Detergents
The Detergents Regulation covers the manufacturing, sale and use of detergents. The sections below will provide you with useful information, especially if you are manufacturing, selling or using detergents.
Cleaning products covered by this legislation
There are many cleaning products present on the market. Most are what we refer to as detergents. A detergent is a substance or a mixture containing soaps and/or surfactants (any organic substance/mixture) intended for washing and cleaning processes. Detergents can be in any form (liquid, powder, paste, bar, cake etc.) and sold for household, institutional or industrial purposes. Other products considered to be detergents are:
- Auxiliary washing preparations’ intended for soaking (pre-washing) rinsing or bleaching clothes, household linen, etc
- Laundry fabric softeners
- All purpose cleaners
- Other cleaning and washing mixtures for washing and cleaning processes
The Detergent Regulation applies to
Any natural or legal person responsible for placing a detergent or a surfactant for a detergent on the market. This includes the following:
- Manufacturers/Producers of detergents
- Importers of detergents
- Any person changing the characteristics of a detergent
- Any person changing the labelling or packaging of a detergent
- Packagers working on their own account (e.g. company A purchases a detergent in bulk from company B and re-packages the detergent with its “own” name on the box)
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Duties and obligations
If your role is any of those listed in the previous section, you have specific requirements under the Detergent Regulation, in order to protect the environment and human health. They are:
- Verify that all surfactants in a detergent are ultimately biodegradable unless an EU derogation is granted
- Ensure the correct classification and labelling of the detergent in line with CLP
- Ensure that additional specific labelling and packaging for detergents sold to the general public only is provided
- Make available on a website the ingredient data sheet for consumers, except for the information on weight percentages ranges, perfumes and essential oils, and colouring agents present
You are also required to have the following information available, if requested by medical personnel and/or a Competent Authority:
- An ingredient data sheet for medical purposes only, containing the name of the detergent and all ingredients (except impurities) in order of decreasing abundance by weight within specific ranges in the detergent (≥ 10%, ≥1% - > 10%, ≥0.1% - > 1%, > 0.1%). This should be available as soon as possible
- Information confirming the biodegradation of any surfactant or relevant EU derogation granted
- Confirmation of the ownership of the test data for ultimate degradation or agreement with the owner for its use
Labelling requirements
There are eighteen specific constituents listed in the Regulation, which must be stated if present at greater than 0.2% by weight; for example all surfactant types, phosphates and aliphatic hydrocarbons.
The Regulation lists 26 allergenic fragrances. If any of the listed allergenic fragrances are present at greater than 0.01% by weight (or at a replacement limit) they must be stated; for example Citral, d-Limonene, Oak moss and tree moss extract and Linalool. Enzymes, disinfectants, optical brighteners, perfumes and preservation agents must be stated, regardless of their concentration.
Only laundry detergents are required to state the following additional information: recommended quantities and/or dosage instructions for a standard machine load for soft, medium and hard water classes for one or two cycle washing processes; capacity of any measuring cup; number of standard washing machine loads of normally and lightly soiled fabrics that can be washed using medium water hardness.
For detergents intended to be solely used in the industrial and institutional sectors, the above mentioned labelling and packaging does not have to be fulfilled if the equivalent information is provided by means of a technical data sheet/safety data sheet or in a similar manner.
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Using and storing detergents
If you are only using and storing the detergent, i.e. you do not fulfil any of the roles listed under the heading "The Detergents Regulation applies to", your obligation is to use and store the product in accordance with the manufacturers’ instructions.
Users of detergents should read the label carefully prior to usage to alert them to the presence of any chemicals classified as irritants and /or allergenic fragrances. To prevent dermatitis, direct skin contact should be avoided. Use safe systems of work, protect the skin and regularly check the skin surfaces.
EU Derogation for surfactants
A person who places detergents containing surfactants on the market can be waived from the biodegradation requirements for surfactant for a period of time (10 years) provided a derogation for that use or uses has been granted. Annex V to the EU Regulation on Detergents outlines the list of surfactants for which a derogation has been granted. If a detergent contains surfactants for which the level of ultimate aerobic biodegradation is lower than that stipulated in Annex III to the Regulation, you may apply for a derogation to the Environmental Protection Agency (EPA).
Further consideration and information
Disinfectants: Detergents which contain surfactants which also have active biocidal activity and are used as disinfectants are exempt from the following:
- Primary and ultimate degradation testing;
- Preparation of a risk assessment and the requirement to use test and analytical methods in the detergent legislation (providing the substance with biocidal activity is stated in the Biocide Directive).
Nevertheless, please note that the labelling provisions (Annex VIIA) will still apply. Biocide registration is undertaken by Pesticide Control Services (PCS) of the Department of Agriculture Food and Forestry.
Cosmetics: Personnel hygiene products, for example shower gels, shampoos do not fall within the scope of the Detergent Regulation. They are regulated by Cosmetic Products Regulations (Department of Health and Children). This situation may change as the Irish Medicine Board (IMB) is undertaken a project concerning cosmetics.
Contact The Health and Safety Authority at detergents@hsa.ie