Environmental claims on cosmetic packaging and marketing are about to face a much harder test. Directive (EU) 2024/825, known as the ECGT Directive (Empowering Consumers for the Green Transition), becomes fully applicable across the EU on 27 September 2026, and cosmetic brands are among the sectors most exposed to it.
The Directive amends two existing consumer protection laws, the Unfair Commercial Practices Directive and the Consumer Rights Directive. Its goal is straightforward: stop companies from making sustainability claims they cannot back up, and give consumers a reliable way to compare products.
What counts as an environmental claim
The definition is wider than most brands assume. An environmental claim is any statement, symbol, colour, image, or even a product or brand name that suggests a product has a positive or reduced environmental impact. A leaf on a label or a green colour scheme can qualify just as much as the word “eco” printed on the box.
Generic claims are effectively banned
Terms like “environmentally friendly”, “green”, “ecological”, “biodegradable”, “sustainable”, “natural”, or “recyclable” can no longer be used on their own. Under the new rules, a generic claim is only allowed if the company can demonstrate recognised excellent environmental performance, for example through compliance with specific EU legislation or applicable EN ISO standards.
There is a way to keep using these terms: the claim needs a clear, specific explanation on the same packaging, website, or advertisement where it appears. A vague label plus a footnote buried in a sustainability report elsewhere is not enough.
Two other practices are now banned outright. A brand cannot claim a benefit for an entire product or company when it really applies to one ingredient, one component, or one stage of production. And self-created sustainability seals, the kind many cosmetic brands have used on packaging for years without independent verification, are no longer permitted. Only labels backed by a recognised, transparent, third-party certification scheme will hold up.
Carbon neutral claims need real reductions
Claims such as “carbon neutral” or “climate neutral” can no longer rest on purchased offset credits alone. They need to reflect an actual reduction in emissions within the product’s own value chain. Forward-looking pledges, like a commitment to reach climate neutrality by a certain year, will also need a concrete implementation plan with measurable targets and independent verification behind them.
Old stock is not exempt
Products and packaging already manufactured, ordered, or sitting on shelves before 27 September 2026 are still covered by the new rules. The Consumer Protection Cooperation Network has published guidance recognising the practical difficulty of updating stock that is already in the distribution chain, and enforcement is expected to be phased and proportionate in the early stages. But there is no blanket exemption. Acceptable corrective steps include removing or correcting claims online, applying stickers to existing packaging, updating advertising and promotional material, adjusting future packaging orders, and displaying corrective information at the point of sale.
What this means in practice
For cosmetic brands, the most common exposure points are familiar ones: “99% natural” or “natural ingredients” claims that don’t account for water content or define what “natural” means, “vegan” or “clean” used as a stand-in for a broader sustainability story it doesn’t actually support, “eco” or “green” packaging language with nothing behind it, “recyclable packaging” claims where a cap, seal, or mixed material actually stops the item being recycled in practice, self-designed leaf icons or in-house labels like “Green Choice” with no independent certification behind them, and carbon neutrality claims tied to offsetting rather than genuine reduction.
The practical response is an audit of every environmental claim currently in use, across packaging, INCI declarations, the website, and advertising, followed by a decision for each one: drop it, rework it with a specific and substantiated explanation, or replace generic wording with a certified label. Marketing and regulatory teams working from the same evidence, rather than approving claims separately, will matter more under this Directive than it has under previous rules.
With less than two weeks left before the deadline, reviewing environmental claims now, rather than after enforcement begins, is the difference between a manageable update and a scramble.
