Which EU rules apply to private label cleaning products?
Four acts. The Detergents Regulation (EC) No 648/2004 sets label and ingredient rules until Regulation (EU) 2026/405 applies on 23 September 2029. The Classification, Labelling and Packaging (CLP) Regulation sets hazard labels and poison-centre notification. A disinfecting claim brings in the Biocidal Products Regulation, and the General Product Safety Regulation (GPSR) covers the remaining risks.
Who is responsible for a private label cleaning product?
The brand on the label, under each act that applies. Ireland's Health and Safety Authority counts among those responsible "any person who changes the labelling or packaging of a detergent product including retailers and distributors who sell “own label” detergents". From 2029, Regulation (EU) 2026/405 makes the brand owner the manufacturer.
| Act | Who it makes responsible | Where it says so |
|---|---|---|
| Detergents Regulation (EC) No 648/2004 | Manufacturers, importers, anyone who changes the formulation, and anyone who changes the labelling or packaging, including own-label sellers | Health and Safety Authority (Ireland), information sheet |
| Detergents Regulation (EU) 2026/405, from 23 September 2029 | The manufacturer, including whoever has a detergent designed or manufactured and places it on the market under its name or trade mark; manufacturers outside the EU appoint an authorised representative | Articles 2 and 9(2) |
| CLP Regulation (EC) No 1272/2008 | The supplier: any manufacturer, importer, downstream user or distributor placing a substance or mixture on the market | Article 2 |
| Poison-centre notification | Importers and downstream users placing mixtures on the market | CLP Annex VIII, Part A |
| Biocidal Products Regulation (EU) No 528/2012 | The authorisation holder answers for the label of a biocidal product | Health and Safety Authority (Ireland), information sheet |
| GPSR (EU) 2023/988 | The manufacturer: whoever markets the product under its name or trademark, for risks the specific acts leave open | Articles 2(1) and 3(8) |
A brand that buys a finished cleaner and adds only its own label can hold several of these roles at once. The manufacturer guide compares them across product groups.
What must the label of a cleaning product say today?
Under Regulation (EC) No 648/2004, as Ireland's Health and Safety Authority summarises it, the label gives the "name, full address and telephone number of the party responsible for placing the product on the market", lists key ingredients by weight range, and points to a website with the full ingredient list. A hazardous product adds the CLP hazard label.
| Particular | Detail | Rule |
|---|---|---|
| Responsible party | Name, full address and telephone number of the party placing the product on the market | Detergents Regulation |
| Ingredient datasheet contact | An address, e-mail and telephone number from which the ingredient datasheet may be obtained | Detergents Regulation |
| Listed constituents above 0.2% | For example phosphates or aliphatic hydrocarbons, each with a weight percentage range | Detergents Regulation |
| Other named ingredients | Enzymes, disinfectants, perfumes, preservatives and optical brighteners; allergenic fragrances | Detergents Regulation |
| Ingredient list | The address of a website where the list of ingredients is published | Detergents Regulation |
| Laundry detergents | Dosage per standard machine load for soft, medium and hard water, and the number of loads | Detergents Regulation |
| Hazard label, where the product is classified | Name, address and telephone number of the EU supplier; hazard pictogram, signal word, hazard and precautionary statements | CLP Regulation |
| UFI, where the mixture is hazardous for health or physical effects | The unique formula identifier from the poison-centre notification | CLP Annex VIII |
Detergents for professional use only may meet the ingredient listing and website duties through a safety data sheet. Medical staff can ask for more: under Article 9(3) of Regulation (EC) No 648/2004, an ingredient datasheet is made available "without delay and free of charge, to any medical personnel".
What does your product decide before it goes on sale?
Its hazard classification and its claims. A mixture classified as hazardous for health or physical effects needs a poison-centre notification and a UFI on the label. A claim to disinfect or kill germs makes it a biocidal product, which needs authorisation. Each case below names what it costs you.
- Hazardous for health or physical effects: under CLP Annex VIII, "importers and downstream users placing mixtures on the market" submit information to the poison centres, and "the submitter shall print or affix the UFI on the label of a hazardous mixture". The cost: preparing the notification and printing the code.
