EU Green Claims for Cosmetics: What 'Natural,' 'Eco-Friendly,' and 'Biodegradable' Now Legally Require

The DGCCRF listed allégations environnementales trompeuses — misleading environmental claims — as a priority enforcement category for consumer goods in both 2023 and 2024. Cosmetics and personal care were named as a high-risk sector. That was before Directive (EU) 2024/825 on Empowering Consumers for the Green Transition completed its transposition across EU member states.

The transposition deadline was March 27, 2026. It has now passed. If your brand is still using “eco-responsible,” “naturally derived,” “carbon neutral,” or generic “clean beauty” language on European packaging — without documented, substantiated evidence files behind each claim — you’re operating on ground that regulators now have explicit legal tools to act on.

Here’s what changed, what it means for your product range, and what real substantiation actually looks like.

What Directive (EU) 2024/825 Actually Prohibits

The directive amends two existing pieces of EU consumer law: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). Its additions to Annex I of the UCPD — the list of commercial practices automatically classified as unfair regardless of context — are what cosmetics brands need to focus on.

The directive prohibits making a generic environmental claim that cannot be substantiated by demonstrated, recognized environmental performance. The Commission’s own guidance provides a non-exhaustive list of terms that fall into this category: “eco,” “environmentally friendly,” “eco-friendly,” “green,” “natural,” “biodegradable,” “climate neutral,” and “carbon neutral” are all cited. The prohibition attaches to their unsubstantiated use — the terms themselves are not banned outright. But the bar for substantiation is now meaningfully higher than anything most cosmetics marketing teams have previously had to clear.

The directive also restricts sustainability labels. From March 2026, new sustainability labels may only be promoted if established by a public authority or based on an approved certification scheme recognized at EU or member-state level. Third-party seals that don’t meet this threshold cannot be newly introduced or promoted.

And critically: claims about an environmental benefit must disclose their scope explicitly. A fragrance packaged in recycled cardboard cannot carry a blanket “sustainable packaging” claim if the plastic closure is virgin-origin. An ingredient-level sourcing claim cannot be presented as a product-level or brand-level statement. Scope ambiguity is one of the most common grounds on which French authorities have historically found misleading practices in cosmetics enforcement investigations — and the directive gives them a clearer statutory hook to act on it.

Why ISO 16128 and Certification Alone Won’t Protect You

This is the gap that many cosmetics formulation and regulatory teams haven’t fully internalized: industry standards and certifications are evidence inputs, not compliance outputs.

ISO 16128-1 and ISO 16128-2 provide a technical methodology for calculating the natural-origin content of a cosmetic formula by mass. The standards are robust, internationally recognized, and widely used across the European industry. A formula with a 94% natural-origin index calculated under ISO 16128-2 gives you something concrete and quantified to point to. But it does not, by itself, constitute substantiation of a broad “natural” claim under Directive 2024/825.

ISO 16128 was not designed to be a legal standard. The UCPD’s “recognized excellent environmental performance” criterion asks whether the environmental benefit is real, material, and proportionate to the claim being made — and that’s a wider question than a natural-origin index alone can answer. Synthetic preservatives, petrochemical-derived processing agents, and ingredients classified as “natural origin” under the ISO methodology but produced via intensive industrial transformation all exist in formulas that score well on the index.

COSMOS certification (administered by ECOCERT, BDIH, SOIL ASSOCIATION, and three other certifying bodies) goes considerably further. COSMOS-NATURAL and COSMOS-ORGANIC standards impose requirements on ingredient sourcing, processing methods, prohibited substance lists, and packaging. A COSMOS-certified product is in a substantially stronger position to support a “natural” or “organic” claim. But whether COSMOS certification constitutes “recognized excellent environmental performance” in every claim context under the directive is not yet settled — the directive is newly transposed, EU case law is sparse, and its application to specific cosmetics claim types will develop over the coming years.

“Clean beauty” presents a separate and arguably greater problem. There is no EU regulatory definition of this term. No ISO standard applies to it, no approved certification scheme covers it, and no scientific committee has defined it. Under Directive 2024/825, using “clean” on EU cosmetics packaging without a specific, brand-defined, substantiated explanation of what “clean” means in your context is a textbook generic environmental claim. Removing it or replacing it with a specific, verifiable assertion is the lower-risk path for brands selling in Europe.

What ‘Substantiation’ Looks Like in Practice

The directive doesn’t mandate a single evidence file format, but Commission guidance and emerging enforcement practice point toward consistent requirements. For each environmental claim, your documentation should address three dimensions.

Scope: What does this claim actually cover, and is that scope disclosed to the consumer? A “sustainably sourced shea butter” claim covers one ingredient’s supply chain — not the product’s full environmental footprint, not the packaging, not the brand’s operations. Document the boundary explicitly. Undisclosed scope limitations have been among the most common grounds for misleading practices findings in DGCCRF investigations under prior legislation.

