Authorities therefore want to clearly identify the responsible economic operator established in the EU. If detergents are sold online — particularly from outside the EU — regulators will want to know: »Who is legally responsible for that product on the EU market?«
If that answer is unclear, the product can quickly become a compliance problem.
If You Distribute Detergents
Distributors may not manufacture or import the products, but they still play an important role.
They are expected to ensure that the products they supply appear compliant.
For example, distributors should check that:
- labels are present and readable
- required product information accompanies the product
- obvious compliance issues are not ignored
If something appears wrong, distributors cannot simply ignore it.
So Who Should Be Paying Attention?
In simple terms, the regulation concerns most companies involved in the detergent supply chain:
- manufacturers
- importers
- private label brands
- distributors
- online sellers
If your company places detergents on the EU market in any of these roles, it is worth understanding the responsibilities connected to that role.
Action Point
My honest suggestion is you should have a short internal discussion this week based on a role you have when it comes to this new EU Detergetns regulation. Just ask two simple questions:
1. Which role do we play under the new Detergents Regulation?
Manufacturer?
Importer?
Brand owner?
Distributor?
2. Do we clearly understand the responsibilities that come with that role?
Many companies discover that answering those two questions already reveals where further review may be needed.
In the next article we will look at something even more practical: a simple checklist companies can use to review their readiness before the new rules apply in 2029.
However, if you find yourself short with time you can share your challenges with me at Luka.Rifelj@bens-consulting.eu.
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