EU Green Claims Rules: What Cosmetic Brands Need to Change Before September 2026

The way cosmetic brands communicate sustainability in the European Union is about to change significantly.

From 27 September 2026, the provisions introduced by Directive (EU) 2024/825 – Empowering Consumers for the Green Transition (ECGT) will apply across the EU, introducing stricter requirements for environmental claims, sustainability labels and other green marketing practices.

For cosmetic companies, this means that packaging, websites, advertising materials and even certain product or brand names should now be reviewed.

EU Green Claims Rules: What Cosmetic Brands Need to Change Before September 2026

Generic environmental claims under scrutiny

One of the main changes concerns broad environmental statements such as:

• “Eco-friendly”

• “Green”

• “Environmentally friendly”

• “Ecological”

• “Biodegradable”

• “Climate friendly”

Under the new rules, generic environmental claims will only be permitted where they can be supported by recognised excellent environmental performance relevant to the claim.

More specific environmental statements may still be used, provided they are accurate, clear and sufficiently substantiated.

For brands, this means that moving from vague sustainability messages to specific and verifiable environmental information will become increasingly important.

It is not only about written claims

The concept of an environmental claim under the Directive is broad.

It can include text, but also pictorial, graphic or symbolic representations, as well as brand names, company names and product names where they communicate or imply an environmental benefit.

This is particularly relevant for cosmetic packaging.

Elements such as leaves, trees, water drops or other nature-inspired graphics are not automatically prohibited. However, when combined with environmental wording, sustainability logos or other green messaging, they may contribute to the overall environmental impression communicated to consumers.

The complete presentation of the product should therefore be considered when assessing compliance.

New requirements for sustainability labels

The Directive also strengthens the rules applicable to sustainability labels.

In general, voluntary sustainability labels presented to consumers will need to be established by a public authority or based on an appropriate certification scheme involving independent third-party verification.

Brands using their own environmental badges, seals or sustainability logos should therefore carefully assess whether these could qualify as sustainability labels under the new framework.

“Carbon neutral” claims are another key area

The rules also target claims suggesting that a product has a neutral, reduced or positive impact on greenhouse gas emissions where that claim is based on offsetting greenhouse gas emissions outside the product's value chain.

This can affect commonly used expressions such as “climate neutral” or similar product-level carbon claims where the claimed environmental benefit relies on offsetting rather than reductions associated with the product itself.

What happens on 27 September 2026?

EU Member States had until 27 March 2026 to transpose the Directive into national law, and the new provisions apply from 27 September 2026.

Importantly, companies should not assume that packaging produced before this date is automatically exempt.

In June 2026, EU Consumer Protection Cooperation authorities agreed on a common approach for dealing with existing or “old stock” displaying environmental claims or sustainability labels.

Authorities expect companies to take timely and good-faith steps towards compliance. However, genuine transitional difficulties may be considered on a case-by-case basis. Factors such as existing stock volumes, packaging production cycles, previous orders, supply-chain constraints and product shelf life may be taken into account.

This is particularly important for cosmetic companies, where packaging may be manufactured many months in advance.

Stickers and corrective measures may be possible

The EU approach does not necessarily mean that all existing products with potentially non-compliant environmental messaging will need to be destroyed or recalled on 27 September.

Depending on the circumstances, reasonable corrective measures may include:

• updating environmental claims on websites and e-commerce platforms;

• modifying advertising materials;

• changing future packaging runs;

• providing corrective information at the point of sale; or

• implementing other proportionate measures to address the problematic communication.

Authorities may avoid disproportionate actions such as product destruction or recalls where these would create excessive costs or unnecessary environmental impact.

What should cosmetic companies review now?

With the September deadline approaching, cosmetic brands selling in the EU should review their environmental communication across the entire consumer journey.

This should include packaging and labels, product and brand names, sustainability seals, websites, online marketplaces, social media, advertisements and other promotional materials.

Particular attention should be given to generic green claims, internally created sustainability badges, climate-related statements and environmental imagery used together with sustainability messaging.

The objective of the new EU framework is clear: environmental communication must become more specific, transparent and verifiable.

For companies preparing new artwork or packaging production, reviewing these elements before approving the next print run may avoid costly corrections after the rules become applicable.

Belab Services can support cosmetic brands in reviewing environmental claims, packaging and marketing materials against the new EU consumer protection requirements and identifying the necessary compliance actions before September 2026.