Detergents and cleaning products: labelling, safety data sheets and classification on import
A detergent is a chemical mixture before it is a consumer product. Hazard label, safety data sheet, tariff heading and transport rules are settled before production, not on arrival.
The SELA International team
The question addressed
Importing detergents and cleaning products: what labelling and safety data sheets are required?
Key takeaway
Most markets build on the UN Globally Harmonized System (GHS), whose eleventh revised edition was published in 2025: a label with pictograms, a signal word, H hazard statements and P precautionary statements, and a 16-section safety data sheet, in the language of the destination country. The European Union adds the CLP Regulation and a detergents regulation, whose new text, Regulation (EU) 2026/405, will apply from 23 September 2029. At customs, washing and cleaning preparations fall under HS heading 34.02 and soap under 34.01. Some concentrates, such as hypochlorite solutions (UN 1791) or sodium hydroxide solutions (UN 1824), travel as Class 8 dangerous goods under the IMDG Code.
Laundry detergents, dishwashing liquids, degreasers, descalers, disinfectants: the family is commonplace on the shelf, but in regulatory terms every product is a chemical mixture. On import, three questions come before price: how the product is classified and labelled, which safety data sheet goes with it, and how it is declared at customs and shipped. The answers depend on the destination country; the principles are largely shared.
The GHS, the common basis for labelling
The Globally Harmonized System of Classification and Labelling of Chemicals (GHS) is maintained under the auspices of the United Nations; its eleventh revised edition was published in 2025. The GHS is not a law: each country builds it into its own regulations, sometimes adopting an earlier revision and only some of the hazard categories. The same product may therefore carry different labels depending on the market. The label of a mixture classified as hazardous shows:
- hazard pictograms, red-bordered diamonds: corrosion for a concentrated alkaline detergent, exclamation mark for an irritant;
- a signal word, “Danger” or “Warning”;
- hazard statements, coded H, for example H314 “Causes severe skin burns and eye damage” or H318 “Causes serious eye damage”;
- precautionary statements, coded P, for example P102 “Keep out of reach of children”;
- the product identifier, the hazardous components that drive the classification, and the supplier’s full identity.
The 16-section safety data sheet
The safety data sheet (SDS) is the technical document intended for professional users, freight forwarders and authorities. The GHS sets out its 16-section structure, which the European Union applies through Annex II to the REACH Regulation, as replaced by Regulation (EU) 2020/878 and applicable since 1 January 2021:
- Identification of the substance/mixture and of the company/undertaking
- Hazards identification
- Composition/information on ingredients
- First aid measures
- Firefighting measures
- Accidental release measures
- Handling and storage
- Exposure controls/personal protection
- Physical and chemical properties
- Stability and reactivity
- Toxicological information
- Ecological information
- Disposal considerations
- Transport information
- Regulatory information
- Other information
Three sections deserve close reading on import: section 2, which must match the label exactly; section 3, which lists the hazardous components; and section 14, which gives the UN number and transport class. A generic, undated SDS, or one written for another market, exposes the shipment to a customs hold or to refusal by the shipping line.
Language and the destination country’s rules
The label must be written in the language required by the destination country. In the European Union, the CLP Regulation (Regulation (EC) No 1272/2008) requires the official language or languages of the Member State where the product is placed on the market, unless that State provides otherwise; it was revised by Regulation (EU) 2024/2865, which notably governs label formatting. Outside the Union, the extent to which the GHS has been adopted varies widely from country to country. Where there is no specific national text, buyers, distributors and tenders often refer to the EU CLP and detergents rules. A bilingual French-English label is not enough everywhere: Arabic or Portuguese, for example, may be required depending on the market.
The EU detergents regulation: a text in transition
Detergents sold in the Union are also subject to a specific regulation. Regulation (EC) No 648/2004, which covers in particular the biodegradability of surfactants and content labelling, will be repealed on 23 September 2029 by Regulation (EU) 2026/405 on detergents and surfactants, adopted on 11 February 2026 and published in the Official Journal on 2 March 2026. Among other things, the new text provides for:
- a label carrying the information set out in its Annex V, in one or more languages easily understood by end-users, as determined by the Member State;
- dosage instructions for consumer laundry detergents, automatic dishwasher detergents and surface detergents;
- the option of digital labelling, with health and environmental information remaining on the physical label;
- an ingredients data sheet, to be provided to the appointed bodies;
- an obligation for manufacturers established outside the Union to appoint an authorised representative established in the Union.
