Key Steps for Registering Detergents in the EU. Requirements and Common Mistakes When Placing Products on the Market

Entering the European Union market for manufacturers of chemical products and detergents from Ukraine, Turkey, Asia or the Middle East is not only about logistics and contracts. First and foremost, it is about compliance with EU regulatory requirements — without which the product simply cannot be legally sold.

In the EU, responsibility for product safety lies not only with the manufacturer, but also with the entity placing the product on the market. For non-EU companies, this means the necessity of appointing a Responsible Person / Only Representative within the European Union.

Our company provides exactly this function and full regulatory support.

Key Steps for Export to the EU

1. Preparation of Safety Data Sheets (SDS) in accordance with REACH and CLP

The SDS must be prepared according to European requirements, not local standards. It must include:

• CLP classification

• full composition of the mixture

• toxicological and environmental data

• consistency with the actual formulation

2. Appointment of a Responsible Person in the EU

Without an EU-based representative:

• notification to ECHA is impossible

• there is no legal contact with regulators

• the importer automatically assumes all legal risks

The Responsible Person represents the manufacturer, communicates with authorities and maintains regulatory documentation.

3. Maintaining a Product Technical File

A typical dossier includes:

• SDS for the product and all ingredients

• quality certificates

• test results (biodegradability, stability)

• fragrance documentation (IFRA certificate, allergen list)

4. UFI Code and Poison Centre Notification (PCN)

According to Article 45 of the CLP Regulation, all mixtures classified as hazardous to health or due to physical hazards must be notified to designated national authorities in each EU Member State through the ECHA Poison Centre Notification system.

Before placing the product on the market, the manufacturer or its Responsible Person must submit full information on composition, toxicology and classification.

Absence of PCN notification for hazardous products is a direct violation of EU law and results in immediate sales ban and product recall.

Without a UFI code and PCN registration in ECHA, a hazardous chemical product cannot legally be sold in the EU.

5. Labelling in EU Languages

The label must comply with CLP requirements and include:

• hazard pictograms

• H- and P-statements

• EU Responsible Person details

• translation into the language of each country of sale

Common Mistakes of Foreign Manufacturers

Based on KRP CG practice, the most frequent issues are:

❌ SDS prepared according to local standards rather than EU requirements

❌ No Responsible Person in the EU

❌ Incomplete or disguised composition (no exact concentrations)

❌ Labelling ignores detergent or aerosol legislation

❌ Missing or inconsistent UFI vs PCN dossier

❌ Incorrect label translation without official CLP terminology

❌ Export attempts without PCN — customs blocking or recalls

Result: fines, sales bans, recalls and loss of contracts.

Why Work with KRP CG

KRP CG is registered in Kraków (Poland) and specializes in:

• preparation of SDS and UFI assignment

• ECHA registrations

• labelling and dossier verification

• Responsible Person services in the EU

• communication with regulatory authorities

We work with manufacturers from Ukraine, Turkey, the Middle East and Asia and help them enter the EU market without legal risks for importers.

Conclusion

Exporting chemical products to the EU is a system of responsibility, documentation and registrations.

Those who prepare in advance enter the market.Those who ignore regulations lose shipments, money and reputation.

KRP CG helps you go from formulation to legal sale in the EU.