What the ECGT Directive means for cosmetics

From 27 September 2026, Directive (EU) 2024/825 applies across the EU, introducing new requirements for environmental claims and sustainability labels. For cosmetics brands, the changes affect everything from generic “green” wording and certification labels to climate claims, product names and future sustainability commitments. This article examines what changes in practice and what companies need to review in their consumer communication.

Environmental language has become commonplace in cosmetics marketing. Terms such as “natural”, “clean”, “green”, “biodegradable” and “planet-friendly” appear frequently on packaging, often alongside visual cues such as leaves, droplets and earth-toned colour palettes. Cosmetic claims are already subject to EU requirements on evidence, honesty and fairness. However, terms such as “natural” and “organic” still have no harmonised legal definition for cosmetic products at EU level.

From 27 September 2026, Directive (EU) 2024/825 – the Empowering Consumers for the Green Transition Directive (ECGT, sometimes “EmpCo”) – adds a new layer of consumer-protection rules governing how environmental claims and sustainability labels must be communicated.

Why were the rules needed

The starting point for the legislation was a trust problem. A 2020 Commission screening of environmental claims in the EU found that more than half (53%) gave vague, misleading or unfounded information, and that 40% were not supported by any evidence.² Those figures were the political backdrop to the Directive, which the EU adopted in February 2024.³

Greenwashing is harmful in two ways. Consumers who can’t distinguish a substantiated claim from a marketing slogan end up making decisions that don’t reflect their values. And companies that invest in real improvements – in formulation, sourcing, certification, and manufacturing – compete on the shelf with companies that simply use the same words without justification. As NATRUE’s President, Prof. Dr. Florian Stintzing, puts it: “Greenwashing is particularly harmful because it can create confusion and make it difficult for consumers to distinguish genuine sustainability from marketing claims.”⁴

What the ECGT actually is

The ECGT is an amending directive. It changes two existing pieces of EU consumer law: the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive. Several features of the design matter for cosmetics.

It regulates communication, not composition. The Commission’s Q&A is explicit that the UCPD does not regulate the intrinsic characteristics or composition of goods; it looks at how they are presented to consumers.⁵ A formulation is not “illegal” because of what it contains under this Directive. What the packaging, website and advertising say about it is what is questioned.

It introduces new rules for sustainability labels, not only for claims. Alongside what companies say in words, the ECGT also regulates the trust marks, quality seals and logos they put on packaging.

It works on two levels. Some practices are added to the UCPD’s “blacklist” (Annex I), meaning they are prohibited in all circumstances, with no need to show that a consumer was misled. Others are added to the general misleading practice provisions and assessed case by case.⁵

It sits on top of sector rules, not in place of them. Cosmetics already have claim-specific requirements under the Cosmetics Regulation and the common criteria for cosmetic claims, which require that claims be supported by evidence, honest and fair.⁶ The ECGT is a horizontal safety net that complements these.

Two further points of scope. The rules apply to business-to-consumer communication only, so a corporate sustainability report is generally outside the Directive, although the moment a company reuses its content in voluntary marketing to consumers, it is in scope. Enforcement sits with national authorities, through the national laws transposing the UCPD. Competitors and consumer organizations with a legitimate interest can also take their own legal action – for example, to have a misleading claim stopped by a court – and infringing traders can face fines.

Six changes that matter for cosmetics

1. Generic environmental claims are prohibited

The most visible change is a blacklist ban on generic environmental claims unless the trader can demonstrate “recognized excellent environmental performance” relevant to the claim (Annex I, point 4a).

A generic claim is an environmental claim in written or oral form where the specification is not given “in clear and prominent terms on the same medium.” The Directive’s recitals give examples that include “environmentally friendly,” “eco-friendly,” “green,” “nature’s friend,” “ecological,” “climate friendly,” “gentle on the environment,” “biodegradable” and “biobased.” For cosmetics, we would add the words that companies use as near-synonyms: “planet-friendly,” “sustainable,” “responsible.” The Directive’s recitals explain that terms like “sustainable” and “responsible” also carry a social dimension, which makes it harder still to use them without specification.⁷

There are only two ways out of the prohibition.

The first is to demonstrate recognized excellent environmental performance. The Directive defines this narrowly, and there are exactly three routes: compliance with the EU Ecolabel; compliance with a national or regional EN ISO 14024 Type I ecolabel that is officially recognized in a Member State (the Commission gives the Nordic Swan, Blue Angel, the Austrian Ecolabel and Milieukeur as examples); or top environmental performance under other EU law. The performance must also be relevant to the claim. The Commission’s own illustration is that “biodegradable” cannot be justified by an EU Ecolabel whose criteria for that product do not cover biodegradability.