- Hazardous only for the environment: outside the poison-centre scope, which covers health and physical hazards. The cost: no notification and no UFI, while the hazard label for its classification still applies.
- A disinfecting, antibacterial or sanitising claim: a biocidal product, which may not be sold without authorisation. The cost: the authorisation, and a label with the authorisation number and the names and concentration of the active substances.
- For professional use only: the ingredient listing and website duties may be met through a safety data sheet. The cost: a safety data sheet instead of a published ingredient list.
- A laundry detergent: dosage for soft, medium and hard water, and the number of loads, on the pack. The cost: three dosages worked out and printed instead of one.
- Sold from a refill station, if hazardous: allowed since 1 July 2026 only under the conditions of section 3.4 of CLP Annex II. The cost: meeting those conditions at every station.
Surfactants that "meet the criteria for ultimate aerobic biodegradation as laid down in Annex III" may be placed on the market without further limitation relating to biodegradability (Article 4(1) of Regulation (EC) No 648/2004, text as adopted in 2004).
The 2017 poison-centre text names importers and downstream users as the ones who submit. Whether a brand that only relabels a finished mixture submits as well is not settled in the text read for this page, so agree in writing who submits and under whose name.
Can a private label cleaner claim to disinfect or kill bacteria?
Only as an authorised biocidal product. Article 17(1) of the Biocidal Products Regulation (EU) No 528/2012 says: "Biocidal products shall not be made available on the market or used unless authorised in accordance with this Regulation." Ireland's Health and Safety Authority treats claims such as antibacterial, antimicrobial, antifungal, sanitising or disinfectant as signs of a biocide.
Such a product's label carries the authorisation number and the names and concentration of the active substances. In Sweden, the Swedish Chemicals Agency (Kemikalieinspektionen) requires advertising for biocidal products to carry the sentence "Use biocides safely. Always read the label and product information before use." It lists "natural", "environmentally friendly", "animal friendly", "non-harmful" and "non-toxic" among terms that are not allowed, and requires Swedish on labels for sale in Sweden.
What changes with the new Detergents Regulation (EU) 2026/405?
It replaces the 2004 Regulation on 23 September 2029. Regulation (EU) 2026/405 states: "Regulation (EC) No 648/2004 is repealed with effect from 23 September 2029." It was signed on 11 February 2026 and published on 2 March 2026 (European Parliament). Compliant products placed on the market before that date "may continue to be made available on the market indefinitely".
The brand that is the manufacturer gets a digital product passport: Article 8(2) requires it to "create a digital product passport in accordance with Article 21", kept with the technical documentation for 10 years. The label information may be given "on a physical label; or on a digital label and duplicated on a physical label" (Article 18(1)).
Annex V lists what the label will carry: a type or batch number; the UFI; the manufacturer's and importer's name and postal and electronic address and a telephone number, with a single point in the Union; weight ranges of under 5%, 5 to under 15%, 15 to under 30% and 30% or more for listed constituents above 0.2%; enzymes, micro-organisms, optical brighteners and perfumes; preservatives; and fragrance allergens above 0.01%.
Two biodegradability rules come later: water-soluble films and polymers within films by 23 March 2032, and other organic substances intentionally added at 10% or more by 23 March 2034. Manufacturers established outside the Union "shall appoint an authorised representative" (Article 9(2)).
When do the new CLP label rules apply?
In three steps. Digital labels and the rules for refill stations have applied since 1 July 2026, and the rewritten poison-centre annex applies from 1 January 2027. Regulation (EU) 2025/2439 moved the label format, including minimum font sizes, the relabelling deadlines, advertising and distance-sales offers, to 1 January 2028.
| Package volume | Minimum x-height |
|---|---|
| Up to 0.5 litres | 1.2 mm |
| Over 0.5 and up to 3 litres | 1.4 mm |
| Over 3 and up to 50 litres | 1.8 mm |
| Over 50 litres | 2.0 mm |
The text is "printed in black on a white background", and "the distance between two lines shall be at least 120 % of the font size". Inner packaging of 10 ml or less may use a smaller font if it stays legible. After a new hazard class, a more severe classification or new supplemental information, labels are updated within 6 months; other changes within 18 months.
