- welcomes the updating and simplification of the Regulation on detergents and the removal of redundant or obsolete elements, however considers that the opportunities for streamlining are offset or exceeded by an increased administrative burden arising from other aspects of the revision proposal;
- emphasises the importance of ensuring coherence and consistency between the revision of the Detergents Regulation and other legislative and technical developments, such as those connected with the Regulation (EC) n. 1272/2008 on CLP and the proposal for a Regulation on Eco-design for Sustainable Products;
- stresses the importance of specific and technical requirements being in place in good time to permit implementation, and so recommends that transitional periods commence only after adoption of the relevant additional legislation;
- recommends that new requirements on detergents containing micro-organisms be adapted to be more consistent, both internally and with other policies, and to support rather than prevent innovation in this emerging product category;
- supports improving the clarity and readability of product labels by removing overlaps between pieces of legislations, simplifying label content and making effective use of digital labelling;
- recommends that the same possibilities for digitalisation of labelling be applied for pre-packaged products as for refill sales, and that detergents may be labelled more clearly using pictograms/icons in place of text;
- finds the obligation to create and notify a product passport for every batch of a detergent/surfactant to be excessively onerous, and recommends establishing a more appropriate trigger for updating of the product passport.