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Greenwashing in the European Union has shifted from being a reputational risk to becoming a compliance issue with a hard deadline. Directive (EU) 2024/825 tightens the rules on environmental claims and sustainability messaging across the European market, and its effective date of application, set for September 27, 2026, requires companies to back up any sustainability message they communicate with verifiable evidence.
What is greenwashing, and why is EU sustainability regulation acting now?
Greenwashing means presenting a product, service, or company as more environmentally friendly than it actually is, through vague, exaggerated, or outright unverifiable messaging. The European Commission found that a very high percentage of environmental claims analyzed across the European market lacked sufficient substantiation, which creates three concrete problems:
- Loss of consumer trust in “green” labels and messaging.
- Unfair competition between companies that genuinely invest in sustainability and those that merely communicate it.
- Growing regulatory risk, with penalties already being applied in several Member States.
The legislative response is Directive (EU) 2024/825 of February 28, 2024, which amends two existing directives: Directive 2005/29/EC on unfair commercial practices and Directive 2011/83/EU on consumer rights. Its technical name, Empowering Consumers for the Green Transition, sums up the goal well: giving consumers reliable information to compare products and make informed decisions.
What directive (EU) 2024/825 technically requires
1. The end of generic, unsubstantiated terms
Terms such as “eco”, “green”, “environmentally friendly”, or “sustainable” are prohibited unless accompanied by specific, accessible justification on the same medium where the claim appears (packaging, website, technical data sheet, or marketing material). Having the evidence in an internal report is not enough: it must be available to whoever reads the message.
2. Strict control of seals and certifications
Only certifications based on third-party verification systems that are transparent and publicly accessible are permitted. Sustainability seals created by the company itself, without independent external validation, are expressly prohibited – a practice that is currently relatively common in cosmetic packaging.
3. Restrictions on offset-based claims
Claims such as “carbon neutral” or “climate neutral” are no longer valid if they rely solely on the purchase of external offset credits or bonds, rather than an actual reduction of emissions within the product’s own value chain.
4. Greater transparency on durability and real impact
The Directive also expands disclosure obligations on durability, repairability, and software updates (relevant for products with an electronic component), and requires that any future sustainability pledge (“net zero by 2030”) be accompanied by a verifiable plan with intermediate targets.
5. Timeline: requirements and the directive’s date of application
This is the date every company should have marked in red:
- Directive’s entry into force: March 26, 2024.
- National transposition deadline: Member States were required to adopt and publish the provisions necessary to transpose the Directive into national law by March 27, 2026.
- Application and enforcement: the new rules will apply across the European Union from September 27, 2026. From that date, companies must comply with the national transposition provisions and may become subject to the measures and penalties set by each Member State.
As currently drafted, the text incorporates the main prohibitions and requirements of Directive (EU) 2024/825 on greenwashing, although it may still be subject to changes during the legislative process.
6. 2026 regulatory update: new guidance
In November 2025, the European Commission published a Q&A document clarifying the practical application of the Directive. In June 2026, the Consumer Protection Cooperation Network (CPC) also agreed on a common approach to the treatment of old stock: products and packaging manufactured, ordered, or already distributed before September 27, 2026.
There is no general exemption, but authorities may take into account reasonable adaptation efforts (corrective stickers, point-of-sale information, updates to digital communications). Neither document is legally binding, but both are the most current reference on how the rule will be applied.
Real Impact on Companies
With the application date in September 2026, no company in the chain is exempt:
Packaging manufacturers ahead of the September 2026 deadline
- Must be able to technically substantiate any claim of recyclability or material origin.
- The greatest risk lies in claims of biodegradability or compostability that are not verified under real-world conditions.
Cosmetics brands: managing greenwashing risk ahead of September 2026
- Greenwashing in cosmetics is one of the sector’s highest-risk areas, due to the intensive use of claims such as “natural,” “clean,” or “eco” on packaging and in advertising.
- A comprehensive review of all active sustainability claims is needed: packaging, INCI, website, technical data sheet, advertising.
- Marketing and regulatory teams must work from the same technical criteria, not in parallel.
Distributors and retailers ahead of the September 2026 deadline
- Bear responsibility for the accuracy of the information they display, even when the claim was originally generated by the manufacturer.
Cosmetic packaging greenwashing examples: clear cases in the cosmetics sector
To turn theory into concrete decisions, here are common patterns in cosmetics that the new regulation rules out:
- “99% natural formula” without a breakdown of what percentage corresponds to water (which in cosmetics often accounts for a large share of that figure) or a definition of what “natural” means under the relevant ISO standard.
- Claims such as “eco,” “green,” or “environmentally friendly” can be misleading when they are not based on demonstrably excellent environmental performance. The use of leaves, trees, green colors, or other visual devices can also convey an implicit environmental claim when, given the context, it suggests the product has environmental benefits that have not been substantiated.
- “Carbon neutral” on packaging when the claimed neutrality is based on offset credits generated outside the product’s own value chain.
- “100% recyclable packaging” when, in practice, the material combines plastics that cannot be separated at standard recycling facilities in the country of sale, or when a component (cap, applicator, seal) prevents the whole item from actually being recycled.