The second, and for most brands the realistic route, is to specify the claim. If the environmental claim is explained in clear and prominent terms on the same medium (the pack, the same advertisement, the same web page), it is no longer “generic.” The Commission’s example is instructive: “climate-friendly packaging” is generic and prohibited, while a statement that all the energy used to make the packaging comes from renewable sources is specific and can be made, provided it is true and substantiated.

This second route has a consequence that many packaging designers will not like. The Commission’s Q&A restates the long-standing view that if there is no space on the pack to specify a claim, the claim should generally not be made. The specification has to be next to, or part of, the claim: a footnote in a leaflet or a link in a corporate report will not be sufficient.

2. Sustainability labels

The second major change concerns labels. Displaying a sustainability label that is not based on a certification scheme, and not established by a public authority, is now prohibited in all circumstances (Annex I, point 2a).

“Sustainability label” is defined broadly: any voluntary trust mark, quality mark or equivalent, public or private, that aims to set a product, process or business apart by reference to its environmental or social characteristics.⁵ A “certification scheme,” in turn, is a third-party verification scheme with a set of conditions. Its requirements must be publicly available; it must be open to all traders willing and able to comply, on transparent and non-discriminatory terms; its requirements must be developed in consultation with relevant experts and stakeholders; and compliance must be monitored by a competent third party that is independent of both the trader and the scheme owner, in line with international, EU or national standards (ISO 17065 is given as an example).⁵

Two points from the Commission’s guidance deserve emphasis. First, the scheme owner and the certified company do not have to be different entities, but the monitoring body must be a legally separate entity from the scheme owner.⁵ Second, once the application date arrives there is no further grace period for labels already in use: any sustainability label on the market from 27 September must comply, and schemes that don’t meet the definition must either adapt or the related labels need to be removed.⁵

For the cosmetics sector, where a long list of self-declared labels has grown up over the years, this is a considerable change. It is precisely why NATRUE described, when the Directive was approved, sustainability labels as an “indispensable cornerstone in establishing trust,” provided they are underpinned by third-party certification meeting strict EU requirements. The NATRUE Label works on that model: it is granted only after independent audit by a NATRUE Approved Certifier against publicly available criteria that set a minimum proportion of natural and organic ingredients for each product category.

The consequences reach beyond formal logos. The Commission notes that packaging artwork, such as a green leaf or a water drop, may in certain circumstances be read by consumers as an implicit environmental claim or even as a voluntary trust mark, particularly when combined with written claims or logos. Imagery on its own, without text, is not a “generic” claim, but the combination is what regulators will look at, and the test is how an average consumer would understand the presentation.

3. Offsetting can no longer support a product claim

The Directive bans claiming, on the basis of greenhouse gas offsetting, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions (Annex I, point 4c). The recitals give as examples “climate neutral,” “CO2 neutral certified,” “carbon positive,” “climate compensated” and “reduced climate impact” when based on offsets.⁵

What remains possible is important to state accurately. Companies may still invest in carbon-credit projects and may talk about those investments, as long as the information is not misleading. A claim about a product’s climate impact can still be made if it is based on the actual life-cycle impact of that product within its own value chain. The Commission’s example is a statement of “reduced CO₂ impact” that is specified on the same medium and based on real improvements in production. The blacklist ban does not apply to offsetting-based claims at company level, though those remain subject to the general misleading practice provisions.

Credible climate communication will need life-cycle data behind it.

4. Claims must not cover more than they should

Annex I now also prohibits making an environmental claim about an entire product or an entire business when it concerns only a certain aspect of the product or a specific activity of the business (point 4b). In other words, environmental benefits cannot be attributed to an entire cosmetic product or company when they apply only to a specific component, characteristic or stage of production.

Cosmetics have plenty of scope for the “halo effect” this provision targets: a recycled cap on a conventional formulation, one natural ingredient in a long ingredient list, a renewable-energy site supplying only one of several production stages. The practical rule is that the claim should say what it covers. A body lotion containing one certified-organic argan oil among forty ingredients can say so about that ingredient; to describe the product as “organic” without restriction would not be justifiable under this provision.

5. Claims about the future need a plan

Companies that promise future environmental performance, such as “climate neutral by 2030,” now have to support that claim with clear, objective, publicly available and verifiable commitments, set out in a detailed and realistic implementation plan with measurable, time-bound targets and allocated resources. The plan must be regularly verified by an independent third-party expert, whose findings are made available to consumers (Article 6(2)(d) UCPD, as amended). This provision works through the case-by-case assessment rather than the blacklist.

