No consumer wants to be manipulated, nor should companies gain a competitive advantage by exploiting environmental concerns simply because sustainability has acquired market value. At the same time, consumers cannot be expected to understand the materials, processes or regulatory intricacies behind every environmental statement they encounter. This is precisely why rules on environmental claims matter: they protect consumers from misleading information, but they also protect responsible manufacturers from competitors who make claims they cannot substantiate.
At its core, this is a question of trust. Where trust, professional responsibility and ethical communication work, detailed rules often remain in the background. Where they do not, regulation inevitably becomes more specific. Greenwashing matters because environmental awareness can influence purchasing decisions. A green leaf, recycled-looking packaging, the words natural, eco-friendly or sustainable, or a carefully constructed story about environmental responsibility can all contribute to the impression a consumer forms about a product. If that impression extends beyond the evidence behind it, there is a problem.
The new European rules address that problem. What they do not do is prohibit companies from communicating genuine environmental benefits, nor do they automatically require every environmental statement to be supported by an assessment of every aspect of a product’s life cycle. Yet, as new rules approach, their meaning can expand considerably in professional and public communication. Manufacturers may then find themselves trying to comply not only with what the legislation says, but also with what they have repeatedly been told it says. And that is where greenwashing itself can begin to be… mindwashed.
What is actually new?
Directive (EU) 2024/825 introduces new and explicit rules concerning environmental claims and sustainability labels, and certain commercial practices are now specifically prohibited. However, the underlying logic is hardly unfamiliar to the cosmetics industry.
Commission Regulation (EU) No 655/2013 has long required cosmetic claims to comply with common criteria including truthfulness, evidential support, honesty, fairness and informed decision-making. A cosmetic claim is also not merely a sentence printed on a label. It may be conveyed through words, names, trademarks, pictures, symbols and other forms of presentation, explicitly or implicitly. The overall impression matters.
The distinction is therefore important. It is not new that a claim must be truthful, clear, substantiated and presented in a way that does not mislead the consumer. What is new is that Directive (EU) 2024/825 now specifically defines and explicitly prohibits certain practices relating to environmental claims.
The basic question nevertheless remains surprisingly simple: What exactly am I claiming, and does my documentation prove precisely that?
Are “Green Words” Now Prohibited?
Not quite. Directive (EU) 2024/825 specifically addresses generic environmental claims. Its examples include expressions such as environmentally friendly, eco-friendly, green, nature’s friend, ecological, environmentally correct, climate friendly, gentle on the environment, carbon friendly, energy efficient, biodegradable and biobased, as well as similar statements suggesting excellent environmental performance.
This is sometimes reduced to the message that such words are simply “banned”. That interpretation is too broad. The prohibition concerns a generic environmental claim where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. The Directive also distinguishes such generic claims from environmental claims whose specification is provided in clear and prominent terms on the same medium.
That distinction matters. “Climate-friendly packaging” is broad and generic; a statement describing a specific and demonstrable property of that packaging is not. The question is therefore not merely which word has been used, but what is being communicated to the consumer and what evidence supports it.
When one part becomes the whole
One of the most useful principles made explicit by the new rules concerns claims that refer to an entire product or business when the environmental benefit actually relates only to a particular aspect.
Suppose the body of a cosmetic bottle contains 50% recycled plastic. That information concerns the bottle body. It does not automatically describe the cap, pump or other packaging components, and it certainly does not, by itself, establish that the cosmetic product as a whole is “sustainable”.
Cosmetic safety and claims professionals already know this logic from another context. If a cream contains an ingredient with a recognised moisturising effect, the mere presence of that ingredient is not necessarily evidence that the finished cosmetic product produces the same effect to the extent implied by the product claim. The same reasoning applies here: the scope of the evidence must correspond to the scope of the claim.
The same is true for a statement such as “98% ingredients of natural origin”. If that percentage has been properly calculated and substantiated, for example using the methodology described in ISO 16128-2, the statement tells us exactly that: the origin of a defined proportion of the ingredients. It does not tell us how much energy or water was used, what packaging was chosen, how far the raw materials travelled or what the product’s overall environmental impact may be. Nor is that a weakness in the claim, because the claim did not say any of those things.
This brings us to a word that is used constantly but not always clearly understood: sustainability. Unlike pH or recycled-plastic content, sustainability is not a single product characteristic, but a much broader concept encompassing environmental and, in its broader meaning, social and economic dimensions. One favourable characteristic therefore cannot, by itself, establish the overall sustainability of a product.
This does not mean that every environmental claim requires proof of a product’s overall sustainability. If a manufacturer claims only that the body of a bottle contains a certain percentage of recycled plastic, that is the property that needs to be substantiated. The problem begins when a specific fact is presented in a way that invites a much broader conclusion. Natural, certified and sustainable are not synonyms.
A green leaf is not a certification
The new rules also address sustainability labels. Such labels can create a particularly strong impression because consumers may interpret a seal, badge or symbol as evidence that a product has undergone some form of independent assessment. Directive (EU) 2024/825 therefore prohibits displaying a sustainability label that is not based on a certification scheme or established by public authorities.
The reason is straightforward: a graphic symbol can look like independent verification even when no independent verification exists. A self-created green seal or leaf does not become a certification simply because it looks like one – whether it was designed by a graphic designer, bought on Etsy, or put together in Canva one Sunday after a family lunch.
