The EU Authorised Representative for Detergents: What Regulation (EU) 2026/405 Requires, and When
July 15, 2026 by Fiona Moir & Hayley Lewis
On 2 March 2026, the EU published Regulation (EU) 2026/405 on detergents and surfactants, the most significant overhaul of this framework in two decades. It replaces the long-standing Regulation (EC) 648/2004 and introduces Digital Product Passports (DPP), stricter biodegradability criteria, new labelling obligations, and a formalised authorised representative role. The Regulation entered into force on 22 March 2026 and will become mandatory starting on 23 September 2029. For companies placing detergents or surfactants on the EU market, one of the most consequential changes concerns who must hold legal responsibility for compliance within the Union. This article sets out the authorised representative requirement and the timeline that goes with it.
What the Regulation requires
The Regulation distinguishes between two routes to market, and the obligation to appoint an authorised representative differs between them.
The first is the general case. A manufacturer may, by written mandate, appoint an authorised representative to carry out specific compliance tasks on its behalf. The mandate is valid only once accepted in writing by the representative, and the Regulation sets out the defined list of tasks that can be delegated, as well as those that cannot. For manufacturers established in the EU, this appointment is optional, a way to streamline how compliance obligations are discharged. Importantly, appointing a representative never transfers responsibility for product compliance, which remains with the manufacturer at all times.
The second route is mandatory. Manufacturers established outside the EU that place detergents or surfactants on the Union market through distance sale, including online marketplaces, must appoint an EU-established authorised representative. In this scenario, there must always be an entity established in the Union responsible for liaising with market surveillance authorities, maintaining the DPP, and ensuring that compliance can be demonstrated. The Regulation sets out an enhanced list of additional tasks for these representatives, including making best efforts to verify the manufacturer's documentation and cooperating fully with enforcement bodies under the market surveillance framework, Regulation (EU) 2019/1020.
In short, EU manufacturers may appoint a representative; non-EU manufacturers selling at a distance into the EU must do so. The role is not a formality. It is the named, accountable point of contact that authorities will turn to, and it carries specific, written obligations around technical documentation, the digital product passport, and ten-year record retention.
The timeline
22 March 2026 marks the entry into force and the start of the forty-two-month transition countdown.
Before 23 September 2029, products already placed on the market under the old Regulation may continue to be sold.
23 September 2029 is the date of full mandatory enforcement. From this point, the old Regulation is repealed, and all new products entering the market must comply in full, including the DPP and the authorised representative requirement where applicable.
A short sell-through period then runs from 23 September 2029 to 23 September 2030, during which products manufactured under the old rules but not yet in the distribution chain may still be placed on the market.
While 2029 may feel distant, appointing and properly mandating a representative, restructuring technical files, and building the digital systems behind the product passport are substantial undertakings. Companies that wait risk a hard barrier to market access in 2029. The practical work of screening, contracting, and onboarding an authorised representative should begin well ahead of the deadline.
How Yordas Group can help
Yordas Group acts as your EU authorised representative for detergents and surfactants under Regulation (EU) 2026/405. With regulatory entities across the EU and a team of regulatory scientists who manage compliance obligations on behalf of manufacturers worldwide, we can hold the mandate, maintain your technical documentation and digital product passport, and serve as your accountable liaison with EU market surveillance authorities.
Whether you are an EU manufacturer looking to streamline how your obligations are met, or a non-EU manufacturer that now requires a representative to sell into the Union, we provide a single point of regulatory accountability backed by scientific expertise.
Talk to our team about appointing Yordas as your EU authorised representative, and put the right structure in place well ahead of the 2029 deadline.
FAQs
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Non-EU manufacturers placing detergents or surfactants on the EU market through distance sale, including online marketplaces, are required to appoint an EU-established authorised representative. EU-established manufacturers may appoint one voluntarily to help discharge their compliance obligations, but are not obliged to.
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The representative carries out the specific tasks set out in a written mandate. These typically include keeping the technical documentation and digital product passport available, cooperating with market surveillance authorities, and acting as the accountable EU point of contact. For non-EU manufacturers selling at a distance, the Regulation adds further tasks, including verifying the manufacturer's documentation.
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No. Responsibility for product compliance remains with the manufacturer at all times. The representative discharges defined tasks on the manufacturer's behalf but does not assume liability for the compliance of the product itself.
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Regulation (EU) 2026/405 entered into force on 22 March 2026 and became fully applicable on 23 September 2029. The requirement, where applicable, applies in full from that date, so appointments should be in place well in advance.
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Yes. A single representative can hold mandates covering a manufacturer's full range of detergents and surfactants placed on the EU market, provided the scope of each mandate is clearly defined and accepted in writing.
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The manufacturer must keep the technical documentation, digital product passport, and any digital label for ten years from the date the product is placed on the market.
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Contact the Yordas regulatory team to discuss your product range and route to market. We will agree on the scope of the written mandate and put the supporting compliance structure in place ahead of the 2029 deadline.
Fiona Moir | Managing Regulatory Consultant • Hazard Communication
I head up the Hazard Communication team where we cover all of our SDS, classification, labelling and packaging services. Part of this service comprises the compilation of Safety Data Sheets (SDS) in accordance with global regulations.
I wear multiple hats, from the delivery and ongoing development of service structure, operations and training (internal and external). I also work with multiple departments to help with the development of the Hazel SDS and classification tools (Internal use) and the Helix SDS Manager.
Hayley Lewis | Managing Consultant - Regulatory • Scientific Services
At Yordas, I am a Managing Regulatory Consultant specialising in Biocides and Product Services. I collaborate with clients to discuss their regulatory needs, propose strategies for compliance, and project manage the delivery and implementation of required applications and reviews, ensuring that the companies we work with remain globally compliant with marketing requirements.
This includes supporting clients in marketing cosmetic products, biocidal products, veterinary products, OSPAR products, and more. Our services range from scoping assessments to determine requirements, costs, and timelines—enabling clients to make informed decisions—through to the commissioning of required testing and the preparation and submission of approval applications worldwide.
Further reading
References
1. Deloitte and The Manufacturing Institute (2021), Creating Pathways for Tomorrow's Workforce Today: Beyond Reskilling in Manufacturing. themanufacturinginstitute.org
2. OECD (2025), OECD Employment Outlook 2025: Can We Get Through the Demographic Crunch? oecd.org
3. Cefic, Facts and Figures of the European Chemical Industry. cefic.org
4. Cefic, Landscape of the Industry: United Kingdom. cefic.org
5. Chemical Industries Association, People and Skills. cia.org.uk
6. IChemE (2026), Employment Survey 2025 results. icheme.org
