Greenwashing in Cosmetics: How to Avoid Misleading Green Claims

Greenwashing in cosmetics is about to stop being a reputational risk and start being a legal one. From 27 September 2026, Directive (EU) 2024/825 — the Empowering Consumers for the Green Transition Directive, known in the industry as EmpCo or ECGT — applies across the EU. It bans a list of vague environmental claims outright and puts the burden of proof on the brand for everything else.

For cosmetic brands this is a bigger deal than it first looks, because green language is everywhere on beauty packaging: “eco-friendly”, “climate neutral”, “ocean-safe”, “clean beauty”, a leaf icon on a carton. Much of it will simply be unlawful in eight weeks’ time, and unlike a new ingredient restriction there is no long transition. This guide sets out exactly what changes, which claims are now banned outright, how to substantiate the ones you keep, and what to do with stock already on shelves.

Why the rules changed

The European Commission’s own screening of environmental claims found that a majority were vague, misleading or unsubstantiated, and that a large share of environmental labels had weak or non-existent verification behind them. Cosmetics were among the worst affected categories, partly because “natural”, “clean” and “eco” have no legal definition and partly because the category leans heavily on emotional, values-led marketing.

Rather than write a new cosmetics-specific rule, the EU amended horizontal consumer law. Directive (EU) 2024/825 entered into force on 27 March 2024 and edits the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive. That matters for two reasons: it applies to every consumer-facing sector at once, and it is enforced by consumer protection and competition authorities — not only by the cosmetic market surveillance bodies you may already deal with.

What is banned outright

The directive adds new entries to the “blacklist” in Annex I of the Unfair Commercial Practices Directive. Blacklisted practices are unfair in all circumstances — there is no case-by-case assessment and no defence based on how you meant it.

Generic environmental claims without proven excellence

Claims such as “environmentally friendly”, “eco”, “green”, “nature’s friend”, “gentle on the environment” or “biodegradable” used in a broad, unspecific way are prohibited unless you can demonstrate recognised excellent environmental performance relevant to the claim. In practice, that means an EU Ecolabel or an equivalent officially recognised scheme — not your own life cycle assessment, however good it is.

Offset-based carbon neutrality claims

Claiming that a product is “carbon neutral”, “climate neutral”, “CO2 positive” or “climate compensated” on the basis of greenhouse gas offsetting is banned. You may still talk about genuine reductions in your own footprint, and you may still buy offsets — you simply cannot present the product to consumers as neutral because of them.

Whole-product claims that only apply to a part

Presenting an environmental characteristic of one component as if it applied to the whole product is prohibited. A carton made from recycled board does not make the product “recycled”; a recyclable cap does not make the pack “recyclable”.

Legal requirements dressed up as features

Advertising something the law already requires as if it were a distinguishing benefit is banned. In cosmetics the obvious example is “not tested on animals” or a cruelty-free hero claim: animal testing for finished cosmetics and their ingredients has been prohibited in the EU since 2004 and 2009 respectively, so presenting it as a brand differentiator on an EU-market product is problematic.

Unverified sustainability labels

Displaying a sustainability label that is not based on a third-party certification scheme, or established by public authorities, is prohibited. Self-created leaf logos, green scoring badges and in-house “eco” seals fall foul of this unless they sit behind a proper certification scheme with monitoring.

The rules for claims you keep

Anything not blacklisted is still permitted — but it must be specific, accurate and substantiated. The practical test is whether an average consumer could be misled, and the practical defence is a documented evidence file.

The underlying discipline is the same one that already applies to every other cosmetic claim under Regulation (EU) No 655/2013 and its common criteria — legal compliance, truthfulness, evidential support, honesty, fairness and informed decision-making. If you have not been through that exercise, start with our guide to what cosmetic claims are allowed in the EU, because green claims are simply a subset of it with extra teeth.

Where the evidence lives: your PIF

This is the part brands most often miss. A green claim is a cosmetic claim, and under Article 11 of Regulation (EC) No 1223/2009 the Product Information File must contain proof of the effect claimed where justified by the nature of the claim. A market surveillance officer asking to see your file is entitled to see the substantiation for “98% natural origin” in the same breath as your safety data.

In practice that means your PIF should hold, per product: the exact claim wording as it appears on pack and online, the standard or method used, the calculation, the supporting supplier documents, and a dated sign-off. Keeping this in a marketing folder instead of the regulatory file is a common and avoidable finding. Our overview of PIF requirements and PIF preparation guide set out how the file is structured.

National layers on top: France and Italy

The directive is a floor, not a ceiling, and two markets already go further on environmental communication.

France combines the AGEC law’s Triman and Info-Tri sorting information with tight restrictions on environmental wording — the terms “biodégradable”, “respectueux de l’environnement” and equivalents are already prohibited on packaging and in advertising for products subject to extended producer responsibility. Our guides to Triman and Info-Tri and French cosmetic compliance cover the detail.

Italy transposed 2024/825 through Legislative Decree No 30 of 20 February 2026, and layers it on top of the existing environmental labelling obligation under Legislative Decree 116/2020, which requires packaging material coding and consumer sorting instructions. Italy has been explicit that the new provisions apply to existing stock from 27 September 2026.

What to do before 27 September 2026

Eight weeks is enough time if you start with an inventory rather than a redesign.

1. Build a claims register

List every environmental word, icon and badge across every SKU and every channel. Include tiny things: a green leaf, a globe symbol, “made with love for the planet”. You cannot triage what you have not written down.

2. Sort into three buckets

Blacklisted (remove now), substantiable (gather evidence and make specific), and unnecessary (drop it — most brands find a third of their green language adds nothing commercially and carries all of the risk).

3. Fix artwork and digital in the right order

Digital channels can be corrected in days and are the easiest enforcement target, so fix the website and marketplace listings first. Artwork changes then follow your normal print cycle. Combine any green-claim artwork change with other pending label work — the expanded fragrance allergen declarations are running on a parallel timeline, and doing two artwork rounds is a waste of money.

4. Document the decision

File the register, the evidence and the sign-off in the PIF. If a claim survives your review, the reasoning should survive with it.

Bringing it all together

Greenwashing enforcement in the EU has moved from soft guidance to blacklisted practices with turnover-based penalties, and cosmetics is squarely in the frame because the category talks about nature more than almost any other. The good news is that the remedy is mostly editorial: strip out the vague words, keep the specific ones, and be able to prove them from a file rather than from a brief.

The brands that will come out of September ahead are the ones treating this as a claims-substantiation project rather than a packaging emergency. A specific, evidenced claim is not only lawful, it converts better than a generic one — “96% ingredients of natural origin under ISO 16128” tells a consumer something, while “eco-friendly” tells them nothing and now costs you money.

Lexora reviews cosmetic labels and marketing claims against both the Cosmetic Regulation and the new green-claims rules, and files the substantiation into your PIF where it belongs. Start with our cosmetic label review service, or take the whole documentation set in one go with the Full Compliance Pack.