There is, however, an important nuance. Not every sustainability label is automatically an environmental claim. If its wording, appearance or context communicates a positive or reduced environmental impact, however, it may also function as one. Once again, presentation matters because a claim is more than text.
Can a truthful claim still mislead?
Yes, and the Directive gives an almost absurdly simple example: bottled water advertised as “gluten-free”.
The statement is factually true, but that is precisely the point. Water does not naturally contain gluten. If we paid at least some attention in chemistry class, the absence of gluten is hardly a distinguishing quality of one bottle of ordinary water over another. Yet highlighting such information can create the impression that the product offers a particular advantage that comparable products do not.
This is why asking whether a statement is true is not always enough. We should also ask whether it is relevant, why it is being highlighted and what conclusion a consumer may reasonably draw from it.
Context can, of course, change the relevance of the same information. In cosmetics, for example, a “gluten-free” statement may have different relevance for a lip product, where unintentional oral ingestion can occur during normal use and certain raw materials could potentially be a source of gluten, than for a product intended exclusively for application to intact skin.
A similar principle applies when compliance with a legal requirement that applies to all products in a category is presented as though it were a special benefit of one particular product. Being legally compliant is not a unique selling point simply because somebody has found an attractive way to print it on the packaging.
Consumer law protects people from misleading commercial practices, but it does not relieve us, as consumers, of the need to think critically about what marketing tells us. We do not need to treat manufacturers as criminals – but neither should we treat consumers as fools.
And what about packaging?
Packaging deserves separate attention because Regulation (EU) 2025/40 on packaging and packaging waste (PPWR) adds another regulatory layer. Where an environmental claim concerns a regulated packaging property, such as recycled content, recyclability or reusability, it must also be considered within the applicable PPWR requirements.
For a cosmetics manufacturer, however, the practical lesson is much simpler than the legal architecture behind it. Claims about packaging properties need to be supported by the relevant packaging documentation. If a manufacturer wishes to state that the body of a bottle contains a particular percentage of recycled plastic, the relevant information and evidence should be available in the packaging documentation, including documentation obtained from the packaging supplier where applicable, and the claim should be limited to the packaging component to which that evidence actually relates.
Evidence concerning a packaging property is not evidence of the environmental performance of the cosmetic product as a whole, just as information about one ingredient is not automatically evidence of the performance of the finished formulation. Nor does a specific environmental claim create a general requirement for a full life-cycle assessment.
The problem is not that specific evidence is too narrow. The problem arises when the claim becomes broader than the evidence supporting it.
When greenwashing becomes mindwashing
Environmental regulation is complex. Social media is fast. Those two realities do not always work well together, particularly in the weeks preceding the application of new rules. Manufacturers may be exposed, day after day, to simplified interpretations, half-truths and sometimes outright misinformation about what will supposedly become prohibited or mandatory. A detailed legal provision becomes a carousel. A conditional prohibition becomes “this is now banned”. An example becomes a universal rule. A requirement from one regulatory area is transferred into another without sufficient legal basis.
Repetition then does something particularly powerful: familiarity begins to replace verification. When the same interpretation appears often enough, from enough apparently authoritative sources, a half-truth can gradually acquire the status of an accepted fact. It is no longer questioned against the actual wording of the legislation because, by the time the rules start to apply, everyone seems to “know” what they say.
There is an old idea that if a falsehood is repeated often enough, it becomes true. Of course, it does not. But it may begin to be perceived as true – and in regulatory communication, that distinction matters enormously.
Simplifying regulation is not the problem. Good professional communication should simplify complex information. The problem begins when simplification changes its meaning. If greenwashing presents environmental information in a way that can influence a consumer’s purchasing decision, we might use the term mindwashing for communication that simplifies, generalises or removes regulatory information from its context to such an extent that the recipient is left with a different understanding from the one that actually follows from the legislation.
This matters particularly when regulatory information is communicated to manufacturers who rely on professional expertise to make business decisions. They should not need to become lawyers, toxicologists, packaging specialists and environmental experts simply to understand which obligations actually apply to their products. One sign of genuine specialisation is knowing the boundaries of one’s own field.
Perhaps the same principle that protects consumers from misleading product claims can also serve as a quality standard for professional regulatory communication. Fear attracts attention. Understanding enables decisions.
Demystifying rather than prohibiting
Preventing greenwashing does not mean preventing environmental claims. The new rules do not stop manufacturers from communicating genuine environmental benefits; they prevent them from saying more than they can substantiate or creating an impression their documentation cannot support. For cosmetics manufacturers, this means distinguishing between several regulatory layers. Regulation (EU) No 655/2013 continues to provide the fundamental logic for cosmetic claims. Directive (EU) 2024/825 introduces specific rules and prohibitions concerning environmental claims and sustainability labels. The PPWR adds another layer where claims concern regulated properties of packaging. These rules interact, but they should not be merged into one enormous and undefined requirement to “prove sustainability”.
Before making a claim, the practical questions remain remarkably ordinary: What exactly am I saying? What will the consumer understand from it? What evidence do I have? Does that evidence support the entire message, including the impression created by the way I present it?
That is ultimately the simplest way to approach the subject: Say what you can substantiate. Substantiate what you claim. And do not use presentation to suggest more than that.
Greenwashing then stops looking like a new and mysterious regulatory discipline and returns to what it fundamentally is: a question of truthfulness, evidence, relevance and fair communication with consumers.
And that is exactly what communication about the regulation itself should be as well.