An online offer for a hazardous product "shall clearly and visibly indicate the label elements referred to in Article 17" (Article 48a), also from 1 January 2028.
Which dates matter for cleaning products from 2025 to 2029?
Most fall between July 2026 and September 2029. CLP digital labels and refill stations started on 1 July 2026, the poison-centre annex rewrite applies from 1 January 2027, and the CLP format rules from 1 January 2028. The new Detergents Regulation applies on 23 September 2029, when the 2004 act is repealed.
| Date | What applies | Act |
|---|---|---|
| 13 December 2024 | The GPSR applies | Regulation (EU) 2023/988, Article 52 |
| 2 March 2026 | Regulation (EU) 2026/405 published; it enters into force on the twentieth day after | European Parliament, Legislative Train |
| 1 July 2026 (passed) | CLP digital labels and the refill-station rule apply | Regulation (EU) 2024/2865 as amended by Regulation (EU) 2025/2439 |
| 9 December 2026 | The new Product Liability Directive applies to products placed on the market after this date | Directive (EU) 2024/2853, Article 2 |
| End of 2026 (expected) | Revised EU Ecolabel criteria for detergents and cleaning products expected to be adopted | EU Green Forum, 15 April 2026 |
| 1 January 2027 | Rewritten CLP poison-centre annex (Annex VIII) applies | Regulation (EU) 2025/2439 |
| 1 January 2028 | CLP label format and minimum font size, relabelling deadlines, advertising and distance-sales offers | Regulation (EU) 2025/2439 |
| 31 March 2028 | Nordic Swan criteria for laundry detergents and stain removers (006) prolonged to this date | Nordic Ecolabelling |
| 23 September 2029 | Regulation (EU) 2026/405 applies; Regulation (EC) No 648/2004 is repealed | Regulation (EU) 2026/405, Articles 35 to 37 |
Later dates are already set: water-soluble films by 23 March 2032 and other organic substances at 10% or more by 23 March 2034 under the new Detergents Regulation, and the Nordic Swan criteria for cleaning products, version 7.0, until 31 March 2031.
Do I need an ecolabel, and which cleaning product manufacturers name one?
No law on this page requires one. The Nordic Swan Ecolabel criteria for cleaning products, version 7.0, were adopted on 11 March 2026, and "the criteria are valid until 31 March 2031". The EU Ecolabel criteria for detergents and cleaning products are "currently being revised", with adoption expected at the end of 2026 (EU Green Forum).
7 of the 39 household and cleaning manufacturers NordSourced lists name the EU Ecolabel or the Nordic Swan Ecolabel on their website (data of 2026-10-14). Ask which products the licence covers and whether yours would be one of them; the certificates guide explains how to look a licence up.
| Manufacturer | Country | Certificates and labels named on its website | Valid document opened by NordSourced |
|---|---|---|---|
| Estko Nordic | Finland | ISO 9001, ISO 14001, EU Ecolabel, Nordic Swan Ecolabel (Svanen) | Not opened |
| Kvadro | Latvia | ISO 9001, ISO 14001, EU Ecolabel | Not opened |
| SEAL (Spodriba) | Latvia | EU Ecolabel | Not opened |
| Blue & Green | Sweden | ISO 9001, ISO 14001, Nordic Swan Ecolabel (Svanen) | Not opened |
| Cifab Trading | Sweden | Nordic Swan Ecolabel (Svanen) | Not opened |
| Kempartner | Sweden | ISO 14001, ISO 9001, Bra Miljöval (Falken), Nordic Swan Ecolabel (Svanen) | Not opened |
| Nopa Nordic | Sweden | Nordic Swan Ecolabel (Svanen), FSC | Not opened |
None of the 39 household and cleaning manufacturers NordSourced lists says, in the sentences quoted from its website, that it prepares safety data sheets, does the regulatory work or applies for ecolabels for clients (data of 2026-10-14). Ask before you order. The regulatory support page shows who says so in other product groups.
