
Digital Product Passport for chemicals
The Digital Product Passport for chemicals applies first to detergents, from 23 September 2029. CLP allows digital labels; REACH already asks for the data.
Where Transpareo supports you
From 23 September 2029 every detergent needs a product passport before it is placed on the market. Transpareo is the DPP platform on which you create, maintain and publish passports for detergents and other chemicals. The cards point to the sections that hold the details. The passport checklist for detergents shows point by point what a detergent passport has to contain.
Every container needs an identifier that leads to its passport. Transpareo issues it with or without a GTIN and creates the QR code for it.
The sheet changes, and customers ask for the version that applied back then. In Transpareo every version hangs on the passport, and earlier versions stay retrievable.
Pictograms, signal word and H and P statements belong to every mixture. Transpareo keeps the classification as a field, publicly readable without a login.
Buyers and authorities ask for CAS, EC and registration numbers. In Transpareo you keep each component with its numbers, each in a field of its own.
You have to name candidate-list substances to your recipients. In Transpareo you maintain that value once, and the passport shows it to every recipient.
Almost every customer asks for the storage class, the waste code and the take-back route. Transpareo keeps them as fields and translates them into 40 languages.
Raw-material data often sits with your supplier. With Transpareo Upstream the supplier fills it in, and you review every value.
Anyone may read the hazard overview, only entitled parties the formulation. In Transpareo you set for every field who may see it.
From 2029 every detergent needs a passport that your company enters in the EU registry. Transpareo checks the passport first and prepares the details the entry needs.
What is coming for chemical manufacturers
The Digital Product Passport for chemicals starts with detergents. Few industries have kept product data for as long, and few can show as little of it in a passport. Transpareo is the DPP platform on which manufacturers publish that data as a passport today.
What already applies today
REACH has required a sixteen-section safety data sheet since 2007. The CLP Regulation has prescribed the classified label for a decade and a half. Since 5 January 2021 the supplier of an article notifies ECHA of candidate-list substances above 0.1 % by weight.
The data exists. It just lives in PDFs, in the languages someone once ordered. Earlier versions are often impossible to retrieve.
REACH itself will not change that soon. In April 2026 the Commission decided not to reopen the regulation. The revision would have brought digital safety data sheets and alignment with the product passport. That makes the structured data around the sheet count all the more.
The passport duty for detergents
The Detergents Regulation entered into force on 22 March 2026. It replaces the regulation of 2004 and requires a digital product passport. The manufacturer creates it before placing the product on the market. It enters the reference in the EU registry.
The first hard passport duty for the sector now has a date.
It applies from 23 September 2029. Three and a half years sound generous until you count the formulations. Every passport stays available for ten years, even after the manufacturer’s insolvency.
What is still moving
The 2024 CLP revision introduces a digital label. Since 1 July 2026 it may add to the physical label. Voluntary supplemental information may sit on the digital label alone. The digital label has to be reachable free of charge and without registration.
For the first time, chemical law describes a digital channel for readers.
A second tranche of the revision applies from 1 January 2027. An amendment of 2025 moved a further group to 1 January 2028, the label format among it. In June 2026 Parliament and Council also agreed on a simplification. It keeps the digital labelling and sets minimum font sizes. It has not been published yet.
Chemicals also fall within the Ecodesign Regulation as products. No chemical group is on the working plan 2025-2030, though. A passport duty from that direction comes in a later cycle at the earliest.
What this page covers
This page gathers everything on the digital product passport for chemicals in one place. It shows the timeline, the roles with their duties and the data a chemical passport carries. Then come the official sources and a sample spreadsheet to compare with your data. At the end are the questions chemical manufacturers ask us most often. A term underlined with dots opens the wording of the provision.
From the rules to the passport
Grey shows the rules that reach a mixture. Teal shows the data you already hold for them, for instance in the safety data sheet. Blue shows the Transpareo product passport with its reading tiers.
The three biggest hurdles in practice
- Separate the document from the data: a safety data sheet is a legal text and stays one. Everything around it has to become structured data, from identity to disposal. Otherwise you are back to maintaining twenty PDFs by hand. In Transpareo each of these details becomes a field of its own.
