Date: 30 September 2026

Prepared for: Importers, Manufacturers, Suppliers and Buyers of Cosmetic Products for the EU Market

Regulatory Update: EU Bans Generic Natural and Clean Beauty Claims from 27 September 2026

From 27 September 2026, the EU Directive on Empowering Consumers for the Green Transition (Directive (EU) 2024/825, "ECGT") applies across all Member States. Generic environmental claims widely used in the cosmetics industry, including "natural", "green", "eco-friendly", "sustainable", "biodegradable", "climate-friendly" and "clean beauty", are prohibited unless can demonstrate recognised excellent environmental performance relevant to the claim.

And Existing stock is not exempt from the new requirements. No transitional provision applies. Products already manufactured and already placed on the market must comply from 27 September 2026.

If your cosmetic products carry any of these claims on packaging or advertising, this change directly affects you.

Background:  

The ECGT was introduced in response to vague, unsubstantiated or misleading environmental claims in the European consumer market. While not a cosmetics-specific rule, it affects cosmetics significantly. With no legal definition of “natural” in EU cosmetics law, products are routinely marketed as “natural” without evidence of being greener than conventional alternatives.

What the ECGT Prohibits

The ECGT adds new prohibited practices to the “blacklist” in Annex I of the Unfair Commercial Practices Directive. These are unfair in all circumstances, so regulators do not need to prove consumer misleading case by case.

1. Generic environmental claims without specification or substantiation

Terms such as “natural”, “green”, “eco-friendly”, “sustainable”, “biodegradable”, “climate-friendly” and “clean beauty” are prohibited unless clearly supported by recognised excellent environmental performance. 

A self-declared environmental report, an internal sustainability score does not by itself satisfy this.

What counts “recognised excellent environmental performance”?

The ECGT requires that the environmental performance be relevant to the claim and recognised under a formal scheme such as:

l Regulation (EC) No 66/2010 (the EU Ecolabel Regulation); or

l National or regional EN ISO 14024 Type I ecolabelling schemes officially recognised in the Member States, such as the Nordic Swan or the Blue Angel; or

l Top environmental performance in accordance with other applicable Union law.

Brand names and product names are also covered. A product named “Natural Glow” or a brand named “Clean Beauty Co.” may constitute an environmental claim under the ECGT. Intellectual property protection does not exempt a name from scrutiny.

2. Claims about the entire product or business when only one aspect qualifies

A claim of environmental must disclose its scope. An ingredient-level or packaging-level benefit cannot be presented as a product-level or brand-level statement.

3. Sustainability labels without recognised certification

Sustainability labels created by a brand or industry are prohibited unless backed by a recognised certification scheme or established by public authorities. A label may still be assessed as an environmental claim if it suggests an overall positive or zero environmental impact.

4. Offset-based “carbon neutral” claims

Claims such as “carbon neutral”, “climate neutral” and “climate net zero” are prohibited if they rely on offsetting emissions outside the product’s value chain; permitted only with verifiable in-chain reductions. “Low carbon footprint” is not absolutely prohibited: with specific verifiable data it may be permitted as a specific claim. The prohibition applies to offset-based claims.

Timeline:  

What this means for you

1. Audit all existing claims immediately. Review every consumer-facing surface including product names, brand names, ingredient callouts, and icons, product pages, advertising, social media, website and point-of-sale material. Identify claims such as “Natural”, “clean”, “eco”, “green”, “sustainable”, “biodegradable” and “climate-friendly” as well as similar implications in brand or product names.

2. Specify or remove. Specific claims require accurate, clear and sufficient evidence. For generic claims, either specify the claim clearly or remove it.

3. Assess certification pathways. If you wish to retain a “natural” claim, COSMOS and NATRUE have confirmed that their certification programmes are recognised as independent certification schemes under the ECGT. Certified products may continue to display the corresponding claims.

4. Do not rely on the existing Cosmetic Claims Regulation alone. Claims must satisfy both the ECGT and Regulation (EU) No 655/2013, which requires claims to be truthful, evidential, honest, and fair.

5. Integrate evidence into your PIF. Environmental claim substantiation should be managed within the Product Information File under Responsible Person, so that evidence can be produced promptly during market surveillance review.

6. Note national penalties. Penalties can reach 4% of annual turnover in the Member States concerned. Enforcement is by consumer protection and competition authorities, not only by cosmetic market surveillance bodies.

For further information, the full text of Directive (EU) 2024/825 is available on EUR-Lex. The European Commission has published a Questions & Answers document on the ECGT Directive. Should you require support with claims compliance, please do not hesitate to contact us.

Reference: Directive (EU) 2024/825 of 28 February 2024 amending Directive 2005/29/EC and Directive 2011/83/EU as regards empowering consumers for the green transition

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