EU ECGT Applies from September 27, Requirements for Cosmetic Claims Tightened Across the Board

The EU Directive on Empowering Consumers for the Green Transition (Directive (EU) 2024/825, "ECGT") will formally apply to traders from 27 September 2026 — less than two weeks away.

Generic environmental claims widely used in the cosmetics industry, such as "natural" and "sustainable", as well as offset-based labels such as "carbon neutral", are prohibited across the board unless supported by sufficient substantiation. Notably, SMEs are not exempt: Chinese companies selling cosmetics into the EU through cross-border e-commerce platforms or independent websites are equally within jurisdiction. CIRS Group summarizes the main contents of the ECGT below for your reference!

Regulatory Overview and Key Timelines

The ECGT was signed on February 28, 2024, published in the Official Journal of the European Union on March 6, 2024, and entered into force on  March 26, 2024. As of mid-2026, however, most Member States had failed to complete transposition in time, and on May 28, 2026 the European Commission sent letters of formal notice to twenty of them. Transposition delays do not reduce compliance risk — under the UCPD framework, unsubstantiated green claims can already be pursued as misleading commercial practices across the entire EU.

Prohibited Practices: The "Red Lines" for Cosmetic Claims

The ECGT works by amending the Unfair Commercial Practices Directive (UCPD, Directive 2005/29/EC) and the Consumer Rights Directive (Directive 2011/83/EU), adding a range of prohibited practices to the "blacklist" in Annex I to the UCPD. These practices are unfair in all circumstances — regulators are not required to demonstrate consumer misleading on a case-by-case basis, and platform compliance teams, customs authorities and consumer protection bodies may all trigger product delisting or penalties directly on this basis.

The practices of greatest concern to cosmetics companies are the following:

1. Unsubstantiated generic environmental claims: Generic expressions such as "natural", "green", "eco-friendly", "sustainable", "biodegradable", "climate-friendly" and "clean beauty" are prohibited across the board when used broadly of a product or brand, unless the trader can demonstrate "recognized excellent environmental performance" — a threshold that typically requires compliance with the EU Ecolabel, an environmental labelling scheme officially recognized by a Member State, or top-level performance in the relevant environmental dimension.

2. Offset-based "carbon neutral" claims: Claims such as "carbon neutral", "climate neutral", "climate net zero" and "low carbon footprint" are prohibited where they rest on the offsetting of greenhouse gas emissions outside the product's own value chain (e.g., purchasing carbon credits); a claim is permitted only where the product's actual life-cycle emissions are neutralized through emission reductions within the value chain, and it must remain verifiable. Marketing language that has become popular in the beauty industry in recent years — "carbon neutral face masks", "climate neutral brands" — will directly constitute a violation after September 27 if based on the purchase of certified emission reductions.

3. Sustainability labels without the backing of a certification scheme: Sustainability labels self-created by a brand or an industry and not based on a recognized certification scheme (nor established by public authorities) are prohibited across the board. In-house marks used by cosmetics companies, such as "green star ratings" and "eco series" labels, cannot continue in use without independent third-party certification.

4. Future environmental commitments without supporting evidence: Visionary statements such as "net zero by 2030" must be accompanied by clear, objective, publicly available and verifiable commitments, including a detailed and realistic implementation plan, quantified and time-bound targets, and independent third-party monitoring of progress; otherwise they constitute actionable violations.

5. One-sided (partial) claims: A benefit relating to a single environmental aspect of a product (such as the packaging, a particular ingredient, or one stage of the life cycle) must not be presented as the product's overall environmental performance. For example, the use of recycled packaging alone cannot be used to present the whole product as "sustainable". Such claims lead consumers to overestimate the product's overall environmental performance, and are therefore blacklisted outright.

6. Other newly added prohibited practices: These include marketing an unrepairable product as repairable, inducing consumers to replace consumables earlier than technically necessary, making unsubstantiated claims about a product's service life, and presenting features required by law as distinctive selling points.

Scope of Application: No SME Exemption — Chinese Cosmetics Exporters Fully in Scope

The ECGT applies to all traders conducting B2C commercial communications directed at EU consumers, regardless of company size or place of registration. For Chinese companies selling cosmetics into the EU through platforms such as Amazon EU, Shein, eBay and OTTO, or through independent websites, every environmental claim on product packaging, listing detail pages, independent websites, social media and marketing materials must be reviewed before the date of application. Member State enforcement authorities have jurisdiction over cross-border infringements affecting EU consumers under the CPC Regulation (EU) 2017/2394 — being registered in China cannot serve as a defence.

Please also note: the Directive contains no transition provisions for existing inventory; how inventory on hand during the transition period is to be handled will depend on the national transposition legislation of each Member State, and companies should not assume that overseas warehouse stock enjoys any "grace period". Updating packaging and marketing materials often takes months; new production batches and new marketing campaigns must be fully compliant from September 27 onward.

Enforcement and Penalties

The ECGT does not create a new enforcement mechanism; enforcement remains with the consumer protection authorities of the Member States under the UCPD (e.g., the DGCCRF in France, the ACM in the Netherlands, the AGCM in Italy), which may order corrective action and require products to be delisted or withdrawn from the market. As amended by the Omnibus Directive (EU) 2019/2161, fines for widespread cross-border infringements can reach 4% of the trader's annual turnover in the Member State(s) concerned, or at least EUR 2 million where turnover cannot be determined; cross-border enforcement is coordinated through the CPC Network, where a complaint filed in one country can trigger coordinated multi-country action; and qualifying consumer organizations may also bring representative actions under Directive (EU) 2020/1828.

For cosmetics companies, the impact concentrates on three points:

• Dual-track claims compliance: In the EU, cosmetic claims are already governed by Regulation (EC) No 1223/2009 and Commission Regulation (EU) No 655/2013; the ECGT adds a blacklist prohibition on top — even where a claim is "substantiated" under the cosmetics rules, it remains prohibited in all circumstances if it constitutes a generic environmental claim or an offset-based "carbon neutral" label;
• The entire marketing chain is within scope: From "natural" and "organic" on bottles and cartons to "clean beauty" language in e-commerce listings, social media and KOL content — any commercial communication made in the trader's name or on its behalf falls within scope;
• Channel-driven impact arrives before fines: Platforms respond to regulatory complaints by removing implicated listings — delisting, search demotion and even shop closure often occur before fines are imposed — and offline beauty retail procurement reviews likewise require claims substantiation. For Chinese cosmetics companies exporting to the EU, the first cost of non-compliant claims is "losing market access", with regulatory penalties coming second.

Recommendations for Cosmetics Companies

• Inventory all environmental claims: Review, item by item, every environmental statement on packaging (bottles, cartons, tags), official websites, platform listings, social media and KOL briefing documents, recording the exact wording, where it appears and the SKUs involved;
• Remove the absolutely prohibited items: Take down all offset-based "carbon neutral" labels, generic claims without recognized certification support, and brand-created sustainability labels — such claims cannot be rescued with footnotes or supplementary explanations;
• Labels and certification: For each claim to be retained, confirm its certification basis, such as the EU Ecolabel, an environmental labelling scheme officially recognized by a Member State, or a certification scheme subject to independent third-party verification; claims lacking recognized certification support are not recommended for retention.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

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