Incoming EU anti-greenwashing directive pushes beauty toward sustainability substantiation

National laws implementing a new EU anti-greenwashing and consumer protection directive will come into effect on September 27 across all member states. The Empowering Consumers for the Green Transition (ECGT) Directive will introduce stricter guidelines related to environmental claims made about consumer products and outline clearer criteria for their substantiation and verification.

Directive (EU) 2024/825 — which bans generic environmental claims without sound substantiation — has direct implications for the personal care and beauty industry, as it regulates the credibility of sustainability claims across an increasingly complex beauty value chain.

Following the directive taking effect, sustainability labels will have to be based on third-party verified certification systems, claims around environmental benefits will be scrutinized to a greater extent, and generic claims associated with sustainability will require rigorous backing and credibility. 

According to the International Natural and Organic Cosmetics Association (Natrue), the directive aims to strengthen transparency and consumer confidence. It also aims to create a more equitable industry landscape for businesses that invest in environmental and social sustainability.

Personal Care Insights sits down with Viktoria Potko, global communications and PR manager at Natrue, ahead of the directive’s application date, to discuss its expected impact on cosmetics and personal care brands. 

Potko discusses the necessity for a directive of this caliber to bolster consumer protection and to steer the industry into making substantiated sustainability choices to remain competitive in an increasingly ecologically motivated market.

“For cosmetics and personal care brands, the ECGT Directive marks an important shift toward greater accountability in environmental communication,” says Potko. 

“This is particularly relevant to cosmetics, where products can involve complex supply chains and numerous environmental considerations, from raw materials and formulation to packaging, manufacturing, and distribution.”

The directive entered into force on March 26, 2024. Enforcement and penalties begin across the EU on September 27.

Against “vague” claims

EU rules push cosmetics brands toward more transparent sustainability claims.

After the directive takes effect this week, companies must ensure that environmental claims made to consumers are clear, specific, and substantiated, Potko tells us. Broad or vague statements such as “green,” “eco-friendly,” or “climate-friendly” will no longer be permitted without sufficient evidence. 

“The directive also addresses claims that give consumers the impression that an environmental benefit applies to an entire product when it actually relates only to a specific component or aspect,” she explains. 

For example, companies will no longer be able to claim that a product has a neutral, reduced, or positive climate impact when such claims rely solely on offsetting greenhouse gas emissions outside the product’s value chain.

Potko highlights the significance of the directive, stating that consumers should be able to distinguish between meaningful environmental performance and marketing language that is difficult to substantiate. 

“At the same time, credible sustainability communication should remain possible, because transparent information can encourage both more informed consumer choices and investment in better products.” 

Anticipating industry shifts 

Potko expects that the directive will have ripple effects in the industry and on how it approaches sustainability. In its mandate to make credible eco-friendliness claims, Potko projects that the directive will incentivize brands to explore their sustainability from multiple perspectives.

“As companies become more careful about what they can communicate, we may see greater investment in data collection, traceability, environmental assessment, and credible certification,” she says.

Beauty companies face stricter requirements for environmental marketing claims.

“It could also increase the value of certification systems that have clearly defined criteria and independent verification, because these provide a structured way of demonstrating that defined requirements have actually been met.”

She tells us that it is important that regulation remains proportionate and practical. Environmental assessment can be complex, particularly for SMEs, and requirements should avoid creating unnecessary duplication where robust evidence or recognized certification already exists, she underlines.

According to Potko, the directive is likely to encourage a move away from headline sustainability claims toward more specific and transparent communication.

“Companies will need to be much more careful with climate-related language based on carbon offsetting. The directive specifically prohibits claims that a product has a neutral, reduced, or positive climate impact when this is based on offsetting greenhouse-gas emissions outside the product’s value chain.” 

Potko expects that the new guidelines could also influence product development. If environmental performance needs to be demonstrated more precisely, companies have a stronger incentive to understand the environmental characteristics of their products throughout their development and supply chains, she explains.

“For the cosmetics sector, this could mean greater attention to ingredient sourcing, formulation choices, packaging materials, manufacturing processes, and other measurable aspects of environmental performance.”

How brands can comply

Potko tells us that brands should start their compliance process by reviewing the environmental claims they currently use across packaging, websites, advertising, social media, and other consumer-facing communications. 

New EU regulations aim to improve trust in sustainability labels.

“Each claim should have a clearly defined scope and appropriate evidence behind it. Where a claim relates to a particular ingredient, packaging component, manufacturing process, or other specific aspect, this should be communicated precisely rather than allowing consumers to assume that the benefit applies to the entire product.”

She also underlines that brands that stay on top of compliance demands for the directive will pay particular attention to future environmental commitments.

“Claims about future environmental performance cannot simply express an ambition. The directive requires such claims to be supported by clear, objective, publicly available, and verifiable commitments, measurable and time-bound targets, a realistic implementation plan, and independent verification.” 

One framework that can assist brands in assuring their compliance is independent certification. According to Potko, a credible certification scheme should have clearly defined and publicly available criteria, require evidence of compliance, and involve independent third-party verification.

“Under the ECGT Directive, certification schemes themselves are expected to meet defined transparency and independent-monitoring requirements,” she says.

“Sustainability labels will only be permitted going forward if they are either established by a public authority or run as a certification scheme with independent third-party verification, publicly available criteria, transparent and non-discriminatory access, and monitoring consistent with recognized standards, such as ISO 17065.” 

She says that self-declared sustainability labels without independent verification will face greater restrictions under the new framework. Potko believes brands should integrate recognized third-party certification into the product roadmap early, rather than seeking it retroactively once a claim is already on the market.

“Ultimately, companies should treat sustainability claims with the same discipline they apply to other regulated product information: define the claim, identify the evidence, establish its scope, and ensure that the communication accurately reflects what has actually been demonstrated.” 

Climate crisis policies

The cosmetics industry is already incrementally moving from claims-led sustainability toward evidence-led sustainability, and the ECGT Directive is set to further encourage and accelerate this broader shift as brands navigate compliance.

However, Potko underscores that it should be seen as one part of a much broader transition, rather than as a climate solution in itself.

Potko says the directive alone cannot reduce the emissions of the cosmetics industry.

“The value of the ECGT Directive is primarily in improving the quality of information available to consumers and the integrity of sustainability communication. It cannot by itself reduce the emissions of the cosmetics industry,” says Potko.

“But it can help prevent environmental claims from obscuring the real impacts of products, and it can encourage companies to substantiate and communicate genuine improvements. At the same time, consumers and businesses need reliable information if environmental considerations are to influence purchasing and product-development decisions.”

According to Potko, directives like the ECGT can contribute by making the sustainability information surrounding products more credible. However, meaningful climate progress will ultimately depend on the scale and speed of actual emissions reductions across the economy, she tells us.

“Whether the ECGT Directive becomes a global model remains to be seen. However, the underlying principle — that environmental communication should be credible, transparent, and verifiable — is relevant well beyond the EU. As sustainability regulation develops in different markets, greater convergence around these principles could make it easier for consumers and businesses to navigate an increasingly complex sustainability landscape,” she concludes.