Greenwashing Rules: Making Sustainability Claims That Hold
Environmental claims in cosmetics moved from a reputational question to a legal one. Regulators in Europe, the United Kingdom and North America have begun treating unsubstantiated environmental wording as a misleading commercial practice, and enforcement has reached the packaging on a shelf rather than only the advertising copy. The practical consequence for a brand is that sustainability language now needs the same evidence discipline as a performance claim.
Why This Category Is Different
A performance claim has an obvious evidence path: the study, the number of subjects, the measurement. An environmental claim depends on a life cycle assessment, and most brands have never commissioned one. That gap is exactly why regulators have focused here, and why the burden of proof sits with the brand rather than with the complainant.
The core principle that applies across all these regimes is that a claim must be specific, substantiated and verifiable. A claim that cannot be verified by a consumer or by an authority is not merely optimistic, it is misleading.
Words and Phrases That Carry the Most Risk
- Eco friendly, environmentally friendly, green. Broad and unverifiable. A product cannot be environmentally friendly in general terms; it can have specific properties such as a defined recycled content or a reduced material mass. These blanket words are the most frequently challenged.
- Carbon neutral, climate neutral, net zero. These require a full greenhouse gas inventory across the relevant scope and evidence of how the residual emissions were addressed. Offsetting based claims are increasingly restricted, and the underlying calculation is rarely carried out by a brand that uses the wording.
- Recyclable. Risky without qualification. A pack is only recyclable if the local collection infrastructure accepts it and it is designed to be recycled in practice. A polypropylene bottle with a metal sprung pump is not recyclable even though the bottle is.
- Biodegradable. Requires a defined test method, a defined environment and a defined timeframe. A material that biodegrades in an industrial composter over six months is not biodegradable in a landfill in a meaningful timeframe, and the distinction matters.
- Natural. There is no legal definition in most markets. Where a product containing substantial synthetic content is described as natural, that is a misleading claim on the facts even though the word itself is unregulated.
- Plastic free. Requires the whole pack including the closure, the label, the seal and any lining to contain no plastic. A glass bottle with a plastic pump is not plastic free.
- Contains X per cent recycled content. Substantiable, but only against a certificate for the actual production batch. The figure on the label has to match the pack in the customer's hand, not the pack in the design file.
The Evidence Each Type of Claim Requires
- Material composition claims. A certificate of recycled content from the converter, traceable to the production batch. Relatively easy and cheap to obtain.
- Mass reduction claims. A comparison of material mass against a defined reference. The reference has to be stated; a claim of 40 per cent less plastic is meaningless without saying less than what.
- Recyclability claims. Evidence that the pack components separate and that the material stream is collected in the markets where the product is sold. The second part is where most claims fail.
- Carbon claims. A life cycle inventory with defined boundaries, verified by a third party. Substantial cost and a recurring cost, because the calculation has to be updated as the supply chain changes.
- Biodegradability claims. Test results from a recognised standard applied to the material and the disposal route claimed.
- Comparative claims. A like for like comparison against a named or clearly defined alternative, using an equivalent functional unit. This is the type of claim most likely to attract a competitor challenge.
Writing a Claim That Survives
Four rules cover most of the ground. Be specific about the property rather than the general impression. Be numeric where a number exists. Say what the comparison is against. And keep the claim to a scope you can document.
Practical examples of the difference:
- Weak. Eco friendly packaging.
- Strong. Bottle made with 50 per cent post consumer recycled plastic; closure and label not recycled content.
- Weak. Sustainable refill system.
- Strong. Refill pouch uses 68 per cent less plastic by weight than the equivalent full size bottle.
- Weak. Biodegradable formula.
- Strong. Formula readily biodegradable according to the standard test method for the surfactant system used.
The strong versions are less exciting and far more defensible. They also tend to perform well commercially, because specific claims are more credible to the consumers who care about the subject.
Where the Claims Usually Break
The failure is rarely a deliberate exaggeration. It is almost always one of four things: a claim drafted by marketing without checking what the factory can document; a pack changed by the converter after the claim was written, with a different recycled content or a different closure; a claim written for one market and used globally without checking the requirement in each; or a claim that applied to the previous formulation and was not reviewed after reformulation.
The control that prevents all four is a claims register: a list of every environmental statement on the pack and in the marketing, with the evidence supporting it, the date it was verified and the person responsible. It is a small administrative effort and it converts a compliance question into a lookup.
What to Do Before the Artwork Is Signed Off
- List every environmental word on the pack and in the copy, including the ones that feel innocuous.
- For each, write down the evidence and check that it exists rather than assuming it does.
- Confirm the pack specification with the converter, including the closure and any liner, so the composition claim matches reality.
- Check the claim against each market of sale, because the requirements and the enforcement priorities differ.
- Add the review to the reformulation checklist so it happens automatically when the formula or the pack changes.
Doing this before the labels are printed costs almost nothing. Doing it after a complaint means a reprint, a listing suspension or a fine, and it usually arrives at the worst possible moment in the product's commercial life.
Claims Reviewed Against the Documentation
OEM COSMETICS ODM supplies the composition, recycled content documentation for pack components, material mass data and formulation information needed to substantiate environmental claims on ISO 22716 and GMP certified lines. Send us the claim you intend to make and we will tell you what evidence it needs and whether the pack can support it.
Talk to our team: WhatsApp +86 18709713948 · Email adon@oemcosmeticsodm.com · Website www.oemcosmeticsodm.com