Household Chemical Requirements for Export to the EU: A Complete Regulatory Guide

Why EU Regulations Are Not a Recommendation, But an Obligation

Ukrainian household chemical manufacturers and Private Label companies are increasingly considering the EU as a sales market. Prices in Euros (30–50 UAH per unit), a population of 450 million, and developed logistics make export economically attractive. But there is one barrier: European regulations. How to launch your own household chemical brand is covered in our step-by-step guide.

Unlike Ukraine, where standards are few and outdated, the EU has a complete control system. A product that does not meet the requirements will not enter retail chains, will be detained by customs, or will be subject to claims from the distributor. Reputational and financial losses from serial product returns can destroy a new business line.

Over the past 2 years, SVK has helped 12 Ukrainian manufacturers prepare their products for export to the EU. The most common problem is that manufacturers underestimate the volume of documentation: a 16-section SDS alone requires 2–3 weeks of preparation. This guide is a practical handbook for manufacturers who are seriously planning to export or are already working with European partners.

Regulation EC 648/2004: The Main Law for Detergents

EC 648/2004 is the framework directive for all detergents sold within the EU. It covers washing powders, liquid soaps, dishwashing liquids, cleaning agents, and disinfectants.

Surfactant Biodegradability as the Main Criterion

All surfactants in the composition must undergo biodegradation by at least 90% within 28 days according to the OECD 301 standard or equivalent. This applies to both anionic and cationic surfactants. The test is conducted by accredited laboratories, and the results must be included in the technical documentation for customs and the distributor.

Mandatory Information on the Packaging and Label

The packaging must indicate: surfactant concentration in % by mass, functional purpose (washing powder, dishwashing liquid, etc.), environmental safety information, and quality control markers. Each element is strictly defined by the regulation, with no variations.

Prohibited and Restricted Raw Materials

NTA (nitrilotriacetic acid) is completely prohibited. EDTA and similar chelators are allowed only within narrow limits and for specialized products. Phosphates are regulated separately (see the section below). Microplastics and microbeads are completely prohibited.

Phosphates: The Strictest Restriction

Phosphates such as hexametaphosphates and polyphosphates were the standard in detergents 20–30 years ago. They prevented hard water scale and provided an alkaline environment. However, studies revealed that phosphates contribute to the eutrophication of water bodies — excessive algae growth.

Directive 2015/73/EU introduced strict limitations:

• For washing powders: a maximum of 0.3 grams per standard dose (60 g of powder)
• For dishwashing liquids: a maximum of 0.05 g per gram of mass
• For other detergents: a maximum of 2% by mass

For Ukrainian manufacturers accustomed to formulas with 15–20% polyphosphates, this is a radical reformulation. In SVK's practice: when we reformulated a line for one of our Private Label clients to a phosphate-free base, it took 4 iterations and 3 months of testing before the effectiveness of the new formula matched the previous one. Alternatives include zeolites, silicates, organic chelators, and phosphate-free hydroxy-carbonate complexes. This makes some formulas more expensive, but it is a mandatory condition for export. Read more about eco-certifications and labeling in the article «Eco-Detergents: Labeling and Certifications».

CLP Regulation EC 1272/2008: Classification and Labeling

CLP (Classification, Labelling and Packaging) implements the GHS (Globally Harmonized System) in the EU. Even if the parent company exports to the US or Asia, European rules within the EU are mandatory. Read about the PFAS ban, which also affects industrial chemistry, in the article «PFAS Ban in the EU».

GHS Pictograms and Signal Words

Every detergent must feature pictograms (black symbols on a white background with a red border) indicating hazard classes: health (organ damage, allergic reactions), physical hazards (flammability), and environmental hazards (toxicity to aquatic organisms). Signal words are: Warning (less hazardous) or Danger (more hazardous).

H-Phrases and P-Phrases

H-phrases describe hazards ("H315: Causes skin irritation"). P-phrases describe precautionary measures ("P280: Wear protective gloves"). All phrases must be presented in the official language of the territory where the product is sold. For export to Poland, it must be Polish; for France, French.

Safety Data Sheet (SDS) as a Mandatory B2B Requirement

If you sell a product to a business (even a small store or laundry), a Safety Data Sheet is required — an extended 16-section version covering: composition, physical and chemical properties, potential hazards, first aid measures, handling and storage conditions, disposal, transportation, and contact information. The SDS must be compiled in the official language of the destination country and Ukrainian, at a minimum.

REACH Registration: Do You Need to Register?

REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) is the general system for all chemical substances in the EU that are manufactured or imported in quantities exceeding 1 ton per year within the EU.

The key point: if you manufacture a formulated product (a mixture of components), the formula itself does not require registration. However, each individual component in your formula must be registered by the European manufacturer of the source substance.

Example: your washing powder contains an anionic surfactant, TAED, an optical brightener, and 10 other components. TAED is produced by five companies worldwide, all of which are registered with ECHA (European Chemicals Agency). You buy TAED from a registered supplier — meaning you do not need registration.

Practical Checklist for Exporters

Common Reasons for Border Bans

1. Missing SDS — the product is not allowed into the distributor's warehouse

2. Phosphates above the limit — detained by customs

3. Unregistered surfactants — the product is classified as unregulated

4. Microplastics in the composition — automatic return

5. SDS in the wrong language — detained until corrected

6. Missing CLP pictograms — the product will fail the store's quality control

FAQ

What documents are required to export household chemicals to the EU?

The minimum package includes: a surfactant biodegradability test according to OECD 301, GHS classification under the CLP Regulation, a 16-section Safety Data Sheet (SDS) in the language of the importing country, verification of REACH registration for components, and labeling with GHS pictograms and H/P-phrases.

How much does it cost to prepare for export to the EU?

A surfactant biodegradability test costs 2-5 thousand EUR (4-8 weeks). SDS compilation costs 500-2 000 EUR. GHS classification costs 300-1 000 EUR. A complete formula reformulation to comply with EC 648/2004 (removing phosphates, replacing surfactants) costs an additional 3-10 thousand EUR, depending on complexity.

Why are products detained at the EU border?

The most common reasons are: missing SDS, phosphates above the limit (>0.3 g/dose for washing powders), surfactants not registered in REACH, microplastics in the composition, SDS in the wrong language, and missing GHS pictograms on the packaging.

Is REACH registration required for a formulated product?

No, the formulated product itself (a mixture of components) does not require registration. However, each individual component must be registered by its European manufacturer. Verify the availability of REACH registration with raw material suppliers before purchasing.

How SVK Helps Ukrainian Manufacturers with Export

SVK has been developing household chemical formulas for over 30 years. We understand that transitioning to European standards is a serious investment for a Ukrainian manufacturer.

Our Export Ready Formula service includes:

• Reformulating your formula to comply with EC 648/2004 (removing phosphates, replacing surfactants, ensuring biodegradability)
• Compiling the SDS in English, German, French, and Ukrainian
• Assistance with GHS classification and labeling
• Contacts of accredited laboratories for testing
• Raw material registration in the supply network

We also manufacture ready-made formulas that already meet all requirements, so you can launch a Private Label or white-label directly for export. Read about Private Label for retail chains in the article «Private Label for Retail Chains».

Contact us for a consultation: svk.ua/eksport

We will help you navigate the path from understanding the requirements to the first delivery to the EU — quickly and without costly mistakes.

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Read also:

• PFAS Ban in the EU: What It Means for Your Production
• Eco-Detergents: Labeling, Certifications, and Trends
• How to Create Your Own Household Chemical Brand
• Private Label for Retail Chains: Why Choose a Ukrainian Manufacturer