EU ESPR & Digital Product Passport: what detergent manufacturers must do now

From September 2026, new requirements around product transparency, claim substantiation and sustainability communication are reshaping how detergent formulations are developed and marketed.

Environmental and sustainability claims have become an important part of product marketing across many consumer categories. At the same time, concerns around greenwashing have led policymakers to introduce regulations that require manufacturers to substantiate and document their claims more rigorously.

Frameworks such as the Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport (DPP) are moving from policy discussions into practical requirements. At the same time, the implementation of the Empowering Consumers for the Green Transition Directive (EmpCo) from September 2026 increases scrutiny of environmental claims and places greater emphasis on reliable, verifiable evidence behind sustainability messaging.

The sustainability landscape is also becoming increasingly dynamic. Discussions now extend beyond carbon footprint to include topics such as circularity, worker rights, local sourcing, biodegradability, toxicity, and product performance. As priorities evolve, companies must be prepared to respond to changing expectations from regulators, customers, and consumers. 

For manufacturers, this means that regulatory readiness is no longer something to monitor from a distance. It is becoming part of daily formulation decisions.

What are ESPR, the Digital Product Passport and EmpCo?

Taken together, these initiatives are shifting the focus from sustainability intentions to sustainability evidence. In simple terms:

• ESPR sets requirements for how products are designed, including environmental performance, durability, and resource use
• Digital Product Passport (DPP) introduces structured data that follows the product, providing information on materials, performance, and environmental impact
• EmpCo strengthens requirements around environmental and sustainability claims, helping ensure that communications to consumers are supported by reliable and verifiable evidence

Together, they create a more connected system where product design, documentation, sustainability claims and supporting data must be aligned, transparent and verifiable.

  Looking for the official definitions?
Learn more from the European Commission about ESPR , Digital Product Passports and EmpCo .

What is actually changing for detergent manufacturers?

The implications are practical rather than theoretical. These developments affect how formulations are designed and how information is managed. Key shifts include:

• More structured and consistent documentation requirements
• Increased demand for traceability of raw materials
• Greater scrutiny of environmental and performance claims
• Stronger requirements for claim substantiation and consumer communication
• A need for data that can be shared across value chains

Importantly, these elements are interconnected. It is not enough to address one in isolation.

Where companies are likely to face challenges

For many formulation teams, the difficulty is not the concept itself, but the execution. Typical challenges include:

• Fragmented documentation
  Information exists, but not in a structured or accessible format
• Unclear claim substantiation
  Claims may be based on internal knowledge, but lack documented evidence that can withstand increasing scrutiny from customers, regulators, and emerging green claims legislation such as EmpCo.
• Limited visibility into raw materials
  Traceability can be incomplete, especially across complex supply chains
• Disconnect between formulation and compliance
  Regulatory requirements are handled separately from formulation decisions

These gaps are often only fully revealed when requirements become more formal.

Why this is not just a documentation issue

It is tempting to approach ESPR, DPP and EmpCo as administrative or compliance tasks. In practice, they go further than that.

Formulation choices increasingly influence the ability to document and substantiate claims, the availability of consistent data, the traceability of materials, and the overall sustainability profile of a product. They also influence how confidently sustainability benefits can be communicated to customers and consumers.

This means that regulatory readiness is shaped early in the formulation process, not just at the end.

What a practical approach looks like

There is no single solution, but a structured approach can reduce complexity and risk. A starting point can be to:

1. Evaluate your current position across claims, sourcing, documentation, and future reformulation needs
2. Identify where documentation or validation is missing
3. Evaluate how raw materials support traceability requirements
4. Prioritize changes based on impact and feasibility

In many cases, improvements do not require a full redesign. Targeted adjustments can address the most important gaps.

From reactive to prepared

Companies that approach these developments early tend to gain more flexibility. They can adapt gradually, test alternatives, and align internal processes over time. Those that wait may face the need for faster and more extensive changes under tighter timelines.

In that sense, ESPR, EmpCo and the Digital Product Passport are not only regulatory frameworks. They are also signals of how the industry is evolving.

A useful place to start

Understanding where your current formulation stands is often the most valuable first step.

1. Are your claims clearly substantiated?
2. Is your raw material data complete and traceable?
3. Is your documentation structured and ready to be shared?
4. Do you have a plan for replacing ingredients if needed?

Answering these questions helps clarify both risks and priorities.

To support this process, Borregaard has developed a Regulatory Readiness Assessment for detergent formulations. The tool provides a structured way to evaluate your current setup, identify gaps and define practical next steps

Take the assessment to understand where your formulation stands — and how to prepare for evolving requirements: