The Inception Impact Assessment for the Detergent Regulation was published by Commission with a deadline of the 19th October. The current state of the Detergents Regulation will be used as baseline scenario to benchmark against which policy options will be assessed to reflect the overall regulatory framework applicable to detergents. Policy options in line with the following scenarios will be looked at in terms of improving the coherence and simplifying the regulatory framework for detergents. The Commission has the following points on the table:

• Clarifications on the scope and definitions of the Regulation (refill sale and microbial products)
• Potential additional requirements for detergents e.g. expansion of phosphorus limitations or requirements for certain harmful substances currently not covered by the Regulation (CMR, EDs).
• Improvement of the coherence of the regulatory framework for detergents by addressing the overlaps and inconsistencies with the REACH, CLP and Biocidal Products Regulations.
• Options being considered on the instrument itself are Revising the Detergents Regulation, Repeal and incorporation of its provisions in other pieces of EU chemicals legislation,  Alignment with the New Legislative Framework (‘NLF’), Non-legislative options
• A.I.S.E. has published its response to the Detergent Regulation Inception Impact Assessment. Here are our key asks:
• The scope of the Detergent Regulation should remain for cleaning products including microbial cleaning products. 
• We support improvement of the coherence of the regulatory framework for detergents by addressing the overlaps and inconsistencies with the REACH, CLP and Biocidal Products Regulations.
• With regards to labelling we support the Commission study on simplification of the labelling requirements for chemicals and the use of e-labelling
• The regulations to cover risk assessment and restriction of ingredients in detergents should continue to be REACH, BPR and the General Product Safety Directive.
• The phosphorous restrictions should not be extended to other product categories
• For refill and bulk sale, guidance can provide clarity with regards how to implement already existing regulatory requirements
• The Detergent Regulation remains fit for purpose and we do not see the value of moving the Regulation under the NLF.
• It is also vital that the future framework reflects the role of voluntary schemes in driving sustainable and innovation in our sector