Regulation (EU) 2026/405 was adopted on 11 February 2026, published on 2 March and entered into force on 22 March; most provisions apply from 23 September 2029. Companies can prepare now, but entry into force does not mean every product already operates a DPP today.

The rules require a DPP for detergents and surfactants made available to end users. Annex VI data include the trade name, unique product and operator identifiers, a clear label or packaging image, responsible parties, traceability, backup provider, declaration of conformity and, where applicable, ingredient and microorganism information. Professional-use SDS exceptions need separate review.

The data carrier and its content must be designed together. It may appear on the label, packaging, accompanying document or refill location; distance-sale buyers must see relevant information before purchase. The system must be open, interoperable and machine-readable, without mandatory consumer registration or unnecessary tracking. Scanability is only the outermost check.

The Commission describes operator duties as compiling product data, linking the physical carrier, registering it and maintaining accuracy through the lifecycle. Import and distance-sale roles also require assessment. A label, formulation, operator or market change should therefore trigger a decision on whether the existing passport still represents the product batch.

Implementing Regulation (EU) 2026/1778, published in July 2026, further describes verified operators, web or API access, semantic consistency, model, batch or item granularity, persistent registration identifiers, timestamps, hashes and versioned data. If product master data, packaging and receipts sit in separate files, updates can create unexplained version gaps.

Technical references also have status boundaries. GS1’s DPP AIDC document can inform identifier design, but it is explicitly provisional, not approved and subject to change. It can support testing, not replace EU law, later standards, authority systems or product-specific compliance decisions.

A practical starting point is one linked table: each market version maps to its product identifier, formulation and ingredient list, packaging image, carrier, responsible party, conformity files, backup service and registration record. Every change should record its effective date, affected batches and disposition of the old version.

EPHYON’s public cleaning-product OEM process connects target market and specification confirmation, formulation-packaging compatibility, approved samples and production records. This can support DPP version discipline when brand, manufacturer and channel define who supplies, checks and maintains each record. The page does not prove EPHYON has completed EU DPP registration or that any product automatically complies.

The Council presents the rules as a modernised framework for microbial products, refills, digital labels, DPP and market surveillance. The real change is not one extra code: product, formulation, packaging, operator and evidence must remain connected by one identity chain. Early version control clarifies later testing and responsibility.

Boundary: this readiness note uses EU law, institutional pages and industry material available on 15 September 2026 and is not legal advice. Scope, registrant, carrier, disclosed data and dates must be confirmed for the final product, market role, delegated acts, harmonised standards and current authority requirements.