As sustainability becomes a leading demand across cosmetics, personal care, and consumer goods, regulators are tightening controls on how brands communicate environmental benefits. The upcoming Green Claims Regulation represents a major shift for marketing teams, compliance departments, and product developers. Because it restricts vague or unsubstantiated sustainability claims, it requires brands to use precise language supported by verifiable evidence. Therefore, companies must understand what they can and cannot say on packaging, websites, and promotional material.
For years, the beauty industry has used phrases such as “eco-friendly,” “green,” “clean,” and “environmentally responsible” without standardized definitions. While many brands improved sustainability practices, others used the trend as a marketing advantage without meaningful proof. This behavior created widespread greenwashing concerns. Consequently, global regulators—especially in the European Union—have developed strict frameworks to ensure environmental claims are truthful, clear, and scientifically validated.
What Is the Green Claims Regulation?
The Green Claims Regulation (GCR) is a European regulatory initiative intended to prevent misleading environmental messaging. It supplements the Unfair Commercial Practices Directive by establishing detailed rules for how environmental claims must be substantiated. Although centered in the EU, its influence extends globally because multinational brands often harmonize messaging across regions.
The Regulation applies to all voluntary environmental claims made about products, packaging, manufacturing processes, or company practices. It requires rigorous evidence, transparency, and independent verification. Because sustainability has become a competitive advantage, the Regulation ensures claims reflect measurable actions rather than marketing language.
Why the Regulation Was Created
Regulators found that more than half of environmental claims used across consumer products were vague, misleading, or unverifiable. Terms like “green,” “conscious,” “clean,” “planet-safe,” and “eco” often lacked scientific backing. In some cases, claims directly contradicted environmental data or selectively highlighted only the positive aspects of a product.
Major issues prompting regulatory action included:
- Use of broad sustainability terms without definitions
- Selective disclosure of positive attributes while ignoring negative impacts
- Misleading natural or bio-based claims
- Unverified biodegradable or compostable claims
- Marketing around carbon neutrality with insufficient justification
To address these concerns, the Green Claims Regulation establishes objective, enforceable criteria for environmental marketing claims.
What Brands Can No Longer Say
The Regulation outlines several claim categories that are prohibited unless strict conditions are met. This includes generalized environmental claims and claims about product composition, packaging, carbon impact, and recyclability. Because many beauty brands rely on sustainability messaging, understanding these restrictions is essential.
1. Vague Environmental Claims
Brands cannot use broad or undefined terms unless they are supported by clear, verifiable evidence. Examples include:
- “Eco-friendly”
- “Green beauty”
- “Planet-safe”
- “Environmentally conscious”
- “Non-toxic” (unless legally defined and scientifically verified)
These claims must be avoided unless accompanied by specific, measurable proof.
2. Claims Without Quantified Impact
Statements such as “reduces environmental impact” or “better for the planet” are not allowed unless the claim specifies exactly which impact is reduced and by how much. Generic wording is considered misleading under the Regulation.
3. Claims Based on Minimal Improvements
Brands may not highlight insignificant improvements as major environmental benefits. For example, a formula containing 2% natural extracts cannot be marketed as “natural-based” or “biodegradable” to suggest a full sustainability transformation.
4. Unsubstantiated Natural or Organic Claims
Claims about naturalness or organic content must meet strict recognized standards. A formula that is 70% water and 5% botanical extracts cannot claim to be “mostly natural.” Similarly, the term “organic” requires certification—not marketing interpretation.
5. Misleading Biodegradable Claims
The Regulation prohibits vague “biodegradable” claims unless a product:
- fully biodegrades within a specified timeframe,
- under defined environmental conditions,
- according to an official test method.
Brands cannot simply say “biodegradable packaging” without lab and field test results.
6. Compostable and Recyclable Claims
Terms like “recyclable,” “compostable,” or “plastic-free” must reflect real-world infrastructure and composition. A product is not “recyclable” if only 20% of local systems can process it. Similarly, products with compostable components must specify whether they belong in home compost, industrial compost, or specialized facilities.
7. Carbon Neutrality
One of the most heavily regulated claim categories involves carbon neutrality. Brands can no longer use:
- “carbon neutral,”
- “net zero,”
- “climate positive.”
unless they provide full lifecycle assessment data and transparent reporting. Claims based solely on offset purchases are prohibited because offsets do not reflect true emission reductions.
Approved Claims Under the Regulation
Although the Regulation restricts vagueness, it does support accurate sustainability communication. Claims are allowed when brands provide:
- specific environmental attributes,
- quantified improvements,
- recognized certifications,
- independent verification.
Examples of acceptable claims include:
- “Packaging contains 65% post-consumer recycled PET.”
- “Formula reduces water consumption by 30% compared to previous version.”
- “Certified COSMOS Organic.”
- “Tested to ISO 14855 for controlled composting.”
These statements are measurable, transparent, and supported by documentation.
Evidence Required for Environmental Claims
The Regulation mandates that any environmental claim must be backed by evidence. Supporting documentation must be:
- scientifically valid,
- publicly accessible,
- verified by an independent third party.
Brands must maintain detailed files, including:
- lifecycle assessments,
- material sourcing documentation,
- certification records,
- scientific test results,
- environmental impact reports.
Claims without robust evidence will be considered misleading, even if unintentionally exaggerated.
Impact on Cosmetic Marketing and Formulation
The Green Claims Regulation affects far more than marketing language—it influences formulation, sourcing, packaging, and supply-chain transparency. Brands must ensure that every sustainability claim aligns with the ingredient list, manufacturing processes, and packaging materials. Because many beauty products rely heavily on naturals, eco-labeled ingredients, or recycled packaging, compliance requires cross-team collaboration between R&D, regulatory, and marketing.
This includes verifying sustainability attributes with suppliers, ensuring accurate percentages, and avoiding selective disclosure. Claims used in social media must follow the same strict rules as packaging claims.
Common Mistakes Brands Make
Despite clear regulatory direction, brands continue to make avoidable mistakes. These include:
- Highlighting natural content without quantifying percentages.
- Using sustainability logos or imagery without certifications.
- Claiming “clean beauty” without defining criteria.
- Exaggerating environmental benefits to differentiate from competitors.
Avoiding these pitfalls requires a disciplined approach to sustainability storytelling and transparent documentation.
How Brands Can Prepare for GCR Enforcement
To comply with the Regulation, brands must redesign sustainability communication using clear, verifiable language. Recommended steps include:
- Reviewing all packaging and website claims.
- Eliminating generic environmental terminology.
- Requesting documentation from ingredient suppliers.
- Developing measurable sustainability metrics.
- Using recognized certifications when possible.
- Coordinating messaging across marketing, regulatory, and R&D.
Early adaptation ensures smoother compliance and stronger consumer trust.
