Yes. Where a product is intended for cleaning or washing, it is considered a detergent, even if it does not contain one or more surfactants.

 
In the Detergents Regulation (648/2004/EC), detergents are defined as: ‘Any substance or mixture containing soaps and/or other surfactants intended for washing and cleaning processes. Detergents may be in any form (liquid, powder, paste, bar, cake, moulded piece, shape, etc.) and marketed for or used in household, or institutional or industrial purposes. Other products to be considered as detergents are:

• ‘Auxiliary washing mixture’, intended for soaking (pre-washing), rinsing or bleaching clothes, household linen, etc.;
• ‘Laundry fabric-softener’, intended to modify the feel of fabrics in processes which are to complement the washing of fabrics;
• ‘Cleaning mixture’, intended for domestic all purposes cleaners and/or other cleaning of surfaces

(e.g.: materials, products, machinery, mechanical appliances, means of transport and associated equipment, instruments, apparatus, etc.);

• ‘Other cleaning and washing mixtures’, intended for any other washing and cleaning processes.

 
‘Washing’ is defined in the Detergents Regulation as “the cleaning of laundry, fabrics, dishes and other hard surfaces”, whereas the ‘cleaning’ means “the process by which an undesirable deposit is dislodged from a substrate or from within a substrate and brought into a state of solution or dispersion.”

 
Examples of detergents which do not contain surfactants are: cleaning vinegar (typically used as a descaler), ammonia (as a degreaser), chlorine bleach and hydrogen peroxide as bleach cleaners (or ‘static cleaners’) and bleaching agents or bleaching additives for the washing process. All of these products must meet the criteria of the Detergents Regulation.