EU Greenwashing Rules for Cosmetics: What Changes on 27 September 2026

Directive (EU) 2024/825 applies across the European Union from 27 September 2026. It bans generic environmental claims that cannot be substantiated, sustainability labels not based on a recognised certification scheme, and carbon-neutrality claims founded on offsetting. For cosmetic brands, the obligation attaches to how products are presented to consumers, not to when they were placed on the market.

Key facts

Item	Detail
Instrument	Directive (EU) 2024/825 of 28 February 2024, amending Directive 2005/29/EC (Unfair Commercial Practices) and Directive 2011/83/EU (Consumer Rights)
Published	OJ L, 2024/825, 6 March 2024 (CELEX 32024L0825)
Entered into force	26 March 2024
Transposition deadline	27 March 2026
Applies from	27 September 2026
Who is bound	Traders making business-to-consumer environmental claims in the EU — brand owners, importers and distributors alike
Enforceable text	National transposing law in each Member State, not the directive itself
Action required	Substantiate, amend or remove every environmental claim across packaging, website, advertising and retailer listings

Why this is not a labelling deadline

Regulation (EC) No 1223/2009 governs the moment a cosmetic product is placed on the EU market. Compliance is assessed against the product as launched, and stock lawfully placed on the market before a change generally benefits from a transitional period.

Directive (EU) 2024/825 does not work that way. It amends consumer protection law, and consumer protection law regulates commercial practices — how a product is presented to a consumer at the point of sale. The relevant question is therefore not when the product was manufactured, but whether the claim a consumer sees on 28 September 2026 complies.

This single distinction determines the scale of the exercise. A brand that reads this as an artwork deadline will update packaging for new production and consider itself compliant. In fact the obligation extends across every consumer-facing surface: existing stock on shelves, product pages, retailer listings, paid advertising, social content and point-of-sale material.

What is prohibited from 27 September 2026?

Three prohibitions matter most to cosmetic and personal care brands.

• Generic environmental claims without demonstrated excellent environmental performance. Terms of the “eco-friendly”, “environmentally friendly” or “green” type are prohibited where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. Vagueness itself is the defect — the claim is unlawful because it cannot be tested, not merely because it may be untrue.
• Sustainability labels not based on a certification scheme or established by public authorities. Self-created seals, house marks and internal scoring badges fall outside what is permitted. Any label displayed must rest on a certification scheme meeting transparency requirements with third-party monitoring, or be established by a public authority.
• Claims of neutral, reduced or positive environmental impact based on offsetting. A “carbon neutral” or “climate neutral” claim founded on the purchase of offset credits, rather than reductions within the product’s own value chain, is prohibited.

The directive also addresses durability, repairability and early obsolescence. Those provisions have limited application to cosmetics, which is worth stating explicitly: much of the published commentary on this directive is written for durable goods, and cosmetic brands reading it can reasonably conclude the regime is less relevant to them than it is.

Who is bound, and by which text?

Because this is a directive rather than a regulation, it creates no directly enforceable obligation on traders. Member States were required to transpose it into national law by 27 March 2026, and it is that national law which is enforced from 27 September 2026. Ireland, for example, transposed through the European Union (Empowering Consumers for the Green Transition) Regulations 2026, S.I. 124 of 2026.

The practical consequence for a brand selling across multiple Member States is that penalties, enforcement priorities and the availability of private civil claims are set nationally and are not uniform. A single EU-wide claims review establishes the substantive position; confirming exposure in a specific market requires reference to that market’s transposing instrument.

Does existing stock benefit from a grace period?

No grace period exists. On 30 June 2026 the Consumer Protection Cooperation Network published a Common Understanding on “old stock” situations, and the European Commission updated its Questions and Answers document to define old stock as products or packaging already manufactured, ordered, distributed or placed on retailers’ shelves before the application date.

Two points about that document are frequently misread. First, it is not a legally binding interpretation and does not create a transitional period; the prohibitions apply in full from 27 September 2026. Second, what it does is set out principles for proportionate enforcement — national authorities may decline to require destruction or recall where that would impose disproportionate cost or unnecessary environmental harm, provided the trader has made reasonable efforts toward compliance.

