EU environmental claims: Directive (EU) 2024/825 applies from 27 September 2026
Environmental claims can describe meaningful choices made by a cosmetic brand. They also need to tell consumers precisely what those choices concern.
A statement about recyclable packaging should not create an unsupported impression of the product’s environmental performance. Similarly, a broad description like “green” may raise questions if the brand cannot define and demonstrate the claimed benefit.
This is especially relevant now. From 27 September 2026, Member States apply the measures transposing Directive (EU) 2024/825, which strengthens protection against misleading practices related to the green transition.
For brands, claim reviews should extend beyond labels to websites, campaigns, product pages, and social media. The practical test is to read each message as a consumer would:
What does it promise? Does the evidence support that impression?
At CEway, we see claim substantiation as part of the product’s regulatory documentation. Clear evidence gives teams a sound basis for communicating specific environmental benefits accurately.
Octocrylene: SEAC adopts its final opinion on the proposed REACH restriction
The regulatory discussion around octocrylene has moved forward. At its 15–16 September 2026 meeting, ECHA’s Committee for Socio-Economic Analysis (SEAC) adopted its final opinion on the REACH restriction proposal submitted by France.
This development matters to companies with sunscreens and other cosmetics containing octocrylene. It does not change the legal conditions for placing those products on the market. A proposed restriction must complete remaining regulatory steps before new requirements apply.
The most useful action now is to identify which products contain octocrylene, where they are marketed, and which teams must respond if the proposal becomes law. This preparation can continue alongside assessing products against current requirements.
Silver in cosmetics: Commission draft proposes additional permitted uses
A European Commission draft could create additional possibilities for silver powder in cosmetics. However, its scope is tightly defined:
The proposal concerns porous, sintered silver powder with particles between 100 nm and 1 mm, not silver in every form.
The proposed maximum concentrations are 0.2% in rinse-off products, 0.3% in leave-on and nail products, 0.2% in oral products and 0.05% in children’s mouthwash.
The draft would also permit its use as a colourant in leave-on and nail products at up to 0.3%. Products that could expose the lungs through inhalation would remain excluded.
This may be welcome news for brands reviewing silver-containing products after Omnibus Act VIII. Before considering a product against the proposed limits, confirm the ingredient’s particle specifications, product category, and usage.
The amendment remains a draft. The final published text will determine whether, and under which conditions, these additional uses are permitted.
EUDR: updated Annex I brings additional palm oil derivatives into scope
The EU Deforestation Regulation (EUDR) is increasingly relevant to cosmetic ingredient supply chains. In July, the European Commission adopted a delegated act updating Annex I to include certain additional palm oil derivatives. Such materials can sit upstream of ingredients used in a wide range of cosmetic products.
The EUDR covers products linked to commodities like palm oil. Its requirements include evidence that these products are deforestation-free, supported by traceability to the production area. A supplier’s general sustainability statement or certification should not automatically substitute the information required under the Regulation.
A key question for brands is whether a purchased ingredient falls under an Annex I product code and which business is responsible for placing that material on the EU market. A palm-derived ingredient does not automatically bring the finished cosmetic within Annex I. However, it can increase the importance of the brand’s ingredient supply chain reliability.
The EUDR generally begins to apply on 30 December 2026 for large and medium-sized operators and on 30 June 2027 for most micro and small operators. According to the Commission, products newly added by the July delegated act would be covered from 30 December 2027, subject to completion of the act’s scrutiny process.
A useful first step is to ask suppliers for the ingredient’s origin and classification, whether it falls within Annex I, and how they will provide the required traceability information. This turns a broad supply chain concern into a review of specific materials and responsibilities.
PPWR: application begins under the EU packaging regulation
The Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40 (PPWR) began to apply across the EU on 12 August 2026. Its requirements have different implementation dates, so cosmetic companies need to identify which obligations apply to their packaging and when they take effect.
A practical starting point is to establish a clear record of the packaging used across the product portfolio. This includes identifying each packaging component, its material composition, and the documentation already available from suppliers.
Three questions can guide this initial review:
- What packaging do we use? Map the packaging components associated with each product.
- What is it made of? Confirm material specifications with suppliers.
- What information do we already hold? Review existing documentation and identify missing or incomplete data.
Collecting this information helps companies assess relevant requirements, request additional supplier documentation, and plan updates against applicable deadlines.
For cosmetic brands, coordinate packaging compliance with product documentation and regulatory planning. Establishing a reliable information base now will make subsequent assessments and supplier discussions more efficient.
