The EU Detergents Regulation (EC) No 648/2004 is the primary European law governing the formulation, labelling, and sale of all cleaning products — including every chemical used in professional car washes. If you operate a car wash in the EU or purchase chemicals from EU manufacturers, this regulation directly affects what products you can legally use and how you must handle them.
This guide explains the regulation in practical terms for car wash operators and managers.
What the regulation covers
Regulation 648/2004 applies to all “detergents” — defined broadly as any preparation containing surfactants intended for washing and cleaning processes. For car washes, this includes:
- Active foam (alkaline pre-wash) — including products like Fortis Foam PRO and Fortis Foam ECO
- Acidic rinse products — used in two-step washing
- Wax and rinse aid — post-wash treatments
- Wheel cleaners — specialized acidic or alkaline formulations
- Interior cleaners — upholstery and dashboard products used in detailing
The regulation does not cover raw chemicals sold to manufacturers for formulation purposes — those fall under REACH.
The four key requirements
1. Ultimate biodegradability of surfactants
This is the most important requirement for car wash chemistry. All surfactants in a detergent product must achieve ultimate aerobic biodegradability — meaning they must break down to CO₂, water, and mineral salts under standard test conditions.
The test standard is OECD 301 (any variant: 301A through 301F). A surfactant passes if it achieves:
- ≥ 60% biodegradation within 28 days (for CO₂ evolution and dissolved organic carbon tests)
- ≥ 70% biodegradation within 28 days (for dissolved organic carbon removal tests)
Products containing surfactants that fail this test cannot be legally sold in the EU. There is a derogation procedure for essential-use surfactants, but it is rarely applied and does not cover standard car wash products.
What this means in practice: when you buy foam from a reputable EU manufacturer, the surfactant biodegradability has already been tested and certified. The risk arises when operators import unregulated products from outside the EU or mix chemicals from multiple sources.
2. Ingredient disclosure and labelling
Every detergent product sold in the EU must carry specific label information:
| Required on label | Details |
|---|---|
| Surfactant types | Listed by category (anionic, cationic, non-ionic, amphoteric) with concentration ranges (< 5%, 5–15%, 15–30%, ≥ 30%) |
| Preservatives | Listed by INCI name if present |
| Fragrances | Listed as “fragrance” plus any allergens above threshold |
| Enzymes | Listed by type if present |
| Phosphorus content | Weight percentage if above 0.5% |
| Dosage instructions | Recommended use amounts |
| Manufacturer details | Name, address, contact |
For car wash operators, the labelling requirement means you should be able to identify exactly what is in your chemicals. If a product lacks proper EU labelling, it may not be compliant — and using non-compliant products can affect your operating licence.
3. Safety Data Sheets (SDS)
Every product must have a Safety Data Sheet available, containing:
- Hazard identification and classification
- First aid measures
- Fire-fighting and accidental release measures
- Handling and storage instructions
- Exposure controls and personal protection requirements
- Toxicological and ecological information
Operators must keep current SDS for all chemicals on site, accessible to staff. Many local authorities check SDS availability during inspections.
4. Phosphate and phosphorus limits
Since the 2012 amendment (Regulation 259/2012), consumer laundry detergents are limited to 0.5g phosphorus per wash. While this limit specifically targets consumer products, the broader trend has pushed professional car wash products toward low-phosphorus or phosphorus-free formulations as well.
Phosphorus in wastewater causes eutrophication — algal blooms that deplete oxygen in waterways, killing fish and other aquatic life. Car washes that discharge to municipal sewers may face local phosphorus limits regardless of the EU regulation.
Operator obligations
While the regulation primarily targets manufacturers and importers, operators have practical obligations:
Use only compliant products
Purchase chemicals from established EU manufacturers who can provide compliance documentation. Both Fortis Foam PRO and Fortis Foam ECO fully comply with Regulation 648/2004.
