As from 27 September 2026, the provisions of Directive (EU) 2024/825 (Empowering Consumers for the Green Transition Directive – ECGT), transposed into Italian law by Legislative Decree 20 February 2026, No. 30, will apply. The Directive amends the European rules on unfair commercial practices and consumer protection, introducing specific measures aimed at strengthening the fight against greenwashing and ensuring that environmental claims are clear, specific, verifiable and supported by adequate evidence.

Cosmetics and greenwashing: the regulatory framework

For the cosmetics sector, the new provisions of Legislative Decree 20 February 2026, No. 30 integrate the common criteria laid down by Commission Regulation (EU) No. 655/2013.

• Commission Regulation (EU) No. 655/2013: the six common criteria continue to constitute the basis for the assessment of all cosmetic claims:

• Compliance with the law.
• Truthfulness.
• Evidential support.
• Fairness.
• Honesty.
• Enabling informed decision-making.

• Directive (EU) 2024/825, as transposed by Legislative Decree 20 February 2026, No. 30, introduces specific requirements for “Environmental claim”, namely, “any message or representation, which is not mandatory under Union law or national law, including text, pictorial, graphic or symbolic representation, such as labels, brand names, company names or product names, in the context of a commercial communication, which states or implies that a product, product category, brand or trader has a positive or no impact on the environment or is less damaging to the environment than other products, product categories, brands or traders, respectively, or has improved its impact over time.”

Ban on generic environmental claims

Among the most significant novelties is the ban on any “Generic environmental claim”, defined as: “any environmental claim made in written or oral form, including through audiovisual media, that is not included on a sustainability label and where the specification of the claim is not provided in clear and prominent terms on the same medium.”

The Directive also lists a number of claims that fall within generic environmental claims, for example: “environmentally friendly,” “eco-friendly,” “green,” “nature’s friend,” “ecological”, “biodegradable” or similar expressions, unless such statements are accompanied, in the same medium of communication, by a clear, visible and adequately substantiated specification.

Part-for-whole claims prohibited

Likewise, a statement relating to a single environmental aspect of the product may not be presented as if it concerned the product’s overall environmental performance. The Directive therefore prohibits presenting a single environmental benefit as if it described the overall sustainability of the product. In other words, it is not permitted to generalise a benefit limited to a specific aspect of the cosmetic, such as the packaging, a single raw material or one stage of the life cycle, to the whole product. This is because the consumer could be led to believe that the entire product is more sustainable than it is.

Sustainability labels and emission offsetting

The Directive introduces specific limitations on the use of sustainability labels, to prevent logos or labels from creating an impression of “environmental certification” not supported by objective criteria.

Sustainability labels are allowed only if they meet one of the following conditions:

• They are based on a structured certification scheme complying with the requirements laid down by the legislation.
• They are established by public authorities.

At the same time, claims attributing to the product a neutral, reduced or positive climate impact are prohibited when such claims are based exclusively on CO2 emission offsetting mechanisms, without real reductions having first been implemented along the value chain.

Compliance strategies

Considering the new obligations, cosmetic companies should review their communication strategies and the technical documentation supporting environmental claims, verifying that each statement is consistent not only with the criteria of Commission Regulation (EU) No. 655/2013, but also with the new requirements of clarity, transparency and scientific demonstrability introduced by Directive (EU) 2024/825.

Deadline of 27 September 2026: what to do?

As from 27 September 2026, the new provisions will also apply to existing products and to “old stock”, meaning goods already manufactured, ordered, distributed or already on shelves. Since no additional transitional period is provided beyond that date, timely action is important.

Manufacturers are invited to:

• Identify non-compliances: map the environmental claims and sustainability labels on existing packaging to identify information that conflicts with the new rules and proceed with the necessary adjustments.
• Adopt practical corrective solutions: physically intervene on non-compliant packaging, for example by applying covering stickers or providing additional explanatory information directly at the point of sale.
• Document due diligence: prepare for inspections by national authorities, which will specifically assess whether reasonable and proportionate efforts were made to adapt products already placed in the distribution chain.

>>> Complife supports manufacturers in label checking, environmental claim compliance, structured testing and strategic regulatory consulting.

SOURCES:

• Directive (EU) 2024/825
• Legislative Decree 20 February 2026, No. 30
• European Commission ECGT Questions & Answers