IF YOU ARE A MANUFACTURER OF DETERGENTS OR SURFACTANTS, YOU ARE OBLIGED TO COMPLY WITH THE ABOVE REQUIREMENT

  • Draw up technical documentation (Annex IV of the Regulation).
  • Carry out the conformity assessment procedure referred to (Annex IV of the Regulation).
  • Establish a product passport.
  • Ensure that the data carrier is printed or otherwise placed on the label or packaging in a visible and legible manner in compliance.
  • CE marking.
  • Keep the technical documentation and passport for 10 years after placing on the market.
  • Ensure compliance with conformity procedures in case of mass production.
  • Where deemed appropriate, due to the performance or risks of the product, carry out sample testing, investigate and, if necessary, maintain a register of complaints, non-conforming products, withdraw the product from the market and inform distributors.
  • Ensure labelling.
  • If the product does not meet the criteria for classification as hazardous under the CLP Regulation, provide information to Member State authorities (in Article 45) as per Annex IV, point 2.2(e).
  • Provide the Member State authorities with the ingredient data sheet if prompted and/or if the detergent data changes.
  • To demonstrate the compliance of the detergent or surfactant with this Regulation, provide information and documentation on paper or electronically, upon request to the competent national authority, in the language of the national authority.

If the manufacturer is not established in the EU, the detergent or surfactant may only be placed on the EU market if the manufacturer designates an authorised representative by written mandate. 

The authorised representative shall provide a copy of the mandate to the competent authority on request. 

Powers of the authorised representative: 

– to verify that a product passport has been produced which meets the requirements of the Regulation. 

– to verify that technical documentation has been produced which meets the requirements of the Regulation. 

– to verify that the conformity assessment procedure has been carried out by the manufacturer in accordance with the requirements of the Regulation. 

– keep the product passport and the technical documentation for 10 years after placing on the market. 

! The authorised representative is not responsible for drawing up the technical documentation and it is not part of the authorised representative’s mandate!