The distinction is between a defence and a discretion. A brand that has documented a claims review, corrected what it can and has a plan for the remainder is in a materially different position from one that has done nothing. Neither is exempt, but only the first can point to reasonable and proportionate effort. This also does not restrain private enforcement, where a competitor or consumer body brings action directly.

How this interacts with existing cosmetic claims rules

Cosmetic claims in the EU are already governed by Regulation (EU) No 655/2013, which sets common criteria for the justification of claims, and substantiation belongs in the Product Information File under Regulation (EC) No 1223/2009. Directive (EU) 2024/825 does not replace either. It adds a consumer-protection layer enforced by different authorities, under different procedures, with different penalties.

In practice this creates a documentation gap worth checking. A claim such as “97% natural origin” may be substantiated in the PIF to the satisfaction of a competent authority under 1223/2009 while remaining vulnerable under consumer protection law, because the consumer-facing presentation omits the qualification that makes the figure meaningful. The safety and substantiation dossier and the marketing estate are typically maintained by different teams, and the two rarely reconcile without being made to.

Where a claim is performance-based rather than environmental — efficacy, tolerance, sensory outcomes — substantiation runs through supporting test data and is unaffected by this directive. It is specifically the environmental and sustainability register that changes.

Recommended actions

• Inventory every environmental and sustainability claim across packaging, secondary packaging, website, product pages, retailer listings, advertising and social channels. The estate is almost always larger than the marketing team’s own record of it.
• Classify each claim into three groups: substantiated and defensible, capable of being made defensible by adding specificity, and requiring removal.
• Withdraw self-created sustainability seals unless they rest on a qualifying certification scheme. This is the fastest category to resolve and the most visually conspicuous.
• Identify any carbon-neutrality claim resting on offsetting and remove it. Reformulating the claim around measured reductions within the value chain is possible but requires data most brands do not currently hold.
• Obtain documented substantiation from packaging and raw material suppliers where a claim depends on their inputs. Responsibility for a claim sits with whoever communicates it to the consumer.
• Record the review itself — date, scope, decisions and remediation timetable. Under the CPC principles, evidence of reasonable and proportionate effort is what distinguishes one enforcement posture from another.

CosmeReg conducts EU claims audits across packaging and digital assets, reconciles consumer-facing claims against PIF substantiation, and acts as EU and UK Responsible Person for brands entering or already selling in these markets.

Frequently asked questions

When do the EU greenwashing rules apply to cosmetic products?

Directive (EU) 2024/825 applies from 27 September 2026. Member States were required to transpose it into national law by 27 March 2026. Enforcement is carried out under each Member State’s transposing legislation rather than under the directive itself, so penalties vary between markets.

Can cosmetic brands still use the word “natural” on packaging?

A claim is not prohibited because of the specific word used, but because it cannot be substantiated. “Natural” used generically and without accessible justification is at risk. The same claim expressed with a defined basis, a stated standard and a figure the consumer can verify is capable of being defended.

Does the directive apply to stock already on retailers’ shelves?

Yes. The directive regulates how products are presented to consumers rather than when they were placed on the market, so existing stock is within scope from 27 September 2026. The CPC Common Understanding of 30 June 2026 addresses proportionate enforcement for old stock but creates no grace period and is not legally binding.

Are own-brand sustainability logos still permitted?

Only where they are based on a certification scheme meeting transparency requirements with third-party monitoring, or established by a public authority. Seals created by a brand for its own products, without independent verification, are prohibited from 27 September 2026.

Does this replace the EU cosmetic claims regulation?

No. Regulation (EU) No 655/2013 on common criteria for cosmetic claims continues to apply, as does the substantiation requirement within the Product Information File. Directive (EU) 2024/825 adds a separate consumer-protection layer, enforced by different authorities under different penalties.

What happens if a claim cannot be substantiated before the deadline?

Remove it. Withdrawing an unsupported claim is materially less costly than defending an enforcement action or a private civil claim, and a documented decision to remove supports the reasonable-effort position that national authorities are expected to weigh under the CPC principles.