To address this issue, the European Union is strengthening its consumer protection framework through new legislation designed to combat greenwashing. While these rules apply across many sectors, they are particularly relevant for the cosmetics industry, where environmental messaging has become an important differentiator.
For manufacturers and brands, the message is clear: environmental claims will need to be backed by robust evidence, communicated transparently, and presented in a way that does not mislead consumers.
Why greenwashing has become a regulatory priority
Greenwashing refers to the practice of making environmental claims that are false, exaggerated, vague or impossible for consumers to verify. In some cases, the problem lies in the wording itself; in others, the claim may be technically true but presented without enough context, creating a misleading impression.
The European Commission has identified greenwashing as a significant obstacle to the transition towards a more sustainable economy. If consumers cannot distinguish between genuinely sustainable products and those marketed as such without sufficient evidence, trust in environmental claims is undermined and companies investing in sustainability may be placed at a competitive disadvantage.
Although the cosmetics industry has long been subject to strict rules on product claims under the Cosmetics Regulation and the Common Criteria for cosmetic claims, the new consumer legislation introduces an additional layer of scrutiny focused specifically on environmental marketing.
The Empowering Consumers Directive
The first major legislative development is Directive (EU) 2024/825, commonly known as the Empowering Consumers for the Green Transition Directive.
This legislation has already been adopted. Member States were required to transpose it into national law by 27 March 2026, and its provisions will apply from 27 September 2026.
The Directive amends existing EU consumer legislation by introducing clearer rules on unfair commercial practices related to environmental claims.
Among the practices receiving greater scrutiny are:
- generic environmental claims such as “green”, “environmentally friendly” or “eco” when they cannot be demonstrated;
- sustainability labels that are not based on recognised certification schemes or established by public authorities;
- claims suggesting that a product has a neutral, reduced or positive environmental impact when these rely solely on carbon offsetting;
- environmental claims that highlight only one positive aspect while omitting significant negative impacts.
The objective is not to prohibit environmental communication, but to ensure that consumers receive reliable, comparable and meaningful information before making purchasing decisions.
The Proposed Green Claims Directive
This proposal has not yet been adopted. It is still progressing through the EU legislative process, meaning that its final text may change before entering into force.
Nevertheless, the proposal provides a clear indication of the direction European regulators are taking.
Its central principle is straightforward: businesses making voluntary environmental claims should be able to substantiate them using recognised scientific evidence and transparent methodologies.
Among other requirements, the proposal would require companies to:
- support explicit environmental claims with robust scientific assessment;
- consider relevant environmental impacts throughout the product’s life cycle where appropriate;
- communicate claims clearly, avoiding ambiguity or selective presentation of information;
- undergo independent verification before many environmental claims are communicated to consumers.
The proposal would also establish stricter rules for environmental labels, seeking to reduce the growing number of private sustainability schemes that can confuse consumers rather than help them make informed choices.
A shift from marketing to evidence
Perhaps the most significant consequence of the new legislative framework is a cultural change in how environmental claims are developed.
Historically, sustainability messages have often originated within marketing departments. Under the emerging regulatory framework, environmental claims will increasingly require collaboration between regulatory affairs, quality, sustainability teams and scientific experts.
Every claim should be supported by documentation that explains:
- what exactly is being claimed;
- the evidence supporting the statement;
- the methodology used to reach the conclusion;
- any limitations or conditions that consumers should understand.
This shift is particularly relevant in the cosmetics sector, where environmental performance may involve complex factors such as ingredient sourcing, manufacturing processes, packaging design, transport and end-of-life management.
How cosmetic manufacturers can prepare
Although part of the legislative framework is still under discussion, companies do not need to wait before taking action.
A proactive review of existing environmental claims can help identify statements that may become problematic under the new rules.
Manufacturers may also benefit from strengthening internal procedures for claim substantiation, ensuring that marketing teams work closely with regulatory and technical experts before new sustainability messages are released.
Equally important is transparency. Consumers increasingly value credible environmental information, and regulators are making it clear that vague or aspirational language will no longer be sufficient.
