Regulation (EC) 648/2004: Key elements

Biodegradability

Tightens the biodegradability testing requirements for surfactants in detergents. It required ‘ultimate’ aerobic biodegradability for all surfactants used in detergents. The biodegradability control methods are outlined in Annex III of the Regulation. The biodegradability test is made on the raw materials, not extracts, and must be conducted in GLP- or EN ISO/IEC 17025 compliant laboratories.

 Specific labelling requirements

Stringent labelling requirements on detergent manufacturers / formulators. The responsibility and labelling of packaging for detergents are specified in Article 11 of the Regulation. The labelling requirements apply whether the surfactant or mixture (detergent) is classified as non-hazardous or otherwise.

 Provision of data

Mandates manufacturers of detergents to give more detailed information on datasheets that must be made available to medical personnel on request.

 Restriction on phosphates in domestic laundry and dishwasher detergents

 Places a ban on detergents for non-professional use restricting the total content of phosphorus in the recommended quantity/dose per wash with further restrictions in place from 1 January 2017.

 Compliance - what do I need to do?

There is no legal requirement to register detergent products in the EU. The manufacturer/importer must however, ensure that the actives (i.e. surfactants) meet the criteria laid down in Regulation 648/2004 and fulfil the information/data provision requirements. Thus, before placing on the market, the manufacturer must ensure that the correct hazard classification, labelling and packaging information is applied on the detergent. In addition, it should be noted that although the detergent regulation contains no specific requirements for toxicological risk or safety assessment of detergent products, there are other supplementary regulations and directives which may be applicable to the product; e.g. the Biocides Product Regulation (528/2012), REACH (1907/2006) and the General Product Safety Directive (GPSD 2001/95/EC). In particular, the latter directive requires that all products for general consumer use must be safe for the purpose for which it is intended.