- The version that applied back then: the audit question is rarely “what does the sheet say now?”. Usually it is “what did it say when this batch shipped?”. Very few systems can answer that. In Transpareo every earlier version stays retrievable.
- Graded depth for B2B readers: buyers, laboratories, downstream users and authorities need different depths of the same product. A single public page is too little for the laboratory. For the formulation you keep confidential, it is too much. In Transpareo you set the visibility of every field.
More on this: Disclosure does not cost you the signature and 40 languages automatically.
Regulatory timeline for chemicals
The key dates of the rules that apply to chemicals or are still to come, in order. Dates that hang on acts not yet adopted are marked as such.
- 5 January 2021SCIP notification duty
Any supplier of an article with a candidate-list substance above 0.1 % by weight notifies the ECHA database SCIP. The duty sits in the Waste Framework Directive 2008/98/EC. That is why it is easy to overlook.
- 10 December 2024CLP revision enters into force
Regulation (EU) 2024/2865 amends the CLP Regulation and introduces the digital label. It has to be reachable free of charge, without registering, downloading or installing anything. A product passport behaves the same way.
- 22 March 2026Detergents Regulation enters into force
Regulation (EU) 2026/405 on detergents and surfactants replaces Regulation (EC) No 648/2004. It requires a digital product passport. Its duties apply only after a long transition.
- 27 April 2026No revision of REACH
The Commission tells Parliament’s environment committee that it will not reopen REACH for now. The revision would have brought digital safety data sheets and alignment with the product passport.
- 16 June 2026Agreement on a simpler CLP Regulation
Parliament and Council reach a political agreement simplifying the CLP, cosmetics and fertiliser rules. It keeps the digital labelling and sets minimum font sizes for labels. Formal adoption and publication are still outstanding.
- 1 July 2026First CLP provisions apply
The first tranche of the revision takes effect, the digital label among it. Voluntary supplemental information may now sit on a digital label only. The hazard information stays on the packaging.
- 20 July 2026EU DPP registry operational
The central registry for product passports goes live. Implementing Regulation (EU) 2026/1778 governs it, and a test environment is available. Every passport is registered there once the duty for its product group applies.
- 1 January 2027Second tranche of the CLP revision
A second group of the revision’s provisions takes effect. Check which of them touch your labels and notifications.
- 1 January 2028Postponed CLP provisions
Regulation (EU) 2025/2439 moved a group of the revision’s rules to this date. They include the label format and the advertising rules. Read them before you plan new packaging.
- 23 September 2029Digital product passport for detergents
The Detergents Regulation applies. Manufacturers create a passport for every detergent and end-user surfactant before placing it on the market. They enter the reference in the EU registry.
- Expected after 2029An Ecodesign act for chemicals
Chemicals fall within the Ecodesign Regulation as products. No chemical group is on the working plan 2025-2030, though. A passport duty from that direction therefore has no date yet.
Who is affected?
Duties for chemicals: what falls on each economic operator on the way to the market.
Compiles the safety data sheet, classifies and labels under CLP. For detergents it will create the passport before placing the product on the market. Only the manufacturer knows the full composition. So every duty lands here first.
Whoever brings a substance or mixture into the EU takes on the duties of registrant and supplier. These include registration, classification and labelling. The importer supplies the safety data sheet in an official language of each member state of supply. A third-country supplier’s sheet is only a starting point. With a supplier request in Transpareo, the supplier fills in its data directly.
Passes the safety data sheet on unchanged and keeps the label intact. Forwards new information up and down the chain. It maintains no data of its own, yet customers usually ask it for the current version. On 21 September 2027 the new Union Customs Code arrives. When a consumer buys online from outside the EU, the seller or the marketplace is then the importer. That depends on the arrangement between the two. This importer makes sure that a detergent, for instance, meets the product rules customs apply.
Uses the substance in its own process or product. It has to stay within the exposure scenarios attached to the sheet. It needs the data in a form its own systems can read. This is who a chemical passport is really written for.
What goes in the DPP for chemicals?
Data fields for chemicals: the key ones the relevant EU regulation requires.
