EU Greenwashing Rules: What's Changing for Cosmetic Brands?

Greenwashing in the Spotlight: What the EU's 2026 Rules Mean for Businesses

A Trust Problem Hiding in Plain Sight

Sustainability now shapes what people buy — and companies know it. That's why so many products today are wrapped in claims of being "green," "eco-friendly," or "climate neutral." But as these labels multiply, so does the temptation to stretch the truth. This practice, known as greenwashing, happens when businesses make environmental claims that are exaggerated, vague, or simply unprovable.

The European Commission looked closely at this problem in its review of environmental claims across the EU market, and the findings were sobering: a majority of the green claims examined were too vague, misleading, or poorly substantiated for consumers to trust at face value. That gap between marketing and reality is exactly what the EU's newest regulations are designed to close.

Why Brussels Is Cracking Down

Unsubstantiated sustainability claims do more than confuse shoppers — they tilt the playing field against companies that are actually investing in genuine environmental improvements. When claims can't be verified, consumers end up choosing products based on marketing spin rather than real impact.

The scale of the problem, as documented by the European Commission, is striking:

• Roughly half of green claims assessed were vague, misleading, or lacked adequate evidence
• About 40% came with no supporting evidence whatsoever
• More than 230 different sustainability labels exist across the EU, varying wildly in rigor and creating what's often called "label fatigue"

The EU's response is aimed at restoring a level playing field — one where genuinely sustainable businesses can compete on the merits of their actual practices, and consumers can trust what they read on a package or in an ad.

The Regulation to Know: Directive (EU) 2024/825

The centerpiece of this crackdown is the Empowering Consumers for the Green Transition Directive. EU member states had to fold it into national law by March 2026, and the substantive rules take effect 27 September 2026. From that date forward, environmental marketing across the bloc will be held to a materially higher standard.

A Shift from Reactive to Proactive Enforcement

Older green-claims rules typically stepped in only after a misleading ad was flagged or challenged — enforcement came after the fact. The 2026 framework flips that model. It goes after specific problem areas before they mislead anyone:

• Sweeping, undefined environmental buzzwords
• Claims of "climate neutrality" that rest entirely on carbon offsets rather than actual emissions reductions
• Self-designed sustainability labels with no independent verification behind them

Crucially, the burden of proof now sits with the business before a claim reaches the public. Companies must be able to substantiate what they say about their environmental performance up front — not scramble to defend it after a regulator or competitor objects.

What Changes for Companies Starting September 2026

Businesses operating in the EU should expect several concrete shifts:

1. Generic labels get harder to use. Terms like "green," "eco-friendly," or "environmentally friendly" won't be allowed unless the company can point to recognized, demonstrable environmental performance behind them.
2. Offset-only neutrality claims are out. You can't call a product "climate neutral" simply because you purchased carbon offsets — the claim needs to reflect real reductions.
3. Homemade labels lose credibility. Sustainability labels a company invents itself, without independent certification, will face new restrictions.
4. Everything must hold up to scrutiny. Messaging that overstates environmental benefits — even subtly — risks being classified as misleading.

For companies in the cosmetics sector especially, this raises the stakes on both regulatory compliance and the underlying evidence behind every claim on a label or ad.

What Happened to the Green Claims Directive?

It's worth clearing up a common point of confusion: the separate, more detailed Green Claims Directive — which would have added further verification requirements — was withdrawn in 2025. That withdrawal does not mean the EU has backed off greenwashing. The Empowering Consumers for the Green Transition Directive remains fully in force and will be the main compliance driver once the September 2026 deadline arrives.

Getting Ready: A Checklist for Businesses

With the deadline on the horizon, now is the time to take stock. Companies should:

• Audit product labels and packaging for unsubstantiated claims
• Review advertising and marketing materials line by line
• Cross-check sustainability reports and ESG disclosures against actual evidence
• Scrutinize digital and social content for outdated or exaggerated claims
• Build a documented evidence trail for every environmental statement made publicly

Getting ahead of these requirements isn't just about avoiding penalties. In a market where consumers are increasingly sustainability-savvy, being able to back up every claim you make is becoming a genuine competitive edge — not just a box to check.

The Bottom Line

The rules taking effect on 27 September 2026 mark a turning point in how environmental marketing is regulated across the EU. Businesses that move now to audit their claims, tighten their evidence, and align their messaging with the new standard will be far better positioned than those waiting for enforcement to catch up with them.

Freyr supports organizations navigating the EU's anti-greenwashing landscape — from claim reviews and compliance assessments to ongoing regulatory monitoring — so businesses can communicate their sustainability story with confidence and credibility.