The Directive does not prescribe the frequency of verification, though the Commission suggests annual or biennial review as a sensible benchmark. It also does not require the plan to appear on the pack; a QR code leading to the plan and to the expert’s findings is enough.⁵ The expert must be independent from the trader, free from conflicts of interest and competent in environmental issues.⁵

6. Names, “free-from” statements and legal requirements

Brand and product names. The definition of environmental claim explicitly includes brand names, company names and product names.⁵ The Commission’s updated guidance clarifies that a term such as “green” in a brand name is not automatically a claim; what counts is whether the average consumer would take the name to promise an environmental benefit.^5,7 But if a name containing terms like “eco,” “natural” or “climate neutral” does create that association, the trader must specify the claim on the same medium or, failing that, demonstrate recognized excellent environmental performance.⁵

“Free-from” and similar benefits. Advertising benefits to consumers that are irrelevant and do not result from any feature of the product or business are now among the practices that may be misleading (Article 6(2)(e)). The Commission’s examples are gluten-free bottled water and plastic-free paper. It also stresses that a benefit shared by many products in a category is not automatically misleading if it is genuinely relevant: a shampoo advertised as free of microplastics, for example, could legitimately make that point where competing products contain them.⁵ Cosmetics marketers should test every “free-from” line against this: is it a genuine, relevant differentiator or a statement of the obvious?

Presenting legal requirements as distinctive. Presenting requirements that the law imposes on all products in the category on the EU market as a distinctive feature of the trader’s offer is prohibited in all circumstances (Annex I, point 10a). Given how heavily regulated cosmetics ingredients already are, this is a live risk for claims that essentially say, “we comply with the law.”⁵

Old stock, stickers and the transition question

The most contentious issue in the run-up to 27 September has been the absence of any transition period. The Commission’s guidance confirms that claims and labels on existing products and “old stock” – already manufactured, packaged or shelved – must comply from that date too, with fixes such as corrective stickers or supplementary point-of-sale information, and enforcers may weigh whether a company made reasonable, proportionate efforts.⁵

NATRUE, together with 17 other European associations, asked the Commission in December 2025 to introduce a “grandfathering” clause for products already lawfully on the market, warning that the alternative risks large-scale, avoidable waste, with smaller manufacturers hit hardest.^8,9,10 That request was not granted. The legal position for 27 September is fixed: no grandfathering, and legacy stock is left to enforcement discretion.

NATRUE’s position

NATRUE welcomes the ECGT. That was our position when the Directive was adopted, and it remains so now that the application date is here. The Directive is an important step towards tackling greenwashing and strengthening consumer trust.

Independent certification is a credible way to communicate. The NATRUE Label is a certification scheme in the sense the Directive intends: the standard is published, and the label is granted through independent certification bodies. NATRUE Approved Certifiers, whose accreditation is coordinated with the International Organic Accreditation Service (IOAS), audit ingredients and finished products against the NATRUE criteria. The Directive’s insistence that labels rest on transparent, third-party-verified schemes is the same principle on which we have built our own system, and we expect it to strengthen the position of certified products on the market.

A level playing field. One of the Directive’s twin objectives is to ensure fair competition for businesses that make genuine investments in environmental and social sustainability. Brands that go through third-party audit bear costs that brands relying on self-declared claims do not. The ECGT narrows that gap.

What a certified natural label can and cannot do

A recognized certification scheme makes a sustainability label lawful under point 2a. It does not, by itself, make any other generic environmental claim lawful. The Directive’s three routes to “recognized excellent environmental performance” are the EU Ecolabel, an officially recognized national or regional Type I ecolabel, and top performance under other EU law. A private certification scheme sits outside that specific list, however rigorous its standard. In practice, this means a NATRUE-certified product should pair its certification with a specific, substantiated statement rather than the certification mark alone.

We believe the right way to communicate a certified product is through specific, verifiable statements about what the certification actually covers. The NATRUE standard is a standard about composition: the origin and processing of ingredients, the exclusion of certain ingredient types, the proportion of natural and organic content for each product category. Those are concrete, verifiable facts, and they can be explained on the same medium as the claim, which is the Directive’s own test for a claim that is not generic.

The point applies equally to the word “natural.” Cosmetics have standards for it, but the Commission’s guidance recognizes that “natural” in a brand or product name can create an environmental association in the mind of the average consumer. Companies should therefore treat “natural” as a claim that needs to be anchored in something specific, such as a certified content or a defined criterion. For NATRUE-certified products, the anchoring is the certification itself with regard to the product composition.

