What You Should Start Checking Now (Before 2029 Sneaks Up)

By now you know three things about the new EU Detergents Regulation.

First, it exists.

Second, it changes some important things compared to the previous rules.

And third, there’s a good chance it affects your company if you manufacture, import, sell or distribute detergents in the EU.

So the natural question becomes:

What should we actually start checking now?

I know that the deadline may feel far away.

But experience from REACH, CLP and Poison Centre Notifications tells us the same story every time:

Companies that prepare early move calmly. They have more time on their hands and actually see this as an opportunity not threat.

In contract I can vouch that companies that wait usually move under pressure and make costly mistakes. When I say costly I don't think just money, but heard-earned reputation. How much is that worth to you?

The good news is that preparing does not mean launching a massive project tomorrow.

It simply means starting to review a few key things.

Let’s look at the most important ones I believe are essentail to your success. 

1. Do You Clearly Know Which Detergent Products You Place on the Market?

I know this sounds obvious.

But believe me that many companies discover that their internal overview is not as clear as they thought. It's always different when you move from thoughts to action.

So start with a simple question:

How many detergent products do we actually place on the EU market?

I'm sure you answered this right from the head. Now let's go one step further. Do you know for each product:

• the formulation
• the supplier or manufacturer
• the markets where it is sold
• the responsible entity in your company

Don't skip this step because this is the foundation for everything else. 

2. Is Your Product Composition Documentation Complete?

I'm sure that by now you already know that the regulation continues to rely on accurate information about product composition.

So it’s worth checking whether documentation is complete AND easy to access.

Ask yourself:

If authorities asked for ingredient information for one of your detergents tomorrow, could we provide it quickly?

Or would we need to contact suppliers and start collecting information again?

If the second answer sounds familiar, that’s a useful signal. 

3. Are Your Labels Consistent Across Products and Markets?

As you know, detergent labels contain several types of information, including:

• ingredient disclosures
• instructions for use
• safety information
• manufacturer details

Over time, companies sometimes update labels product by product. If these actions are not done organized and planned this might cause problems.

What do I mean by that?

Different versions of labels circulating across different markets.

The new regulation is a good opportunity to ask:

Are our detergent labels consistent and up to date across the entire portfolio? 

4. Do You Clearly Know Who Is Responsible in the Supply Chain?

The new framework places stronger emphasis on the role of the economic operator.

In practice that means responsibilities must be clear between:

• manufacturer
• importer
• brand owner
• distributor

A simple exercise is to review supply agreements and confirm:

Who is responsible for providing compliance documentation if authorities ask for it?

If the answer is vague, it’s worth clarifying. 

5. Where Is Your Product Compliance Information Stored?

This queston seem decivingly simple but I can tell you from experience that this is where many companies discover their biggest challenge.

Compliance information often exists but it is scattered across:

• spreadsheets
• supplier emails
• internal folders
• archived PDFs

The new regulation moves gradually toward structured and accessible product information.

So a useful question to ask is:

If we needed the full compliance information for one detergent, could we gather it quickly?

Or would we need to search across several systems? 

6. Are You Ready for More Digital Compliance?

Concepts such as Digital Product Passports and digital access to product information suggest something important.

Compliance information will increasingly need to be:

• structured
• accessible
• easy to share when required

That often requires better coordination between:

• regulatory teams
• product development
• IT
• marketing

Not necessarily immediately — but eventually. 

Action Point

Here's my recommendation. Pick one detergent product from your portfolio. Then run a quick internal check.

Ask your team three questions:

1. Where is the full compliance documentation stored?
2. Who maintains that information?
3. Could we provide it quickly if authorities asked?

If the answers are clear, the transition to the new regulation will likely be manageable. If they are not, this is the perfect moment to start improving the structure. No panic required. Just preparation.

In the next article we’ll step back and look at the bigger picture. Because the new Detergents Regulation does not exist in isolation. It connects closely with other important chemical regulations such as:

• CLP
• REACH
• Poison Centre Notifications (PCN)

And understanding those connections can make compliance much easier. If you find yourself short with time you can share your challenges with me at Luka.Rifelj@bens-consulting.eu.