The sheet has sixteen sections, with the exposure scenarios annexed where they exist. It comes in an official language of each member state of supply. Every change produces a new, dated version. A superseded sheet is a liability.
This covers hazard classes and categories, the signal word, the pictograms and the H and P statements. Since 1 July 2026 supplemental information may sit on a digital label only. The hazard information itself stays on the physical label.
This covers the CAS and EC numbers of the components, the REACH registration number and the identified uses. Any authorisation or restriction counts too. Your article number and pack size belong here as well, because that is how a buyer finds the product.
These are candidate-list substances above 0.1 % by weight in an article. The supplier names them to its recipients. It also notifies them to ECHA. The same value serves both duties and is often maintained twice.
A detergent passport names, among other things, the trade name, the identifier, the manufacturer and every substance intentionally added. For industrial and institutional cleaners the safety data sheet covers that list. The passport stays available for ten years, insolvency included.
This covers waste codes under the European list of waste, the storage class and incompatibilities. Add the transport classification and the take-back or collection route per country.
Downloads
The checklist for chemicals as a PDF to print and tick off, and the sample spreadsheet of the Transpareo import to compare with your own product data - all without an account.
The checklist for detergents and surfactants follows the regulation text: every data point is binding law.
Sample row for chemicals, filled in and with every column the import expects.
14 columns, sample values included
Transpareo for chemicals
Transpareo is the DPP software for manufacturers of chemicals and detergents. It separates the documents from the data. Identity, classification, uses, storage and disposal become fields you maintain once. You keep components with their CAS numbers. Each field has its own visibility.
The safety data sheet, the registration dossier and the exposure scenarios hang on the passport as documents, per language and per version. Your data comes in through the web interface, an Excel spreadsheet or the API. Suppliers fill in their details through a request. The sample spreadsheet above shows an alkaline industrial cleaner with every column.
Before publication Transpareo checks every passport. Every publication is a signed version at a permanent address. So the sheet that applied to a batch two years ago stays reachable too. Once a passport is registered in the EU registry, Transpareo Vault archives it for ten years. Whoever reads the passport checks the signature with the Transpareo Time Machine. The fields appear in 40 languages, and you check the translation. You can export at any time as JSON-LD, CSV, Excel spreadsheet or SQL.
Frequently asked questions about the DPP for chemicals
Is there a DPP duty for chemicals today?
For detergents and end-user surfactants, yes, with a long runway. The Detergents Regulation applies from 23 September 2029. From then on each of these products needs a passport before it is placed on the market. For chemicals in general there is no duty yet. They do fall within the Ecodesign Regulation. No chemical group is on the working plan 2025-2030, though. What applies today is REACH, CLP and the SCIP notification. Together they supply most of a passport’s content. In Transpareo you can create these passports today.
Does the digital label under CLP replace the printed one?
No. The label elements stay on the physical label, and a digital label may add to it. Only voluntary supplemental information may sit on a digital label alone. The digital label has to be reachable free of charge and without registering or installing anything. A product passport has the same shape. In June 2026 Parliament and Council agreed on a simpler CLP Regulation. The deal keeps the digital labelling and sets minimum font sizes. The text is not in the Official Journal yet.
Does this apply to importers too?
Yes, and more heavily than most expect. An importer of a substance or mixture steps into the role of registrant and supplier. It registers where the tonnage requires it. It supplies the safety data sheet in an official language of each member state of supply. Classification and labelling under CLP sit with it too. A sheet from a third-country manufacturer is source material that you check and adapt. With a supplier request in Transpareo, your supplier fills in its data, and you review every value.
We are B2B only. Who is the passport for?
Buyers, laboratories, downstream users and authorities. Such a passport needs little storytelling and a lot of precise identity, versions and access control. In Transpareo every data field has its own visibility. The product identity and the hazard overview can be public. Composition, exposure scenarios and registration data stay behind logged access. Only the customers and authorities you name can open them.
How do we keep sixteen sections in twenty languages current?
