Notification of Detergents and Cleaning Agents according to the national Detergents and Cleaning Agents Act

  1. Distinction from Other Legal Provisions
  2. Transitional Provisions
  3. Notification of Detergent and Cleaning Agents NOT Classified as Hazardous

Detergents and cleaning agents (WRM) are in general subject to notification in Germany. There is a requirement to transmit data for medical purposes to the BfR according to §10 of the national Detergents and Cleaning Agents Act and Article 9 of the European Regulation on Detergents (EC) No. 648/2004, if no notification requirement arises from one of the legal provisions described in the following paragraphs. This information is forwarded to the poisons centres within the German federal states to support their mission of providing advice and treatment recommendations in cases of suspected poisoning or exposure to relevant products.

Product notifications for detergents and cleaning agents are free of charge.

In addition, the BfR is legally required to provide product trade names as well as related manufacturer’s/formulator’s information to the German Environment Agency (UBA). The UBA is the contact point for the monitoring authorities of the German federal states in detergent and cleaning regulatory affairs.

Links to the applicable legislation:

Distinction from Other Legal Provisions

The Regulation (EC) No 1272/2008 on Classification, Labelling and Packaging of Substances and Mixtures (CLP) Art. 45 and Annex VIII stipulate a notification requirement on product mixtures classified as hazardous. For detergent and cleaning product mixtures falling within the scope of this provision, no notification requirements apply according to the national Detergents and Cleaning Agents Act. That means no additional notification is required according to this legal provision.

Note: Please provide a corresponding EuPCS code unambiguously marking these products as detergents or cleaning agents.

Products within the scope of notification requirements for cosmetic products (Regulation (EC) No 1223/2009 on cosmetic products) are also exempt from product notification according to the Detergents and Cleaning Agents Act. Please register those products via the Cosmetic Products Notification Portal (CPNP). Further information on this issue is available from the Federal Office of Consumer Protection and Food Safety (BVL).

Transitional Provisions

According to Annex VIII of the CLP Regulation, transitional provisions apply to the notification of products classified as hazardous, which also includes appropriately classified detergents and cleaning products. Further explanation is available on the website Notification of Hazardous Products.

Please note:

  1. The national transitional provision according to § 28 (12) Chemicals Act is still in place for detergent and cleaning agents for industrial use (at industrial sites only), which are classified as hazardous until 31 December 2023.
  2. For this purpose, the properties of the detergent and/or cleaning agents are submitted to the BfR in accordance with Annex VII Section C (Medical Data Sheet) of the European Detergent Regulation. Notifications made via submission of a safety data sheet to the ISi database of the Institute for Occupational Safety and Health of the German Statutory Accident Insurance (IFA) are not permitted in this context.
  3. The national XProductNotification Format is used to submit notifications for these products. The novel European PCN Format may be used instead. For more information see below.
  4. Products for which notification has been issued in accordance with the Regulation on Detergents cannot take advantage of the transitional provision of Annex VIII of the CLP. If any product is intended to be sold beyond 2023, a new (initial submission) using the PCN format (Notification of Hazardous Products) must be submitted by 1 January 2024.

Notification of Detergent and Cleaning Agents NOT Classified as Hazardous

All detergents and cleaning agents which do not fall within the scope of notification requirements of Art. 45, in conjunction with Annex VIII of the CLP Regulation, including all products that constitute individual substances rather than mixtures, are subject to notification requirements according to § 10 of the national Detergents and Cleaning Agents Act and, according to their contents, Annex VII Section C of the European Regulation on Detergents.

The BfR recommends the following notification formats:

  • The traditional national notification format of Germany (XProductNotification, see also FAQ on Product Notifications)

    Note: Please mark the respective products as detergents or cleaning agents by clicking "yes" in the dedicated data field.

  • The novel European Poison Centres Notification Format

    Note: Please mark the submission dossiers as "Voluntary Notifications" / "Non-hazardous submissions" in case you would use the PCN Format for the notification of those detergent and cleaning agents.
    Please assign a relevant EuPCS code to your product to clearly mark your product as detergent or cleaning agent.

Please see also "Notification of Hazardous Products" as well as the Product Notification FAQ.

Please note: If the PCN Format is used for notification purposes of detergent and cleaning agents not classified as hazardous, additional indications have to be made beyond the scope of the notification requirements according to the Detergent Regulation. If you would wish to submit only the minimum requirements, please use the XProductNotification Format as provided by the BfR and upload the data at the 'BfR Web Portal'.

A UFI does not need to be assigned to these detergents and cleaning agents, but it would facilitate the poisons centres’ work if you would generate, print and attach a UFI, and eventually indicate it in the notification as well.

Further information on the Unique Formula Identifier (UFI) is available here:

Both the BfR and the poisons centres handle all received information with the strictest confidence.

For general enquiries regarding the Detergent and Cleaning Agents legislation, please contact the German Environment Agency (UBA).


Help


BfR Helpdesk Product Notifications

E-Mail
produkt-meldungen@bfr.bund.de

Phone
+49-(0)30-18412-23218
+49-(0)30-18412-23206
+49-(0)30-18412-23201


National REACH-CLP-Biocides Helpdesk

Internet
https://www.reach-clp-biozid-helpdesk.de/EN/Home/Home_node.html

Phone
+49-(0)231-9071-2971

Contact form
https://www.reach-clp-biozid-helpdesk.de/EN/Services/Contact/Kontaktformular_node.html


German Environment Agency (UBA)

Internet
https://www.umweltbundesamt.de/en/services

E-Mail
buergerservice@uba.de

Phone
+49-(0)340-2103-2416

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