All industries Risk: medium

Cosmetics: Greenwashing Risk 2026

The cosmetics industry is under dual scrutiny: the EU Cosmetics Regulation (1223/2009) already prohibits animal testing, making 'cruelty-free' without additional context a trivial claim. From 27 September 2026, EmpCo prohibitions will additionally apply to 'natural', 'organic' and 'eco-friendly' without external certification.

Typical claims in Cosmetics

„natural cosmetics"
„organic"
„eco-friendly"
„sustainably packaged"
„vegan"
„cruelty-free"
„free from microplastics"

Concrete examples (red/amber)

'Natural cosmetics' without COSMOS/NATRUE certification
'Organic cream' without organic certification
'Cruelty-free' — for EU cosmetics a trivial claim since 2013 EU requirement

Recognised certificates

COSMOS

International natural cosmetics standard, defines organic content + purity of ingredients.

NATRUE

European natural cosmetics standard with 3 levels.

EU-Bio (DE-ÖKO-XXX)

EU organic label with control body number.

Leaping Bunny

Internationally recognised cruelty-free certification, goes beyond EU requirement.

Frequently asked questions

Is 'cruelty-free' sufficient as a USP?

No — since 2013 animal testing on cosmetics has been banned EU-wide. The claim is a trivial claim and from 2026 subject to legal challenge under EmpCo Annex I No. 10a. Instead use 'Leaping Bunny certified'.

What is the difference between COSMOS and NATRUE?

COSMOS (international, 2 levels): Natural (≥ 95% natural ingredients), Organic (≥ 95% organic). NATRUE (European, 3 levels) with clearer organic content levels. Both are recognised substantiation.

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General information, not legal advice

Empcora is a pure checking and documentation service and provides general information only on the legal situation based on the EmpCo Directive (EU 2024/825) and the unfair-competition / consumer-protection law transposing it in your jurisdiction including references. This is not individual legal advice and includes neither the rewriting nor the drafting of texts. No liability or warranty is assumed for the correctness, completeness or up-to-dateness of the analysis, nor for any legal consequences. The legal assessment of an individual case rests with an admitted law firm or lawyer.