Now That EU Green Transition Rules Are in Force, Which Cosmetic Packaging Claims Are Off-Limits? 

Europe’s crackdown on greenwashing didn’t go away; it just arrived through a different door. While the proposed Green Claims Directive has sat in limbo since 2025, the Empowering Consumers for the Green Transition Directive (ECGT) has applied since September 27, 2026. It bans generic environmental claims, self-made sustainability labels and offset-based neutrality claims for products, and cosmetic packaging carries plenty of all three. 

There was no reprieve for existing stock. The Commission’s September 2026 Q&A on the directive states: “The ECGT Directive does not provide for a transition period beyond this date.” For beauty brands and their packaging suppliers, the question has shifted from whether the rules will bite, to which claims, logos, and even product names need to change. 

The Green Claims Directive Is Stalled, Not Gone 

The confusion started in June 2025. On June 20, 2025, the Commission announced that it intended to withdraw its proposed Green Claims Directive, which would have required companies to verify environmental claims through independent third parties before using them. According to Latham & Watkins, the European People’s Party had argued the proposal’s procedures were too complex, burdensome and costly, and risked hindering sustainability communication. 

The withdrawal never became official. The European Parliament’s Legislative Train notes that the Commission’s 2026 Work Programme, adopted October 21, 2025, still lists the proposal as pending, and the Parliament’s procedure file shows that it is awaiting the Council’s first-reading position. Industry groups opposed it in its proposed form: Cosmetics Europe co-signed a July 2025 joint statement calling it “unclear, complex, impractical, and insufficiently harmonized.” 

The ECGT was never part of that fight. As Latham & Watkins put it at the time, “The Green Transition Directive will not be affected by the withdrawal of the Green Claims Directive Proposal.” 

What the ECGT Bans Outright 

The directive works by amending the EU’s Unfair Commercial Practices Directive and adding new practices to its blacklist, which are banned in all circumstances. The text of Directive (EU) 2024/825 adds several that land squarely on cosmetic packaging: 

• Sustainability labels not based on a certification scheme. “Displaying a sustainability label that is not based on a certification scheme or not established by public authorities” is banned. In-house eco seals are the obvious target. 

• Generic environmental claims. Terms such as “eco-friendly,” “green,” “ecological” or “biodegradable” are banned unless the trader can show recognized excellent environmental performance, such as an EU Ecolabel or an equivalent officially recognized ecolabel. 

• Whole-product claims based on one feature. Making an environmental claim about an entire product when it concerns only one aspect, such as the bottle, is banned. 

• Offset-based neutrality claims. “Claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact” is banned, however well-documented the offsets are. 

• Legal requirements sold as a feature. Presenting a requirement that applies to every product in the category as a distinctive benefit is banned. 

Claims about future performance, such as a pledge to reach net zero, also face new conditions. They must be backed by a detailed, realistic implementation plan with measurable, time-bound targets and regular verification by an independent expert. 

How the Commission Reads Packaging Claims 

The Commission’s Q&A, which it describes as the preliminary views of its services rather than an official position, gives the clearest guide to how authorities may read the text. Several answers bear directly on packaging: 

• Brand and product names count. Terms such as “eco,” “natural” or “climate neutral” in a brand or product name can be environmental claims if used “in a way that is likely to create an environmental association,” even when the name is protected as intellectual property. 

• Specific beats generic. The Q&A treats “climate-friendly packaging” as a generic claim, while “100% of energy used to produce this packaging comes from renewable sources” is a specific one. 

• Icons can be labels. “A green leaf or water drop,” especially combined with logos, “may be seen by the average consumer as a voluntary trust mark or quality mark.” 

• “Biodegradable” is generic. The Q&A lists it among generic claims. 

The Q&A does not address “refillable,” “clean” or “plastic-free.” Specific, accurate claims such as “recyclable” or “refillable” are not generic claims under the directive, but they remain subject to the general rules against misleading practices and can’t be stretched into whole-product sustainability messaging. 

Recommended Reading from Beauty Packaging: Refillable Packaging Gears Up for a New Phase in Beauty 

No Grace Period, but Some Flexibility on Old Stock 

The industry asked for breathing room and didn’t get it into law. In December 2025, NATRUE, the international natural and organic cosmetics association, called for a grandfathering clause for products already on the market, warning that the Commission’s interpretation “risks causing substantial and unnecessary waste” and “contradicts established EU principles of legal certainty.” The request came with a joint statement from 17 other associations. 

“A transition that is workable, proportionate and consistent with circularity objectives is essential,” said Dr. Mark Smith, Director General of NATRUE. 

What brands got instead is a non-binding agreement among national consumer authorities. The Consumer Protection Cooperation Network’s June 2026 common understanding on old stock says traders “must act without delay” to comply, using “stickers, removing labeling or similar corrective solutions where appropriate and feasible.” It lists packaging cycles as an objective constraint, says authorities “may refrain from requiring the destruction or recall of products,” and notes that online claims get closer scrutiny because they don’t face the same challenges as printed packs. It also says that “the exact duration of such a transitional period cannot be determined.” 

A Patchwork Across Member States 

Enforcement will not be uniform. The Commission sent letters of formal notice to 20 member states in May 2026 over transposition of the directive, including France, Spain, the Netherlands, Austria and Poland. 

National rules on existing stock also differ. According to law firm Freshfields, Austria may exclude claims on goods placed on the market by September 27, 2026 for three years, Germany requires courts to weigh proportionality and good faith, and the Dutch implementation act contains no comparable provision. 

Still, the policy direction is clear. “Greenwashing remains a problem, and an ambitious campaign against it must be pursued,” wrote Thierry Libaert, a member of the European Economic and Social Committee and its former rapporteur on the ECGT, in a September 2025 EESC opinion piece. 

What Beauty Brands Should Audit Now 

The directive applies to consumer-facing claims on packs, websites, and ads alike. For brands and the suppliers producing their packaging and labels, five checks come first: 

• Generic words on packs, and in names. Flag “eco,” “green,” “natural,” “biodegradable” and similar terms, including in brand and product names, unless backed by a recognized ecolabel. 

• In-house logos and leaf icons. Any symbol that could read as a trust mark needs a certification scheme behind it or should come off. 

• Carbon neutral product claims. Offset-based product claims are banned; company-level investment in climate projects can still be described under the general rules. 

• Whole-product claims. “Recyclable bottle” is specific; “sustainable product” based on the bottle alone is not. 

• Online claims first. Authorities expect faster fixes online, where there is no printed stock to work through. 

The Rules Are Live; the Details Will Follow 

The EU’s most ambitious greenwashing proposal stalled, but the law that matters most for beauty packaging is already in force. Generic claims, self-made eco labels and offset-based neutrality claims are banned across the bloc, and no legal grace period covers packs on shelves. 

What remains uncertain is how strictly each country will enforce old-stock flexibility and whether the Green Claims Directive returns. For brands, neither is a reason to wait. Packaging artwork and online copy reviewed now, will cost less than stickers, relabeling, or enforcement later.