Products placed on the market before 23 September 2029 in compliance with the old regulation may continue to be made available indefinitely. For a manufacturer exporting to Europe, or to markets that take their cue from it, formulas, labels and data sheets will need reviewing before then.
Customs and transport: 34.02, 34.01 and dangerous goods
In the WCO Harmonized System (2022 edition), heading 34.02 covers organic surface-active agents other than soap, together with surface-active preparations, washing preparations and cleaning preparations, whether or not containing soap, other than those of heading 34.01. The latter covers soap, along with surface-active products for washing the skin in liquid or cream form put up for retail sale: a liquid hand soap is not a detergent in tariff terms. Nor does every cleaning product fall under chapter 34. Classification at eight or ten digits, and therefore the applicable duty, remains national.
| Product | HS subheading |
|---|---|
| Laundry detergent, dishwashing liquid or cleaner put up for retail sale | 3402.50 |
| Washing or cleaning preparations not put up for retail sale | 3402.90 |
| Toilet soap in bars | 3401.11 |
| Liquid hand soap put up for retail sale | 3401.30 |
| Scouring pastes and powders | 3405.40 |
| Disinfectants put up for retail sale | 3808.94 |
On the transport side, a product classified as hazardous for users is not necessarily dangerous goods for carriage, and vice versa: section 14 of the SDS says which. By sea, dangerous goods fall under the International Maritime Dangerous Goods Code (IMDG Code), whose Amendment 42-24 has been mandatory since 1 January 2026. Hypochlorite solutions, for example, are UN 1791 and sodium hydroxide solutions UN 1824, in Class 8 (corrosive substances), packing group II or III depending on the product. A dangerous goods declaration, approved packaging and compliant marking are then required, and acceptance by the shipping line should be confirmed before booking. Products in small containers may, subject to conditions, qualify under the limited quantity provisions.
What to require from the manufacturer
- A 16-section SDS per reference, dated, in the format and language of the destination market, consistent with the formula actually produced.
- The label artwork, showing classification, pictograms, H and P statements and the responsible operator’s contact details, approved before printing.
- The transport classification — UN number, class, packing group — or a written statement that the product is not regulated for transport.
- The list of ingredients and, for markets aligned with EU rules, evidence of surfactant biodegradability.
- Any registrations or authorisations specific to the destination country, particularly for disinfectants, which often fall under a separate regime.
- A commitment to report any change of formula, which requires the SDS and the label to be updated.
For cleaning products, SELA INTERNATIONAL LTD states the destination market, the labelling language and the expected regulatory framework in every quotation request, and has labelling and compliance with the destination market checked during the pre-shipment inspection.
This article sets out general reference points and does not constitute regulatory or legal advice. Each destination country sets its own requirements for the labelling, language and, where applicable, registration of chemical products; the regulations of the destination country prevail.
Sources
- EUR-Lex, Publications Office of the European Union — Regulation (EU) 2026/405 of the European Parliament and of the Council on detergents and surfactants, and repealing Regulation (EC) No 648/2004
- EUR-Lex, Publications Office of the European Union — Regulation (EU) 2024/2865 amending Regulation (EC) No 1272/2008 on classification, labelling and packaging of substances and mixtures
- EUR-Lex, Publications Office of the European Union — Commission Regulation (EU) 2020/878 amending Annex II to Regulation (EC) No 1907/2006 (REACH)
- World Customs Organization (WCO Trade Tools) — Harmonized System 2022 — Heading 34.02
- Maritime and Coastguard Agency, GOV.UK — MIN 715 (M) Carriage of Cargoes - Adoption of Amendment 07-23 of the International Maritime Solid Bulk Cargoes (IMSBC) Code and Amendment 42-24 of the International Maritime Dangerous Goods (IMDG) Code
- Hong Kong Fire Services Department, Dangerous Goods Thematic Website — Dangerous Goods (search: UN 1791)