The beauty industry is facing its biggest regulatory shake-up in years. With Directive (EU) 2024\/825 cosmetic brands across Europe must prepare for a complete overhaul of how they communicate environmental claims. Although the Directive entered into force in March 2024, its obligations will apply only after national transposition, from September 2026, the vague, unsubstantiated “green” promises that have long dominated beauty marketing will be banned\u2014and the consequences for non-compliance could be severe.<\/p>\n
For years, consumers have been bombarded with environmental claims in the beauty aisle. Products labeled as “natural,” “eco-friendly,” “green,” or “sustainable” line the shelves, often with little to back up these assertions. According to the European Commission, 53% of green claims give vague, misleading or unfounded information, while there are 230 sustainability labels and 100 green energy labels in the EU, with vastly different levels of transparency.<\/p>\n
This practice\u2014known as greenwashing<\/strong>\u2014has eroded consumer trust and made it nearly impossible for shoppers to distinguish genuinely sustainable products from those that simply look the part. The cosmetics industry has been particularly prone to these practices, with brands using botanical packaging, earth tones, and nature-inspired branding to suggest environmental benefits that their formulations may not deliver.<\/p>\n The Greenwashing Directive, formally known as Directive (EU) 2024\/825, introduces sweeping changes that will fundamentally reshape how cosmetic companies market their products. Here’s what brands need to know:<\/p>\n Starting September 27, 2026,<\/strong> cosmetic brands will face strict prohibitions on several common marketing tactics:<\/p>\n For any environmental claim that is allowed, brands must provide comprehensive documentation covering several key areas. Claims must specify their scope\u2014whether they apply to the entire product, a component, or specific characteristics.<\/p>\n Companies must demonstrate compliance with legal requirements and show how their product performs compared to others in the same category. Additionally, brands need to address significant environmental impacts related to climate change, water use, pollution, biodiversity, and animal welfare.<\/p>\n While these rules apply across all industries, cosmetic brands face unique challenges in adapting to the new framework. The beauty industry has built much of its recent growth on the “clean beauty” and “natural cosmetics” movements, which often rely on the exact types of claims now under scrutiny.<\/p>\n One of the biggest issues for cosmetics is the widespread use of the term “natural.” Currently unregulated in most markets, “natural” has become a catch-all term that means different things to different brands. Some use it to indicate that a single ingredient is plant-derived, even if the rest of the formula is synthetic. Others apply it more rigorously to entire formulations.<\/p>\n Under the new rules, brands using “natural” or similar terms will need to be far more specific. They’ll need to define exactly what they mean, provide evidence for these claims, and ensure that the claim isn’t misleading in the context of the entire product. Under EU consumer law, claims are assessed based on the perception of the average consumer, not on internal brand definitions.<\/p>\n The directive introduces significant changes related to natural and organic cosmetics, requiring brands to substantiate any organic claims with appropriate certifications. Simply featuring organic ingredients is not enough\u2014brands must clarify what percentage of the product is organic and provide third-party verification.<\/p>\n The directive’s ban on self-certification is particularly impactful for cosmetics. Many beauty brands have created their own sustainability seals or partnered with less rigorous certification programs. Going forward, only labels based on transparent, third-party certification schemes or approved by public authorities will be acceptable.<\/p>\n Recognized certifications in the cosmetics space include COSMOS Organic, ECOCERT, EU Ecolabel or equivalent, independently verified certification schemes recognised at EU level. Brands without these or equivalent certifications will need to either obtain them or remove sustainability claims from their marketing.<\/p>\n It’s important to note a recent development: in June 2025, the European Commission announced its intention to withdraw the proposed Green Claims Directive. This separate directive would have introduced even more stringent requirements, including mandatory pre-verification of all environmental claims by accredited third parties.<\/p>\n However, the withdrawal of this proposal doesn’t mean brands are off the hook. The ECGT already entered into force in March 2024 and needs to be transposed by March 2026 and applied as of September 2026. The Empowering Consumers for the Green Transition (ECGT) Directive\u2014Directive 2024\/825\u2014remains in full force and will be implemented across all EU member states.