Separate the document from the data. The safety data sheet stays a document, attached per language and per version exactly as you issue it. It is a legal text, and nobody should machine-translate it. You maintain the structured data around it once. That covers identity, classification, uses, hazard overview, storage and disposal. Transpareo translates it into the 24 official EU languages and 16 more, and you check the result. More on this in 40 languages automatically.
A new version of the sheet appears every few months. Does that break the passport?
No, it is the normal case. Every update produces a new, dated version. In Transpareo every publication is a signed version, and earlier versions stay retrievable at the same address. A customer may need to show which sheet applied when a batch shipped in 2027. That customer can still reach it. This answers the audit question that catches most SDS management. What auditors usually ask for is the version that applied at the time.
Do I need a GTIN?
No. Formulated chemicals are usually sold by article number and pack size. No rule requires a retail barcode for them. Without a GTIN, Transpareo issues a unique identifier of its own, with your manufacturer part number alongside it. The QR code leads to the passport just the same. If you have a GTIN, Transpareo turns it into a GS1 Digital Link that other systems resolve too.
What is SCIP and does it still concern us?
SCIP is the ECHA database of articles containing candidate-list substances above 0.1 % by weight. The notification duty sits in the Waste Framework Directive and has applied since 5 January 2021. Because it lives in waste law, it is easy to miss. The value behind it is the same one you name to your recipients. A passport will show it as well.
Who sees the composition?
Only whoever you allow. In Transpareo every data field has its own visibility. A value is public without a login, or reserved for a tier that readers reach through logged access. Product identity, hazard pictograms and disposal information are usually public. The full formulation and the exposure scenarios stay protected, and the registration dossier goes to authorities alone. For detergents the list of intentionally added substances belongs in the passport. Who may read which data is for an implementing act to set, and that act is still pending. More in disclosure does not cost you the signature.
What does non-compliance cost?
Member states set the penalties. Inspections are routine in this sector. An outdated safety data sheet or a wrong classification turns up in an ordinary inspection. The costly part comes further down the chain. A customer whose own audit fails over your superseded sheet changes supplier. From 23 September 2029 a detergent without a passport may not be placed on the market.
Official documents
Legal sources for chemicals to read for yourself: what each document is and when you need it.
- Regulation (EC) No 1907/2006 (REACH)The registration, evaluation, authorisation and restriction framework. It governs the safety data sheet, which suppliers update without delay when new information arises, and the duty to tell recipients about candidate-list substances in articles. The source for most of the data on this page.
- Regulation (EC) No 1272/2008 (CLP)Classification, labelling and packaging. It sets what has to be on a label, from the pictograms to the precautionary statements. Read it alongside the 2024 revision.
- Regulation (EU) 2024/2865 revising CLPThe 2024 overhaul. It introduces the digital label. That is the first time EU chemical law describes a digital channel for readers, with the same freedoms a product passport needs.
- Regulation (EU) 2025/2439Moves a group of the revision’s dates to 1 January 2028, among them the label format and the advertising rules. Short, and worth reading before anyone orders new packaging artwork.
- Regulation (EU) 2026/405 on detergents and surfactantsReplaces Regulation (EC) No 648/2004 and requires a digital product passport for detergents and end-user surfactants. It puts the passport duty on the manufacturer, sets out its content and requires the registry entry.
- Directive 2008/98/EC (Waste Framework Directive)It is the legal basis of the SCIP notification for articles containing candidate-list substances, in force since 5 January 2021. Cited here because the duty is chemical in substance and lives in waste law.
- DPP page of the European CommissionThe official roadmap for the product passport with the state of the delegated acts and the registry. This is where a chemical product group shows up first once it enters a working plan.
Further reading on our blog
Transpareo signs each field of a product passport on its own, so a disclosed protected field keeps its proof. Its reader need not trust the platform.
How our automatic translation handles technical terms in product data. We show why that data needs different treatment from a novel.
Trust in a product passport rests on the signed record of the product itself. Transpareo Proofchain keeps it verifiable that way for ten years, longer than a platform usually lasts.
The EU register for Digital Product Passports became law on 16 July 2026. What it asks of you, and what we prepare for you.
Ready for your chemical passports?
Set up your passports for chemicals today. By the time the obligation takes effect, you have long been up and running.