Practical steps for brands

1. Build a claims inventory. List every environmental and sustainability-related statement, logo, name and image across packs, websites, marketplaces, social media and retail materials. Include implicit claims: leaf motifs, green colour schemes and product names.
2. Sort each claim into a category. Is it a sustainability label (needs a qualifying scheme or public authority)? A generic claim (needs specification or recognized excellent performance)? An offsetting-based claim? A whole-product claim covering only part of the product? A future claim?
3. Fix or remove the blacklisted items first. Offsetting-based product claims, non-qualifying labels and unspecified generic claims are prohibited regardless of context and need no proof of actual consumer deception to be enforced.
4. Specify rather than delete where you can. Where the underlying fact is sound, restate the claim in specific terms next to the claim itself. Where there is no room for the specification, the Commission’s view is that the claim should not be made.
5. Document the evidence. For every retained claim, hold the substantiation before the claim is used, not after a complaint. Life-cycle data, supplier declarations, test reports and certificates should be traceable to a specific statement.
6. Check the certification scheme. For labels, confirm that the underlying scheme meets the definition, including independent monitoring and public criteria. For future commitments, confirm that a competent, independent expert is in place and that a public plan exists.
7. Triage legacy stock. Identify which SKUs in the supply chain carry non-compliant claims, decide between stickering, supplementary point-of-sale information and withdrawal, and keep a record of the reasonable and proportionate efforts made, since the Commission has indicated that this may be taken into account by enforcers.
8. Brief the wider team. Marketing agencies, retailers, distributors and social media teams all produce claims. The compliance burden follows the claim.

Looking ahead

Two things are worth watching after 27 September 2026.

First, enforcement will be national and uneven at first. Enforcement lies with national competent authorities, which will prioritise by gravity and circumstance.⁵ Some Member States have been quicker than others in transposing the Directive.

Second, the Commission’s guidance is not the last word. The Q&A is expressly a document of preliminary views that cannot bind the Court of Justice, which alone can interpret the Directive authoritatively.⁵ Points such as the treatment of imagery, of brand names and of old stock may develop as cases emerge. The Commission has said it will update its formal guidance notices on the UCPD once practice has accumulated.⁵

Conclusion

The ECGT does not tell cosmetics brands what to formulate or how to package. It tells them what they may say about it, and what they must be able to prove. For companies that have always worked from the composition upward, with documented ingredients, independent audits and specific statements, the rules describe good practice. For those that relied on a general glow of green language, the adjustment is larger.

Article written by Viktoria Potko, NATRUE Global Communications and Public Relations Manager.

Originally published in Euro Cosmetics Magazine.

 

References:

1  Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information. https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng

2  European Commission, “Green claims” – criteria to stop companies from making misleading claims about the environmental merits of their products and services (source of the 2020 finding that 53% of claims were vague, misleading or unfounded and 40% unsubstantiated). https://environment.ec.europa.eu/topics/circular-economy-topics/green-claims_en

3  European Commission, “Sustainable consumption” (adoption of the Directive on 28 February 2024; transposition deadline 27 March 2026). https://commission.europa.eu/topics/consumers/consumer-rights-and-complaints/sustainable-consumption_en

4  NATRUE press release, “NATRUE: The ‘Empowering Consumers for the Green Transition’ Directive tackles greenwashing and protects consumers,” Brussels, 1 September 2026 (statement by Prof. Dr. Florian Stintzing, President of NATRUE). https://natrue.org/eu-greenwashing-rules-ecgt-directive-cosmetics/

5  European Commission, Directorate-General for Justice and Consumers, Questions & Answers on Directive (EU) 2024/825 (ECGT Directive), June 2026 edition. Non-binding preliminary views of Commission services. https://commission.europa.eu/document/download/3c257883-bb2a-4dd9-a6dc-501d587bb34f_en?filename=faq-empowerting-consumers-gtd.pdf

6  Regulation (EC) No 1223/2009 on cosmetic products, Article 20, https://eur-lex.europa.eu/eli/reg/2009/1223/oj ; and Commission Regulation (EU) No 655/2013 laying down common criteria for the justification of claims used in relation to cosmetic products, https://eur-lex.europa.eu/eli/reg/2013/655/oj

7  Bird & Bird, “EU Commission publishes FAQ on the Empowering Consumers Directive: Some clarity and remaining open questions” (updated version, on brand names and Recitals 9 and 10). https://www.twobirds.com/en/insights/2026/eu-commission-publishes-faq-on-the-empowering-consumers-directive–some-clarity-and-remaining-open-q

8  NATRUE, “NATRUE Calls for Practical ECGT Transition with Grandfathering Clause to Avoid Waste,” 11 December 2025. https://natrue.org/natrue-ecgt-transition-grandfathering-clause/

9  Joint business statement, “Grandfathering clause ECGT,” December 2025 (18 European associations). https://www.eurochambres.eu/wp-content/uploads/2025/12/Joint-business-statement-Grandfathering-clause-ECGT-final.pdf

10  Personal Care Insights, “Stricter EU greenwashing rules risk creating cosmetic waste,” 20 January 2026. https://www.personalcareinsights.com/news/ecgt-transition-cosmetics-greenwashing.html