Pharma & Natural Cosmetics: Greenwashing Risk 2026

The pharma and natural cosmetics sector is one of the highest-risk industries for warning letters and enforcement action: consumers are particularly sensitive to health-related claims and sustainability promises, and the combination of medicinal-product regulation and cosmetics law creates a dense web of substantiation requirements. The EmpCo Directive (EU 2024/825) significantly raises the transparency and evidence bar from 27 September 2026. Generic claims such as "natural healing" or "plant-based active ingredients" are inadmissible without scientific substantiation or third-party certification (Annex I No. 4a UCPD as amended by EmpCo). Under Section 5 UWG and the EmpCo Directive (EU 2024/825), even the term "natural" can be misleading where a product contains added flavourings or thickeners, irrespective of whether those additives are legally classified as "of natural origin". More broadly, generic sustainability claims for cosmetics products without transparent supply chains or recognised certificates are equally exposed under § 5 UWG (UCPD Art. 6) — a principle reinforced by the EmpCo Directive (EU 2024/825) and therefore a key European reference for the industry. Beyond EmpCo, EU Cosmetics Regulation 1223/2009 requires that any cosmetic claim be substantiated by evidence retained in the product information file. The EmpCo Directive adds a per-se ban on claims of climate neutrality achieved solely through offsetting (Annex I No. 4c UCPD): relevant here is whether concrete reduction measures are demonstrated and transparently documented, rather than reliance on offsetting alone. The Directive requires that claims be supported by clinical studies, recognised certifications (NaTrue, COSMOS) or independent assessments, and that a complete ingredient list using INCI nomenclature be provided. Whether marketing aligns with these requirements depends on the extent to which claims rest on verifiable facts rather than generic, unsubstantiated promises — the central distinction the EmpCo framework draws in the pharma and natural cosmetics sector.