New European Union rules intended to protect consumers against misleading environmental claims will apply from 27 September 2026.
Directive (EU) 2024/825 on Empowering Consumers for the Green Transition introduces stricter requirements for environmental and sustainability claims made on product packaging, websites, advertisements and other business-to-consumer communications.
Generic claims such as “eco-friendly”, “green”, “sustainable” and “climate-friendly” may create significant compliance risks when they are not supported by clear, relevant and verifiable evidence.
What Is Greenwashing?
Greenwashing occurs when a company presents a product, service or business activity as more environmentally beneficial than it actually is.
It may involve vague, exaggerated, unsubstantiated or misleading claims that create an inaccurate impression of a product’s environmental characteristics.
Examples may include:
- Eco-friendly
- Environmentally friendly
- Green
- Sustainable
- Ecological
- Climate-friendly
- Carbon-neutral
- Kind to nature
A claim may still be misleading even where part of it is technically accurate. Companies must also consider the overall impression created for the average consumer.
When Will the EU Greenwashing Rules Apply?
EU Member States were required to adopt and publish national measures implementing Directive (EU) 2024/825 by 27 March 2026.
The new requirements will apply across the European Union from 27 September 2026.
The rules may affect environmental communications used in:
- Product packaging
- Brand and product websites
- E-commerce listings
- Social media content
- Digital advertising
- Printed marketing materials
- In-store promotions
- Product catalogues
- Sustainability labels and symbols
Restrictions on Generic Environmental Claims
The Directive prohibits generic environmental claims where recognised excellent environmental performance relevant to the claim cannot be demonstrated.
Potentially high-risk expressions include:
- Eco-friendly
- Environmentally friendly
- Green
- Ecological
- Climate-friendly
- Sustainable
- Biodegradable
- Nature-friendly
These terms are not necessarily prohibited in every situation. However, the exact environmental benefit must be clear and appropriately supported.
For example, a specific claim such as “the bottle contains 80% recycled plastic”, where accurate and verifiable, may be preferable to a broad statement such as “eco-friendly packaging”.
Carbon-Neutral and Climate-Neutral Product Claims
The Directive introduces specific restrictions on claims that a product has a neutral, reduced or positive impact on greenhouse gas emissions where the claim is based on offsetting.
Potentially affected claims include:
- Carbon-neutral
- Climate-neutral
- CO₂-neutral
- Climate-positive
- Reduced climate impact
The purpose of this restriction is to prevent consumers from believing that a product itself generates no emissions, or produces fewer emissions, where the claimed benefit results only from the purchase of carbon credits or investment in offsetting projects.
Companies should clearly distinguish between direct emissions reductions, value-chain improvements and separate offsetting activities.
Sustainability Labels and Logos
The Directive also restricts the display of sustainability labels that are not based on a certification scheme or established by a public authority.
A sustainability label will generally need to be:
- Based on a credible certification system; or
- Established by a public authority.
Self-created symbols such as “eco choice”, “green approved” or similar marketing logos may pose a compliance risk where they are not supported by an independent and credible verification framework.
Claims About Future Environmental Performance
Forward-looking claims such as “we will be carbon-neutral by 2030” or “we are transitioning to fully sustainable production” will also be subject to stricter requirements.
Such claims should be supported by:
- Clear and objective commitments
- A publicly available implementation plan
- Measurable and time-bound targets
- Regular verification by an independent third-party expert
Publishing an aspirational target without a realistic implementation plan may be considered misleading.
Impact on the Cosmetics Industry
The cosmetics industry is likely to be significantly affected due to the frequent use of natural, clean, sustainable and environmentally focused marketing.
Claims requiring particular attention may include:
- Natural
- Clean beauty
- Green beauty
- Sustainable
- Plant-based
- Vegan
- Biodegradable
- Recyclable
- Plastic-free
- Ocean-friendly
- Reef-friendly
- Carbon-neutral
Terms such as “natural”, “plant-based” and “vegan” are not automatically environmental claims in every context. However, they may fall within the new rules where they are used to suggest that a cosmetic product has a superior environmental performance.
Companies should assess not only the wording but also images, colours, symbols and the overall impression created by their marketing.
How Should Recyclability Claims Be Presented?
A recyclability claim should clearly identify which part of the packaging is recyclable.
Where a bottle is recyclable but the pump, cap or label is not, the overall package should not be presented as fully recyclable without an appropriate qualification.
Companies should assess:
- Which packaging components are recyclable
- Whether suitable recycling infrastructure exists in the target market
- Whether consumers must separate individual components
- Whether the claim relates to the entire package or a specific part
- Whether the claim is supported by current technical evidence
Impact on Cosmetic Product Safety Assessors
The Directive does not directly amend the toxicological safety assessment requirements applicable to cosmetic products.
However, information used in product safety files, technical documentation and marketing materials should remain accurate and consistent.
Cosmetic product safety assessors, Responsible Persons and regulatory teams may need to work together on matters such as:
- Accuracy of formulation and ingredient claims
- Calculation of natural or plant-derived content
- Biodegradability information
- Packaging materials and recycled content
- Environmental performance testing
- Certification and verification documents
- Consistency between packaging and digital communications
How Will Existing Packaging and Old Stock Be Treated?
The rules will apply from 27 September 2026, but practical issues may arise for products and packaging manufactured or distributed before that date.
The EU Consumer Protection Cooperation Network has indicated that national authorities may adopt a proportionate and phased enforcement approach where genuine old-stock difficulties exist.
Companies will nevertheless be expected to take timely and good-faith compliance measures, including:
- Updating online claims
- Correcting digital advertising
- Adapting future packaging orders
- Providing corrective information at the point of sale where appropriate
- Documenting stock levels and transition plans
This approach does not provide an automatic or unlimited exemption for existing stock. Cases may be assessed individually based on the circumstances and the compliance actions taken by the company.
What Should Cosmetic Companies Do Before September 2026?
Cosmetic manufacturers, Responsible Persons, importers and brand owners operating in the EU should conduct a comprehensive review of their environmental communications.
Recommended actions include:
- Creating an inventory of environmental claims
- Reviewing websites and e-commerce pages
- Replacing vague language with specific information
- Preparing substantiation files for each claim
- Removing product claims based solely on carbon offsetting
- Assessing self-created sustainability labels
- Supporting future targets with credible implementation plans
- Updating certificates and verification records
- Developing an old-stock transition strategy
- Coordinating marketing, legal and regulatory teams
What Do the New Rules Mean for Cosmetic Brands?
The new EU requirements mean that environmental communication should be treated as a verifiable compliance matter rather than solely as a creative marketing exercise.
Environmental claims made to consumers must be clear, specific, substantiated and non-misleading.
Cosmetic companies that fail to review their communications before 27 September 2026 may face packaging changes, withdrawal of advertising materials, investigations by consumer authorities and sanctions under applicable national legislation.