Clean Beauty Rules: EU Bans, MoCRA and Recalls — 2026-09-06
The EU’s new greenwashing directive (EmpCo) enters into force on September 27, 2026, banning vague sustainability claims like "eco" and "green" without proof. Meanwhile, US regulators continue to tighten MoCRA enforcement, with FDA facility registration renewals and asbestos testing rules for talc products shaping the compliance landscape.
Clean Beauty Rules: EU Bans, MoCRA and Recalls — 2026-09-06
Top developments
EU EmpCo Directive Takes Effect in Late September
The European Commission’s EmpCo Directive, aimed at curbing greenwashing, becomes applicable across the EU starting September 27, 2026. This new rule prohibits the use of vague environmental claims such as "eco," "green," or "sustainable" on packaging unless backed by specific, verifiable evidence. For cosmetics brands, this means self-created "clean beauty" seals and generic labels like "recyclable bottle" will be banned unless substantiated by third-party certification or rigorous testing data.

FDA MoCRA Registration Renewals and Talc Rules
In the US, the FDA is actively enforcing MoCRA (Modernization of Cosmetics Regulation Act) provisions, with the first biennial facility registration renewals due in FY 2026. Brands must verify their registration status to avoid purges of lapsed entries. Additionally, the FDA is moving forward with standardized testing methods for detecting asbestos in talc-containing cosmetics, a critical step for brands reformulating powder products to meet safety standards.

German Media Warns of Ingredient Bans in Drugstores
German consumer media outlets are highlighting upcoming EU ingredient bans affecting major drugstore chains like dm and Rossmann. The EU is set to prohibit specific substances in nail polish and restrict eleven other cosmetic ingredients, including certain solvents and preservatives, with compliance deadlines approaching in early 2027. This has triggered a wave of reformulation efforts among private-label and branded cosmetics sold in Germany.
Local view
France: French media outlets like Alternativi and Presse Agence are focusing heavily on the consumer impact of the EU greenwashing ban. Reports emphasize that terms like "durable" (sustainable) will be illegal on packaging without proof, aiming to protect shoppers from misleading marketing. The Belab Services analysis notes that cosmetic brands have only weeks to audit their packaging claims before the September 27 deadline.
Germany: German industry guides from Intep and IHK Schwaben are providing practical checklists for companies to comply with the EmpCo Directive. They warn that vague promises of "climate neutrality" or "biodegradability" must be removed or rigorously proven. The Evz.de (European Consumer Centre) press release highlights that this shift is designed to strengthen consumer protection against misleading environmental advertising.
Context & numbers
The EU’s new regulations target a market where greenwashing has been rampant. The EmpCo Directive specifically bans generic terms like "natural," "clean," and "biodegradable" unless supported by same-medium proof. In the US, MoCRA compliance now requires mandatory facility registration, product listing, and safety substantiation files for every SKU. The FDA is also finalizing rules for fragrance allergen labeling, mirroring the EU’s recent expansion of its allergen list to over 80 substances effective July 2026.
On the radar
- September 27, 2026: The hard deadline for the EU EmpCo Directive to become applicable. Brands must have updated packaging and marketing materials by this date.
- October 13, 2026: The Food and Drug Law Institute (FDLI) is hosting a webinar on "Cosmetics Legislation and Litigation," focusing on Extended Producer Responsibility and recall trends.
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