Detergent & Cleaning Product Labelling: Fragrance and Allergen Declaration

In Turkey, the framework for cleaning products is set by the Regulation on Detergents. Published in the Official Gazette dated 27 January 2018, numbered 30314, this regulation governs the rules for placing detergents and surfactants used in detergents on the market. The regulation was drawn up in alignment with EU legislation, taking into account Council Regulation (EC) No 648/2004 of 31 March 2004 on detergents.

Its scope can be summarised under four headings: rules on the biodegradability of surfactants in detergents; restrictions or prohibitions on surfactants with respect to biodegradability; rules on additional information on detergent labels, including the fragrance allergens they contain; and information that manufacturers must hold for submission to the Ministry and health personnel on request, as well as restrictions on phosphate and other phosphorus compound content in consumer laundry detergents and automatic dishwasher detergents.

The critical point here is that the detergents regulation alone is not sufficient. In applying the regulation, the provisions on classification, packaging and labelling set out in the Regulation on Classification, Labelling and Packaging of Substances and Mixtures (SEA Regulation), published in the Official Gazette dated 11 December 2013, numbered 28848 (bis), remain in force. In other words, the SEA Regulation operates in parallel on the same packaging. The SEA is the Turkish equivalent of the EU's CLP Regulation; it governs the classification of chemicals according to hazard class, their labelling, and their safe packaging.

The definition also supports this distinction. Detergent products are substances or mixtures containing soaps and/or other surfactants intended for washing and cleaning processes other than the cleaning of the human body; they may be in any physical form — liquid, powder, paste, bar, moulded shape or similar — and are placed on the market for use in households, or for institutional or industrial purposes.

There is also a third framework: the moment you add a disinfection claim to a product, the picture changes. Detergents containing surfactants considered to be disinfectants are subject to the labelling provisions specified for disinfectants in Section A of Annex 7. Writing "kills 99.9% of bacteria" on packaging brings the product within the scope of biocidal legislation as well. If you want to sell a scented surface cleaner and you do not have a biocidal authorisation file, do not write that sentence.

The regulation explicitly lists what must appear on the packaging of detergents offered for sale to consumers. This information must be legible, visible and indelible: the name and trade name of the product; the name or trade name or trademark and full address and telephone number of the party responsible for placing the product on the market; and the address, telephone number and e-mail address from which the ingredient data sheet can be obtained. Packaging must also display the contents in accordance with the specifications set out in Section A of Annex 7; instructions for use and, where necessary, special precautions must also appear on the packaging.

There are two additional layers. Packaging for consumer laundry detergents and consumer automatic dishwasher detergents must also carry the information in Section B of Annex 7 — namely dosage tables, usage quantities according to water hardness, and the standard number of washes. The language question is non-negotiable: all specified information must appear on the label in Turkish.

The ingredient declaration differs from the INCI logic used in cosmetics. Here, substances are given according to functional groups and weight bands. The function and concentration of the chemical substances used in a detergent product are stated for concentrations above 0.2 wt%; fragrance allergens must be listed on the label if present above 0.01 wt%. Certain components — such as fragrance oils/parfum, enzymes, optical brighteners and preservatives — are declared groups regardless of their concentration; this is why enzymes, disinfectants, optical brighteners and parfum appear consistently on labels.

Where the label ends, the ingredient data sheet begins. Manufacturers placing mixtures covered by this Regulation on the market must, upon request, provide any health professional with the ingredient data sheet provided for in Section C of Annex 7 without delay and free of charge. Furthermore, manufacturers must make this ingredient data sheet available on their websites, except in certain specified cases. In other words, the attitude of "I won't publish ingredients on my product page in case competitors copy them" is contrary to the regulation.

Who counts as a "manufacturer" also matters: manufacturers of detergents and/or surfactants used in detergents must be established in Turkey. If you are using contract manufacturing, clarify in your agreement which party the responsible-party line on the label refers to.

In cleaning products, the fragrance allergen declaration looks not at the total fragrance oil content but at the individual substances within the fragrance oil. The threshold is 0.01% by weight, calculated on the finished product. The concentration limit of 0.010% by weight per substance is used as the reference for fragrance materials subject to declaration requirements under Annex 3 of the Cosmetics Regulation. Note: the list is borrowed from cosmetic legislation, but the rules governing it are those of the detergents regulation.

This borrowing has become confusing in recent years as the allergen list has expanded. Detergents legislation requires allergen information to be provided on the label of any washing or cleaning product; the list of fragrance allergens was drawn up under cosmetic legislation and has recently been extended to approximately 80 substances. The fact that the detergent side refers to the cosmetics list without specifying any transitional period left application somewhat uncertain for a time. The European Commission has clarified that the transitional periods granted for cosmetic products also apply to laundry and cleaning products.

Get your relationship with IFRA right too. IFRA Standards are an industry self-regulatory system; their limits are defined by product category and on a per-molecule basis, and cleaning products are included in that categorisation. However, IFRA compliance does not remove the labelling obligations under the detergents regulation. Do not make sweeping generalisations such as "this fragrance oil is safe up to this level"; request your supplier's IFRA compliance statement and category information, and verify that it matches the product type you intend to use it in.

The sequence works as follows: first you classify the mixture, then the label elements derive from that classification. The most common deficiency found in inspections is that the classification is correct but the label elements are missing or printed in the wrong language. The fragrance oil plays a quiet but significant role in this classification: many aroma chemicals fall into the skin sensitiser category (H317) or are classified as hazardous to the aquatic environment, and can alter a mixture's classification even at low concentrations.

The core rules for label elements:

There is an additional heading on the packaging side: single-use soluble capsules. When a consumer laundry detergent or automatic dishwasher detergent that is liquid is contained in a soluble single-dose packaging, additional provisions apply, while the SEA provisions remain in force. If you are considering capsule production, plan for these additional provisions and child-resistant outer packaging requirements from the outset.

There is a historical turning point on the notification side: the Communiqué on detergents and surfactants used in detergents, administered by the Ministry of Health, was repealed as of 23 December 2017; with the repeal of that Communiqué, it became possible to place detergents on the market without completing a notification process. This does not mean "no obligations whatsoever". The obligation has shifted from the notification desk to the technical file and label responsibility. In practice, the following are expected to be in the file: the ingredient data sheet; safety data sheets for raw materials; the safety data sheet for the finished product and the qualification of its author; the percentage quantities by weight of the chemical substances making up the product formula within a ±5% range, together with the reasons for their inclusion in the formula.

Biodegradability is also part of the file. Legislation requires surfactants used in detergents to be fully biodegradable. This is important because detergents generally flow into sewerage systems after use and are processed in water treatment plants. When selecting a surfactant, put test data alongside the price.

If you are thinking about exports, set your horizon now: the EU side has been updated. Regulation (EU) 2026/405, published on 2 March 2026, replaces the 22-year-old Regulation (EC) No 648/2004. The new regulation updates the EU framework to cover online and distance sales, refill sales, detergents with intentionally added micro-organisms, digital labelling and product traceability. A mandatory Digital Product Passport for all detergents and surfactants placed on the EU market is coming; digital labelling may serve as an alternative to a physical label for most information, but critical safety information such as dosage, allergens and emergency information must remain on the physical label. On the timeline: most provisions begin to apply on 23 September 2029, when Regulation (EC) No 648/2004 is repealed; products placed on the market in compliance with the old regulation between 23 September 2029 and 22 September 2030 may remain on the market until 23 September 2030.

Below we have compiled the questions most frequently asked by aspiring manufacturers.