Clean Beauty Rules: EU Bans, MoCRA and Recalls — 2026-09-02
The EU’s new anti-greenwashing directive (Directive 2024/825) takes effect on September 27, 2026, forcing cosmetic brands to substantiate all environmental claims or face penalties. Simultaneously, US MoCRA compliance enters a critical phase with facility registration renewals and product listing audits becoming mandatory for market access.
Clean Beauty Rules: EU Bans, MoCRA and Recalls — 2026-09-02
Top developments
EU Greenwashing Directive Enters Force in Less Than a Month
The EU Directive (EU) 2024/825, aimed at empowering consumers for the green transition, becomes applicable on September 27, 2026. This regulation prohibits vague environmental claims such as "natural," "clean," or "biodegradable" unless brands can provide verifiable, science-based proof. Cosmetic companies must now ensure that sustainability labels are backed by certified schemes or official public authorities to avoid sanctions.
MoCRA Compliance Deadlines Tighten for US Market Entry
As the Modernization of Cosmetics Regulation Act (MoCRA) matures, FDA oversight has intensified. Brands must confirm that facility registrations are active and calendar biennial renewals, as the FDA actively purges lapsed registrations. Additionally, product listings require annual updates, and safety substantiation files must be assembled for every SKU before regulatory inquiries occur.
PFAS Restrictions in Packaging Take Effect
Under the Packaging and Packaging Waste Regulation (PPWR), restrictions on PFAS (per- and polyfluoroalkyl substances) in packaging took effect on August 12, 2026. This move significantly impacts cosmetic containers and secondary packaging, requiring brands to reformulate materials to eliminate these "forever chemicals" to remain compliant in the EU market.
Henna Import Liability Shifts Under EU Rules
New EU cosmetic risk rules clarify that while pure henna is not banned, the Responsible Person (RP) liability framework means importing brands share the legal risk with manufacturers. This shift requires stricter due diligence on imported henna products to ensure they meet EU safety standards and labeling requirements.
Local view
In Germany, the consumer protection agency (Verbraucherzentrale) and industry bodies like IHK Schwaben have issued urgent warnings regarding the new EmpCo directive. They emphasize that from September 27, 2026, terms like "bio" or "eco" will be strictly regulated, requiring proof of certification. German media reports highlight that retailers like dm and Rossmann are already adjusting shelf labels to avoid non-compliance with the upcoming ban on misleading green claims.
Context & numbers
- Effective Date: September 27, 2026 (EU Directive 2024/825).
- PFAS Ban Date: August 12, 2026 (PPWR packaging restrictions).
- Allergen Labeling: The EU continues to expand allergen lists, with recent updates impacting fragrance labeling requirements.
- MoCRA Renewals: Biennial facility registrations and annual product listings are now key operational burdens for US-market brands.
On the radar
- September 27, 2026: Hard deadline for EU greenwashing compliance; brands must have proof for all environmental claims ready.
- 2027 Deadlines: Rinse-off cosmetics face a microplastics restriction deadline in 2027 under REACH, requiring ongoing reformulation efforts.
- Omnibus VIII Regulation: Draft updates regarding CMR substances (hair dyes/solvents) are expected to be finalized in late 2026, potentially adding new bans to Annex II.
This content was collected, curated, and summarized entirely by AI — including how and what to gather. It may contain inaccuracies. Crew does not guarantee the accuracy of any information presented here. Always verify facts on your own before acting on them. Crew assumes no legal liability for any consequences arising from reliance on this content.
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