Regulation (EU) 2026/405 introduces a dedicated Digital Product Passport for detergents and end-user surfactants. Its main requirements apply from 23 September 2029. That may sound distant, but it affects data, labels, evidence and import processes that cannot be reorganised shortly before the deadline.
What the detergent DPP must do
Before placing a detergent or end-user surfactant on the market, the manufacturer must create a Digital Product Passport for each model. The passport states that conformity with the Regulation has been demonstrated and contains at least the data set in Part A of Annex VI.
The DPP must be accurate, complete and up to date. It has to be available in the languages required by the Member State and accessible to consumers, market-surveillance and customs authorities, the Commission and other economic operators according to their access rights. By creating the passport, the manufacturer assumes responsibility for the declared compliance.
Minimum availability is ten years, including in cases of insolvency, liquidation or cessation of activity. Hosting therefore becomes a compliance function. A working link on the day of sale is not enough.
One data carrier for several obligations
The data carrier must be physically present on the label or packaging; accompanying documents may be used for unpackaged bulk transport. At refill stations, it has to be present at the station. It must be indelible, automatically processable and visible before purchase, including in distance sales.
Where other EU law also requires information through a data carrier, one data carrier should be used. Where another rule requires a DPP for the same product, a single combined passport should be created. This is a clear architectural signal for packaging, product and safety teams: several uncoordinated QR codes are not a sustainable target design.
The carrier may expose additional information, but mandatory content must remain clearly identifiable and separate. Marketing information must not obscure compliance data.
Model, batch or individual product
The detergent passport generally corresponds to a specific model. If other Union law requires a passport at batch or item level, the detergent DPP may adopt that finer granularity.
Granularity affects almost every technical decision:
- which identifier appears on packaging or the refill station,
- how formulation and supplier data are versioned,
- how precisely a recall can be targeted,
- how many Registry entries are created,
- which changes require a new passport rather than an update.
Companies should distinguish between model, formulation version, batch and sales unit in their product-data model now. One stock-keeping unit is rarely sufficient for complex ranges.
What is different at refill stations
Refill sales connect the product, container and point of sale. The data carrier at the station must correspond to the detergent actually dispensed. A static sign covering several changing formulations creates an identification risk.
In practice, a station needs:
- an unambiguous identifier for the product offered,
- a controlled change process for formulation or supply batch,
- an accessible DPP link before purchase,
- fallback information when digital content is temporarily unavailable,
- a record of which version was dispensed during each period.
Privacy: mandatory scans do not justify tracking
The Regulation limits the use of access data. Economic operators should not track, analyse or use usage information beyond what is strictly necessary to provide the DPP information online. Consumer personal data must not be stored in the passport without explicit consent.
Technically, that rules out hidden advertising profiles behind a mandatory scan. Server logs, analytics and consent flows should ensure that required product information remains free and accessible without unnecessary data collection.
Customs and imports
For goods from third countries, the reference to the DPP must be available to customs authorities. The Regulation provides for the unique registration identifier and relevant commodity code to be checked against Registry data. Manufacturers established outside the EU must also appoint an authorised representative.
Importers should therefore verify more than the presence of a QR code. They need structured evidence of the Registry entry, responsible economic operator, product model and commodity code. That check belongs in supplier approval.
A practical preparation path to 2029
- Separate product models, formulation versions and batches in the data model.
- Map every mandatory Annex VI field to its authoritative source system.
- Treat language and access rights as structured rules.
- Plan one persistent data carrier for packaging, refill and online sales.
- Contractually secure availability, backup and provider portability for at least ten years.
- Test Registry and customs processes with importers and representatives.
- Limit tracking on mandatory access paths to what is technically necessary.
The detergent DPP is not just a digital label with a few extra fields. It connects conformity, identity, multilingual content, refill processes, customs and long-term availability. Planning these components together makes it possible to build one durable data-carrier architecture instead of adding competing solutions to packaging and points of sale later.