Questions and answers
Do I need to notify anyone before selling a cleaning product in the EU?
It depends on the product. A mixture classified as hazardous for health or physical effects is notified to the poison centres and carries a UFI on its label (CLP Annex VIII). A product with a biocidal claim needs authorisation under Article 17 of the Biocidal Products Regulation. A product that is neither still needs a compliant detergent label.
Who is legally responsible for a private label detergent?
The brand on the pack, in each act's words. Ireland's Health and Safety Authority counts anyone who changes the labelling or packaging, including retailers and distributors selling own-label detergents, as responsible under Regulation (EC) No 648/2004. From 23 September 2029, Regulation (EU) 2026/405 makes whoever places a detergent on the market under its name or trade mark its manufacturer.
Which ingredients have to be listed on a detergent pack?
Listed constituents present above 0.2% with a weight percentage range, such as phosphates; enzymes, disinfectants, perfumes, preservatives and optical brighteners by name; and allergenic fragrances. The label also gives a website with the full ingredient list and a contact for the ingredient datasheet, as the Irish Health and Safety Authority sums up Regulation (EC) No 648/2004.
Can I call my cleaner antibacterial?
Only if it is authorised as a biocidal product. Article 17(1) of Regulation (EU) No 528/2012 says biocidal products shall not be made available on the market unless authorised, and Ireland's Health and Safety Authority treats antibacterial, antimicrobial, antifungal, sanitising and disinfectant claims as signs of a biocide. The label then carries the authorisation number and the active substances.
Can a biocidal cleaner be advertised as eco-friendly or non-toxic?
Not as Sweden's Chemicals Agency applies the rules. It lists "natural", "environmentally friendly", "animal friendly", "non-harmful" and "non-toxic" among terms not allowed for biocidal products, and requires advertising to carry the sentence "Use biocides safely. Always read the label and product information before use." Its page, published on 22 September 2026, also requires Swedish on labels for sale in Sweden.
Which language must a cleaning product label be in?
The acts read for this page settle it piece by piece. The GPSR asks for instructions and safety information in a language consumers understand, as the Member State where the product is sold decides (Article 9(7)). Sweden's Chemicals Agency requires Swedish on biocidal products sold in Sweden. Check each country of sale before printing a shared label.
What is a UFI, and does my cleaner need one?
UFI stands for unique formula identifier. Under CLP Annex VIII, the submitter prints or affixes it on the label of a hazardous mixture, meaning one classified as hazardous for health or physical effects. A cleaner classified only for environmental hazards falls outside that scope.
When does the new Detergents Regulation apply, and what does it add?
Regulation (EU) 2026/405 applies from 23 September 2029, when Regulation (EC) No 648/2004 is repealed; compliant products placed on the market before then may stay on sale indefinitely. It adds a digital product passport kept for 10 years, a UFI and a single EU contact point on the label, and the option of a digital label duplicated on a physical one.
What changes for cleaning products in 2026 and 2027?
CLP digital labels and the refill-station rule have applied since 1 July 2026. The Product Liability Directive applies to products placed on the market after 9 December 2026, and revised EU Ecolabel criteria for detergents are expected at the end of 2026. The rewritten poison-centre annex of CLP applies from 1 January 2027.
When do the new CLP font size rules apply?
From 1 January 2028, after Regulation (EU) 2025/2439 postponed them. The minimum x-height is 1.2 mm for packages up to 0.5 litres, 1.4 mm up to 3 litres, 1.8 mm up to 50 litres and 2.0 mm above that, printed in black on a white background with line spacing of at least 120% of the font size.
Can I sell a hazardous cleaner from a refill station?
Yes, since 1 July 2026, but only on conditions. The amended CLP Regulation allows hazardous substances or mixtures to be supplied to consumers and professional users via refill stations only if the conditions laid down in section 3.4 of Annex II are fulfilled. Plan the station's labelling and information against that section before you start.
Is the EU Ecolabel or the Nordic Swan required to sell cleaning products?