Maintain documentation
Keep on file:
- Safety Data Sheets for every product in use
- Product labels (or photos of labels)
- Purchase records showing the manufacturer and product identity
Follow dilution instructions
Using products at incorrect dilution ratios — particularly over-concentrating — can affect the environmental profile of your wastewater. An over-concentrated working solution means more surfactant reaching the oil separator and sewer, potentially exceeding local discharge limits. Our guide to chemical dosing mistakes covers this in detail.
Manage wastewater properly
The regulation works in concert with local wastewater discharge regulations. Even biodegradable surfactants must be properly treated — they are biodegradable, not immediately harmless. A functional oil separator and, ideally, a closed-loop water recycling system ensure your wastewater meets discharge requirements.
Regulation 648/2004 vs REACH — what is the difference?
| Aspect | Regulation 648/2004 | REACH |
|---|---|---|
| Scope | Detergent products (formulations) | Individual chemical substances |
| Focus | Biodegradability, labelling, phosphorus | Registration, safety assessment, restriction |
| Who must comply | Manufacturers, importers of finished products | Manufacturers, importers of raw chemicals |
| Testing | OECD 301 biodegradation tests | Full toxicological and ecotoxicological dossier |
| Operator impact | Use compliant products, keep SDS on file | Indirect — chemicals you buy should be REACH-registered |
Both regulations apply simultaneously. A car wash chemical must contain REACH-registered substances and meet Regulation 648/2004 biodegradability requirements.
The 2025 revision proposal
The European Commission has proposed a revision of the Detergents Regulation to align it with the EU Green Deal and Chemicals Strategy for Sustainability. Key proposed changes include:
- Digital labelling — allowing QR codes instead of full physical labels
- Microplastic restrictions — potential limits on microplastic ingredients in wash products
- Stricter biodegradability requirements — extending ultimate biodegradability requirements beyond surfactants to all organic ingredients
- Simplified procedures — streamlining the derogation process
Car wash operators should monitor these developments, as the revised regulation may impose new requirements on product formulation and labelling. Products formulated with high-biodegradability ingredients — like Fortis Foam ECO — are well-positioned for tighter future requirements.
Practical checklist for car wash operators
- Verify product compliance — check that all chemicals carry EU-compliant labels with surfactant categories and concentration ranges
- Collect and file SDS — request current Safety Data Sheets from every supplier, keep them accessible on site
- Use correct dilution — follow manufacturer recommendations with a dosing pump to ensure accurate concentration
- Maintain your separator — a functional oil separator is essential for treating surfactant-laden wastewater
- Document everything — purchase records, SDS files, dilution settings, and wastewater test results
- Choose biodegradable products — read more in our guide to biodegradable car wash chemicals
- Stay informed — follow updates to the regulation through ECHA or your industry association
Frequently asked questions
Do I need a licence to use car wash chemicals in the EU?
No specific licence is needed to use compliant detergent products. However, you need local permits for wastewater discharge, and inspectors may verify that your chemicals are EU-compliant and properly documented. The licence requirement applies to manufacturers and importers, not end users.
What happens if I use non-compliant chemicals?
Using products that don’t meet Regulation 648/2004 can result in fines from market surveillance authorities. More practically, non-compliant chemicals may contain surfactants that don’t biodegrade properly, which can cause you to fail wastewater discharge tests — leading to penalties under local environmental law.
Are all car wash foams automatically compliant?
No. Products manufactured and sold within the EU must comply, but imported products from outside the EU may not meet the biodegradability requirements. Always verify that imported chemicals carry proper EU labelling and can provide OECD 301 test results for their surfactants.
How does this regulation affect my choice of foam?
Choose products from EU manufacturers who provide full documentation. Both Fortis Foam PRO (high-performance alkaline foam) and Fortis Foam ECO (eco-friendly formula with enhanced biodegradability) comply with all current requirements and are formulated to meet anticipated future standards.