The EU cosmetics greenwashing directive—Directive (EU) 2024/825—will reshape how cosmetic products marketed in the European Union communicate environmental benefits. From 27 September 2026, many environmental claims that regularly appear on cosmetic labels, e-commerce pages and advertising will be prohibited unless they meet strict new conditions.
For cosmetics manufacturers, brand owners, importers, responsible persons and safety assessors, this is not a narrow packaging issue. It affects product positioning, marketing content, sustainability labels, artwork approvals and existing stock already in the distribution chain.
Cosmetic products placed on the EU market already have specific labelling obligations under Regulation (EC) No 1223/2009. Directive (EU) 2024/825 adds a separate layer of green claim controls that sits alongside those product-specific requirements.
COSlaw has published a detailed update on the new rules, noting that Directive (EU) 2024/825 was adopted in February 2024 and amends both the Unfair Commercial Practices Directive and the Consumer Rights Directive. You can read the original overview in the COSlaw guidance on environmental claims after 27 September 2026.
What the EU cosmetics greenwashing directive introduces
Directive (EU) 2024/825 establishes safeguards to regulate environmental claims and sustainability labels. It does this by amending the Unfair Commercial Practices Directive and expanding the blacklist of commercial practices prohibited in all circumstances under Annex I.
Three new prohibited practices are particularly relevant for cosmetics businesses:
- Displaying a sustainability label that is not based on a recognised certification scheme;
- Making an environmental claim concerning an entire product or business where the claim relates only to a specific aspect or activity;
- Making a generic environmental claim without being able to demonstrate recognised related excellent environmental performance.
Because these practices are blacklisted in Annex I, they are considered unfair commercial practices in all circumstances. A business cannot defend them simply by arguing that the overall impression was not misleading or that other information was available elsewhere.
The cosmetics sector is particularly exposed because products are often marketed through short on-pack statements, visual cues and online product descriptions. A cream described as “green” or a shampoo presented with nature imagery may trigger the same analysis even if no detailed environmental statement is made.
How the new rules define environmental claims
What counts as an environmental claim?
Under the EU cosmetics greenwashing directive, an environmental claim is any representation that states or implies that a product, category, brand or trader has a positive or zero environmental impact, is less harmful than comparable products, or has improved its impact over time.
This definition is not limited to express statements. It also includes implicit environmental messages created through symbols, colours, images or other visual elements. Product or brand names that may lead the average consumer to expect an environmental benefit can also qualify as environmental claims.
In practice, a cosmetic jar with a leaf icon, a predominantly green label or a product name such as “Eco” or “Bio” may fall within the scope of the directive. Marketing teams should treat visual identity as part of the claims review, not as a separate branding question.
Recognised excellent environmental performance
A key change is the prohibition of generic environmental claims unless the trader can demonstrate recognised excellent environmental performance. Examples of claims that may be considered generic include “environmentally friendly”, “green”, “ecological” and “biodegradable”.
According to the Commission guidance cited by COSlaw, recognised excellent environmental performance can be demonstrated by compliance with specific Union laws, and with applicable national or regional EN ISO standards.
A claim may not be treated as generic where relevant specifications are clearly and prominently explained on the same medium. That means the specific information can appear directly on the product packaging, website, advertisement or other communication where the claim is presented.
This same-medium explanation is important for online listings. A general claim on a product page should be accompanied by the specific environmental benefit and the basis for it on the same page, rather than in a separate document or a different part of the website.
Compliance impact on cosmetic products and existing stock
One of the most operationally significant points for cosmetics brands is that the new rules will not apply only to new products placed on the market after 27 September 2026. They also cover products and packaging already manufactured, ordered, distributed or on retailers’ shelves before that date.
This includes existing stock and so-called old stock situations. The Consumer Protection Cooperation Network has issued a Common Understanding document on how the rules should be enforced in these cases.
Corrective measures that traders may use include:
- Removing or correcting claims appearing online;
- Using stickers or similar relabelling solutions;
- Updating advertising and promotional materials;
- Adapting future packaging designs and new orders;
- Displaying corrective information at physical or online points of sale.
Old stock products are not exempt from the requirements. However, competent authorities may adopt a phased and proportionate approach during the initial stages of application. Businesses are still expected to take all reasonable measures to achieve compliance by 27 September 2026.
For a brand with long shelf-life products, seasonal gift sets or multi-market packaging, this means that compliance planning should include an inventory review well before the deadline. Products ordered now may still be in circulation after the application date if they have a long shelf life or if distribution timelines extend beyond September 2026.
Practical steps for cosmetics brands before September 2026
Because the EU cosmetics greenwashing directive applies to products already in circulation, waiting until the deadline is a compliance risk. A structured review should start now.
Audit environmental claims
Catalogues of packaging, labels, product listings and marketing assets should be reviewed for terms such as green, ecological, environmentally friendly or biodegradable. The assessment should consider whether the claim is generic, what evidence is available, and whether the claim concerns the whole product or only one attribute.
Teams should also review visual elements. Green colour palettes, leaf symbols, nature imagery and product names can create implicit environmental messages even when no express claim appears.
The review should be documented. For each claim, record the wording, the medium, the specific benefit, the supporting evidence and the decision on whether to retain, modify or remove it. This documentation can support later enforcement discussions and helps align internal stakeholders.
Check sustainability labels
Any sustainability label used on cosmetic packaging or in marketing should be based on a recognised certification scheme. If the scheme cannot be identified or verified, the label should be removed or replaced before the deadline.
This check should cover both primary packaging and secondary packaging, as well as e-commerce badges and retailer listing information. A label that appears only in online marketplaces is still a commercial practice within the scope of the directive.
Align EU and UK market access documentation
The source update focuses on EU law, but UK-based brands and responsible persons selling into the EU must meet the same EU requirements for products placed on the EU market. Brands managing multiple markets should treat this as part of EU market access rather than a purely local packaging issue.
If internal resources are limited, working with a cosmetic compliance services partner can help review claims, labels and supporting documentation across EU and UK market access requirements.
What cosmetics businesses should monitor next
The application date of 27 September 2026 is fixed. Cosmetics businesses should monitor updates from the European Commission, the CPC Network and national consumer protection authorities.
In particular, companies should watch for further clarification on how to demonstrate recognised excellent environmental performance, how national authorities treat visual and implicit claims, and how the common understanding on old stock is applied in practice.
Internal procedures should also be updated so that future packaging development, artwork approval and e-commerce copywriting include a green claim compliance check before launch. The easiest claims to defend will be specific, verifiable and explained in the same medium where they appear.
Conclusion
The EU cosmetics greenwashing directive changes the burden of proof for environmental marketing. Cosmetics businesses should not wait for enforcement action to correct claims that will be unlawful from 27 September 2026.
Prepare now: environmental claims on cosmetic products must meet EU greenwashing rules by 27 September 2026.