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The withdrawal of the Green Claims Directive in 2023 did not mark the end of regulatory scrutiny over environmental claims. For cosmetic brands operating in the EU, sustainability messaging remains under increasing regulatory pressure today.
Although the original proposal was formally withdrawn, its objectives are still being actively pursued through existing EU consumer protection legislation. As a result, green, natural and eco-friendly claims continue to be closely examined, even in the absence of a standalone Green Claims Directive.
Background: the withdrawal of the Green Claims Directive
On 22 March 2023, the European Commission published COM(2023)166 final, its original proposal for the Green Claims Directive. Following extended negotiations, the Commission withdrew this proposal in June 2025, reflecting shifting regulatory priorities, growing overlap with other EU legislation, and a strategic move toward consolidating sustainability enforcement under horizontal legal frameworks.
Rather than eliminating control over environmental claims, the withdrawal aimed to avoid regulatory duplication while maintaining enforcement through existing rules.
For cosmetic brands, especially those marketing natural, organic, or eco-friendly products, this regulatory shift continues to shape how environmental messages are assessed and challenged in practice.
Why was the Green Claims Directive withdrawn?
The Green Claims Directive was originally intended to address misleading environmental claims, often referred to as greenwashing, by requiring companies to substantiate sustainability messages with clear, science-based evidence.
However, by 2023, several developments made a standalone directive less necessary:
- The Unfair Commercial Practices Directive (UCPD) was already being revised to address vague, misleading or unverified environmental claims.
- The Empowering Consumers for the Green Transition initiative introduced similar obligations within a broader, cross-sector legal framework.
- The European Commission acknowledged the growing regulatory burden and potential fragmentation, particularly for sectors like cosmetics, where sustainability intersects with safety, labelling and marketing requirements.
In this context, the Green Claims Directive became redundant, not obsolete. Its withdrawal was designed to streamline enforcement rather than weaken it.
What does this mean for the Cosmetics industry today?
The absence of a dedicated Green Claims Directive does not mean environmental claims are less regulated. Quite the opposite. Sustainability messaging is now assessed under more centralised and widely applicable consumer protection rules.
For cosmetic products, this translates into:
- Stronger enforcement of sustainability-related claims under the Unfair Commercial Practices Directive, especially for generic or absolute terms such as “eco”, “green” or “natural”.
- Increased scrutiny of labelling and marketing practices, particularly where products position themselves as environmentally responsible alternatives.
- Higher expectations for claim substantiation, even without a cosmetics-specific environmental claims law.
Regulators are clearly moving toward horizontal enforcement models, where one sustainability rule applies across multiple sectors. Cosmetic brands should not assume that the withdrawal of the directive results in fewer obligations or lower enforcement risk.
Timeline and regulatory context
The draft withdrawal published in March 2023 formed part of the European Commission’s broader simplification agenda. Rather than introducing new sector-specific legislation, the EU has focused on strengthening the application of existing frameworks, including:
- Directive 2005/29/EC on Unfair Commercial Practices (UCPD)
- A potential future Green Claims proposal, which would need to be reintroduced by the Commission before any substantiation principles become binding – as of today, there is no confirmed timeline for this.
In other words, while the legal form has evolved, the regulatory expectations around environmental claims are already being enforced.
How should cosmetic brands act now?
Given the current enforcement landscape, cosmetic companies should already be treating environmental claims with the same level of scrutiny as ingredient safety or labelling compliance.
Key actions include:
- Auditing all green marketing claims to ensure they are factual, specific and verifiable.
- Maintaining robust documentation supporting sustainability claims, including lifecycle data or third-party certifications.
- Avoiding vague or generic terms such as “eco”, “sustainable” or “planet-friendly” unless these are clearly explained on-pack or online.
- Training marketing and commercial teams to align communications with current EU consumer protection requirements.
Waiting for new legislation is no longer a viable strategy. Enforcement is already happening under existing rules.
Stay ahead of cosmetic compliance with Cosmeservice
At Cosmeservice, we support cosmetic brands in meeting EU regulatory expectations, from labelling and advertising review to INCI and ingredient claims evaluation. As sustainability claims face increasing scrutiny across the EU, proactive verification and compliance-driven messaging are becoming essential. Our team can assist with:
- Reviewing and substantiating environmental claims
- Identifying compliance risks in marketing language
- Aligning sustainability messaging with UCPD requirements and monitoring any future EU Green Claims proposal
If you need support reviewing your sustainability claims, contact our team at info@cosmeservice.com.
FAQs
Is COM(2023)166 the withdrawal of the Green Claims Directive?
No. COM(2023)166 final, published on 22 March 2023, is the European Commission’s original proposal for the Green Claims Directive. The Commission withdrew this same proposal later, in June 2025, following political pushback over its scope and impact on small businesses.
Does the withdrawal of the Green Claims Directive mean environmental claims are no longer regulated in the EU?
No. The withdrawal removes a standalone, cosmetics-relevant law, but sustainability claims remain enforceable under existing legislation, particularly the Unfair Commercial Practices Directive (UCPD) and the Empowering Consumers for the Green Transition framework.
Can cosmetic brands still use terms like ‘eco’ or ‘natural’ in the EU?
Only if the claim is specific, factual and verifiable. Generic or absolute terms such as “eco”, “green” or “natural” face increased scrutiny under the UCPD when they are not clearly substantiated on-pack or online.
Will the EU introduce a new Green Claims law in the future?
Possibly, but there is no confirmed timeline. Any future Green Claims proposal would need to be reintroduced and negotiated by the Commission, Parliament and Council before becoming binding, following the same legislative process as the withdrawn 2023 proposal.
How should cosmetic brands prepare if there is no Green Claims Directive?
Brands should treat environmental claims with the same rigour as ingredient safety or labelling compliance: auditing all green marketing claims, keeping documentation such as lifecycle data or third-party certifications, and training marketing teams on current UCPD requirements.