No law read for this page requires either. The Nordic Swan criteria for cleaning products, version 7.0, adopted on 11 March 2026, are valid until 31 March 2031, and those for laundry detergents and stain removers were prolonged to 31 March 2028. The EU Ecolabel criteria for detergents are being revised, with adoption expected at the end of 2026.
Which cleaning product manufacturers in the Nordics and the Baltics name the Nordic Swan or the EU Ecolabel?
7 of the 39 household and cleaning manufacturers NordSourced lists name one of the two on their website (data of 2026-10-14): Estko Nordic, Kvadro, SEAL (Spodriba), Blue & Green, Cifab Trading, Kempartner and Nopa Nordic. A licence covers named products, so ask whether your formula would be licensed and who pays for the application.
Does the manufacturer prepare the safety data sheet and poison-centre notification for me?
Ask, because none of the 39 household and cleaning manufacturers NordSourced lists says so in the sentences quoted from its website (data of 2026-10-14). The law names importers and downstream users as poison-centre submitters, so write down who submits, under whose name, and who updates the documents when the formula changes.
Where to go next
Sources
- Regulation (EC) No 648/2004 on detergents, Articles 4 and 9 (text as adopted), EUR-Lex; text read in the Publications Office (Cellar) copy of the Official Journal. Checked 13 Oct 2026.
- Labelling and packaging requirements for detergents and biocidal detergent products (information sheet, September 2018), Health and Safety Authority (Ireland). Checked 13 Oct 2026.
- Regulation (EU) 2026/405 on detergents and surfactants, Articles 2, 4, 8, 9, 18, 35 to 37 and Annex V, EUR-Lex; text read in the Publications Office (Cellar) copy of the Official Journal. Checked 13 Oct 2026.
- Revision of the Detergents Regulation (Legislative Train), European Parliament. Checked 13 Oct 2026.
- Regulation (EC) No 1272/2008 on classification, labelling and packaging (CLP), Article 2 (text as adopted), EUR-Lex; the as-adopted text was read on legislation.gov.uk (The National Archives). Checked 13 Oct 2026.
- Regulation (EU) 2024/2865 amending CLP: Articles 30, 31, 35 and 48a, Annex I section 1.2.1, EUR-Lex; text read in the Publications Office (Cellar) copy of the Official Journal. Checked 13 Oct 2026.
- Regulation (EU) 2025/2439 amending Regulation (EU) 2024/2865 as regards dates of application, EUR-Lex; text read in the Publications Office (Cellar) copy of the Official Journal. Checked 13 Oct 2026.
- Commission Delegated Regulation (EU) 2017/542, CLP Annex VIII on poison centres (original text), EUR-Lex; text read in the Publications Office (Cellar) copy of the Official Journal. Checked 13 Oct 2026.
- Regulation (EU) No 528/2012 on biocidal products, Article 17 (text as adopted), EUR-Lex; the as-adopted text was read on legislation.gov.uk (The National Archives). Checked 13 Oct 2026.
- Labelling of biocidal products (published 22 September 2026), Swedish Chemicals Agency (Kemikalieinspektionen). Checked 13 Oct 2026.
- Regulation (EU) 2023/988 on general product safety (GPSR), Articles 2, 3, 9 and 52, EUR-Lex; text read in the Publications Office (Cellar) copy of the Official Journal. Checked 13 Oct 2026.
- Directive (EU) 2024/2853 on liability for defective products, Article 2, EUR-Lex; text read in the Publications Office (Cellar) copy of the Official Journal. Checked 13 Oct 2026.
- Nordic Swan Ecolabel criteria: cleaning products (026), Nordic Ecolabelling. Checked 13 Oct 2026.
- Nordic Swan Ecolabel criteria: laundry detergents and stain removers (006), Nordic Ecolabelling. Checked 13 Oct 2026.
- EU Ecolabel surges ahead in 2026 (15 April 2026), EU Green Forum (European Commission). Checked 13 Oct 2026.
Directory figures are counted from the manufacturers listed on NordSourced, each listed because its own website says it makes products for other brands; see how we check. This page is general information, not legal advice. Found a mistake? Tell us.