Methodology: How was the benefit assessed and quantified? For biodegradability claims, this means test data — typically OECD 301B (ready biodegradability) or OECD 302C (inherent biodegradability), conducted by an ISO 17025-accredited testing laboratory. For carbon accounting claims, a lifecycle assessment (LCA) following ISO 14044 methodology is the expected standard, ideally verified against EN ISO 14064. For natural-origin content claims, an ISO 16128-2 calculation with a fully disclosed scope — which components are included, how fragrance complexes are handled, whether packaging is in or out — is the methodological minimum.

Verification: Has the evidence been independently reviewed? Supplier-provided documentation alone — a CoA, a letter of attestation, a spec sheet — is insufficient for product-level or brand-level environmental claims. For ingredient-level claims, supplier documentation with full traceability records and third-party audit history represents the minimum standard. For broader claims, independent verification against a recognized methodology is effectively required.

One figure matters considerably here: for infringements with a Union dimension — where the same misleading claim appears across multiple EU member states and the Consumer Protection Cooperation (CPC) network coordinates enforcement under CPC Regulation (EU) 2017/2394 — penalties can reach 4% of annual worldwide turnover. For a cosmetics brand with €30 million in global revenue, that’s a potential €1.2 million maximum fine from a single coordinated enforcement action. Proportionality applies, but these are not theoretical ceiling figures.

France’s Additional Layer: AGEC and DGCCRF Enforcement

Brands based in France, or distributing significantly into the French market, operate under a further compliance layer that predates Directive 2024/825 by four years.

The loi AGEC (loi relative à la lutte contre le gaspillage et à l’économie circulaire, enacted 10 February 2020) introduced provisions directly relevant to cosmetics marketing. The most widely overlooked by international brands entering the French market: AGEC prohibits using “not tested on animals” claims on finished cosmetic products sold in France. The basis is straightforward — since animal testing prohibition is already a mandatory legal requirement under Article 18 of Regulation (EC) No 1223/2009, presenting it as a product differentiator misleads consumers about what the claim actually represents.

This catches brands expanding from North America by surprise. Products from the US and Canada regularly carry “cruelty-free” and “not tested on animals” as prominent label claims. French market versions — and any EU-wide labeling intended for French distribution — need to handle this claim category differently. Removing the claim or reframing it in terms of the specific sourcing or formulation practice you’re actually highlighting is the compliant path.

AGEC also mandates the Info-Tri labeling system for recyclability guidance on French-market packaging, EPR (extended producer responsibility) reporting obligations for packaging waste, and the TRIMAN sorting symbol on applicable packaging types. These interact with EU-level packaging requirements under the revised Packaging and Packaging Waste Regulation, creating a layered compliance picture for brands supplying France specifically.

The DGCCRF enforces all of this. Their investigations result in injunctions, administrative fines, and public naming on the dgccrf.gouv.fr website. With Directive 2024/825 now transposed into French law, investigators have a significantly expanded statutory toolkit compared to twelve months ago.

How to Audit Your Claims Before an Inspector Does

The practical response to all of this is a structured claims audit — conducted proactively, before a regulator prompts you.

Step 1: Map every claim across every touchpoint. Primary packaging, secondary packaging, product inserts, your EU-facing website, retailer listing copy, and social media accounts targeting EU consumers. Environmental and “natural”-adjacent claims accumulate across touchpoints faster than any single team tracks them. Retailer listing copy in particular is often written by someone outside the regulatory function and never reviewed against current law.

Step 2: For each claim, answer three questions. Is the scope of this claim explicitly defined and disclosed? Is there methodology-backed evidence supporting it (test data, LCA, ISO 16128-2 calculation)? Has that evidence been independently verified, or is it supplier-asserted only?

Step 3: Classify your claims into three buckets. Claims with strong substantiation that would survive regulatory scrutiny. Claims that need upgraded or extended documentation. Claims that should be retired or replaced with specific, verifiable assertions.

Step 4: For claims you’re retiring, plan the transition carefully. Coordinate revised packaging artwork, updated website copy, and updated retailer-facing materials across your regulatory, marketing, and supply chain teams. Document the rationale for each decision — the fact that you conducted this review and made deliberate choices matters if you’re later inspected.

Step 5: Build a dedicated evidence file for every claim you keep. Organized by product and claim type, version-controlled, and readily accessible for inspection. This is distinct from your Product Information File under Regulation (EC) No 1223/2009 — reference between them, but maintain the claims evidence separately.

For most brands with 15–30 SKUs in EU distribution, this process surfaces 3–5 claims that are inadequately supported. Addressing them proactively costs a fraction of what a DGCCRF investigation costs in management time and legal exposure — before any penalty is even considered.

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Written by Nour Abochama, Quality & Regulatory Advisor, Care Europe | VP Operations, Qalitex. Learn more about our team

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• ISO 17025-Accredited Testing to Support EU Cosmetics Claim Substantiation — Qalitex Laboratories provides analytical testing including biodegradability assessments and natural-origin calculations to build defensible EU evidence files.
• European Cosmetics Brands Expanding into Canada: Health Canada Compliance — Androxa guides European cosmetics and personal care brands through Health Canada notification requirements and Canadian environmental claims frameworks.