<\/p>\n The clock is ticking for cosmetic companies. With the September 2026 enforcement deadline approaching, brands should take immediate action:<\/p>\n Conduct a comprehensive review of all packaging, advertising, websites, and social media content. Identify any problematic claims, self-made eco-labels, or unsubstantiated sustainability assertions.<\/p>\n For any environmental claims you plan to maintain, compile the necessary evidence. This includes:<\/p>\n If your products genuinely meet certain environmental standards, invest in recognized third-party certifications. Research which certifications are most relevant to your product category and market positioning.<\/p>\n Replace broad, generic claims with specific, substantiated statements. Instead of “eco-friendly,” consider more precise language like “packaging made from 80% post-consumer recycled plastic, certified by [certification body]” or “certified organic ingredients by COSMOS Organic standard, comprising 95% of the formula.”<\/p>\n Ensure that everyone involved in creating marketing materials understands the new restrictions. Develop internal guidelines for what can and cannot be claimed, and implement approval processes to prevent non-compliant claims from going to market.<\/p>\n As member states begin implementing and enforcing these rules, pay attention to how authorities are interpreting the directive. Enforcement actions against competitors can provide valuable guidance on where the red lines are drawn.<\/p>\n While adapting to these regulations requires investment, there are significant business benefits to getting ahead of the curve:<\/p>\n While these regulations are specific to the EU, their impact will be felt globally. The EU market is too important for most major cosmetic brands to ignore, and many companies find it more efficient to apply stricter EU standards across all their markets rather than maintaining different claims in different regions.<\/p>\n There’s also a strong possibility that other jurisdictions will follow the EU’s lead. California, which often leads US regulatory trends, has already enacted laws banning false and misleading environmental claims. Other US states and countries worldwide may adopt similar frameworks in the coming years.<\/p>\n The new EU greenwashing rules represent a fundamental shift in how cosmetic brands can communicate about sustainability. The days of vague, unsubstantiated “green” marketing are ending, replaced by a system that demands specificity, verification, and genuine environmental performance.<\/p>\n For brands that have been genuinely working toward sustainability, these regulations are an opportunity to showcase their authentic efforts in a landscape where competitors can no longer hide behind empty claims. For those who have relied on greenwashing tactics, the next two years present an urgent challenge: either invest in real sustainability improvements and proper documentation, or prepare to significantly scale back environmental marketing.<\/p>\n The beauty industry has always been about aspirations and image. But when it comes to environmental claims, the new message from EU regulators is clear: show us the evidence, or don’t make the claim at all<\/strong>.<\/p>\n About the Author<\/strong><\/p>\n Katerina Zouridaki is an EU cosmetic regulatory specialist and CEO of ELINEK S.A., with extensive experience in EU cosmetic safety assessment, regulatory compliance, and product documentation. She supports cosmetic brands across Europe in navigating complex legislative updates, including Omnibus Regulations, CLP classifications, and ingredient restrictions, ensuring safe and compliant products on the EU market.<\/p>\n Sources<\/strong><\/p>\n Directive (EU) 2024\/825 of the European Parliament and of the Council<\/strong><\/p>\n Directive 2005\/29\/EC (Unfair Commercial Practices Directive – UCPD)<\/strong><\/p>\n European Commission Study on Environmental Claims (2020)<\/strong><\/p>\nWhat the New Rules Mean for Cosmetic Brands<\/strong><\/h2>\n
Banned Claims and Practices<\/strong><\/h3>\n
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What Must Be Substantiated<\/strong><\/h3>\n
The Cosmetics-Specific Challenge<\/strong><\/h2>\n
The “Natural” Conundrum<\/strong><\/h2>\n
Organic Claims Under Scrutiny<\/strong><\/h2>\n
The Sustainability Label Landscape<\/strong><\/h2>\n
What About the Green Claims Directive?<\/strong><\/h2>\n
Real-World Impact: What Brands Must Do Now<\/strong><\/h2>\n
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The Business Case for Compliance<\/strong><\/h2>\n
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The Global Ripple Effect<\/strong><\/h2>\n
Conclusion: A New Era of Transparency<\/strong><\/h2>\n
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