- Proprietary labels such as “Green Choice” or “Eco Certified” created by the brand itself, without accreditation from an independent body.
- Unverifiable sustainability comparisons, such as “cuts your footprint by 50%” without specifying against which reference product or under what calculation methodology.
In all these cases, the problem is the same: the company cannot back up its claims with data. This is exactly what Directive (EU) 2024/825 is beginning to penalize.
How to comply with EU sustainability regulation before the September 2026 deadline, without disrupting the business
Adaptation is not purely a legal exercise – it is, above all, an operational one. A realistic action plan involves:
1. Sustainability claims audit. Inventory all active environmental messages across packaging, website, and marketing material, and identify which ones lack documented support.
2. Technical validation. Support every claim that is kept with verifiable third-party data, testing, or certifications.
3. Internal alignment. Marketing and regulatory teams must share a single approval protocol for messaging before publication.
4. Supplier control. Require documented traceability from raw material and packaging suppliers, since responsibility also falls on whoever communicates the final claim.
5. Message reformulation. Replace generic rhetoric with specific, measurable statements: less “eco,” more data.
Cosmeservice offers a comprehensive claims audit service for the cosmetics sector, designed to have everything reviewed ahead of September 2026: documented technical validation, updated regulatory notifications, and ongoing monitoring of regulatory changes. The goal is to achieve compliance without slowing down sales or brand repositioning already underway.
Relationship with other european regulations
Directive (EU) 2024/825 does not operate in isolation. It’s worth considering it alongside:
- PPWR (Packaging and Packaging Waste Regulation): tightens requirements on recyclability claims and packaging reduction, with its own progressive application timeline.
- CSRD: requires certain companies to report sustainability impact in an auditable way, which reinforces the need for verifiable data in commercial claims as well.
- Proposed Green Claims Directive: its actual status is worth clarifying. In June 2025, the European Commission announced its intention to withdraw the proposal after part of the Parliament rejected it over its complexity, and negotiations have since stalled with no return date. This does not affect Directive (EU) 2024/825, which remains in force and is what sets the September 2026 date. The Green Claims Directive, if revived in the future, would add an additional verification framework, but today it is not an enforceable obligation.
The operational takeaway is clear: sustainability stops being a message and becomes verifiable data, with or without the Green Claims Directive.
Risks of failing to adapt to EU greenwashing rules
The penalties and other consequences of maintaining unsubstantiated claims go beyond the fine itself:
- Financial penalties, which in some Member States can reach significant percentages of annual turnover.
- Mandatory withdrawal of products or marketing materials.
- Loss of B2B customers who require traceability from their suppliers.
- Reputational damage that is difficult to reverse in a market increasingly attentive to environmental scrutiny.
- Exclusion from demanding supply chains that already require compliance documentation as a qualification requirement.
EU greenwashing is no longer optional
Directive (EU) 2024/825 marks a turning point in European sustainability regulation. With its application date set for September 27, 2026, every company that communicates environmental claims – from packaging manufacturers to cosmetics brands and distributors – needs to review its messaging before that date.
The rules can be summed up in three words: evidence, transparency, and verification. Companies that start now will not only avoid penalties – they will gain a real competitive advantage over those still communicating sustainability without being able to prove it.
FAQs
What does the September 2026 application of EU greenwashing rules mean?
That all sustainability claims must be validated with verifiable evidence from September 27, 2026, the date from which penalties can be imposed. Cosmeservice helps companies reach that date with everything audited and documented through a comprehensive service.
What are environmental claims under Directive (EU) 2024/825?
They are messages that communicate an ecological impact of a product or company. They must be specific, verifiable, and backed by data accessible on the same medium where they are communicated.
How do you comply with EU sustainability regulation?
Through a claims audit, technical validation, and alignment between marketing and regulatory processes. Cosmeservice covers the entire process, start to finish.
Can I still use terms like “eco” or “green” on my packaging?
Only if you can prove them with specific, accessible evidence alongside the message itself. Without that justification, the term is prohibited.
Who is affected by this regulation?
All companies operating in the EU that communicate environmental claims, with particular impact on cosmetics, packaging, and distribution, given the heavy use of sustainability messaging in these sectors.
What has happened with the Green Claims Directive?
The proposal has been stalled since June 2025 with no return date. This does not affect Directive (EU) 2024/825, which is the enforceable rule from September 2026 onward.
Where should I start?
With a full audit of current sustainability claims. With Cosmeservice, you can start with an assessment and a tailored action plan ahead of September 2026.
What happens to stock manufactured before September 27, 2026?
There is no automatic exemption, but authorities may take reasonable adaptation efforts into account during the initial application period, according to the CPC’s common understanding from June 2026.
References
- Directive (EU) 2024/825
- Directive 2005/29/EC
- Directive 2011/83/EU
- PPWR
- CSRD
- Proposed Green Claims Directive
- European Commission announcement on entry into force
- Circular Economy Action Plan (2020)
- European Commission Q&A on Directive (EU) 2024/825 (Nov. 2025)
- CPC common understanding on old stock (June 2026)
