Clean Beauty Rules: EU Bans, MoCRA and Recalls — 2026-09-11
The EU’s strict new green claims directive takes effect in just 16 days, forcing brands to substantiate all "eco-friendly" and "green" labels or face removal from the market. Meanwhile, French investigative journalism highlights the persistence of hazardous substances in cosmetics despite regulatory pressure, while German legal experts warn companies to audit environmental advertising immediately.
Clean Beauty Rules: EU Bans, MoCRA and Recalls — 2026-09-11
Top developments
EU Green Claims Ban Hits September 27 Deadline
With only two weeks remaining before the enforcement date of Directive (EU) 2024/825, the EU’s ban on unsubstantiated green claims is imminent. Starting September 27, 2026, terms like "eco-friendly," "green," and "climate neutral" are prohibited on product packaging and marketing unless backed by rigorous, verifiable proof. This regulation specifically targets the cosmetics sector, where vague sustainability labeling has been rampant, requiring brands to reformulate packaging and marketing materials to avoid penalties.
French Media Exposes Persistent Hazardous Substances
French economic publication Alternatives économiques reported on September 9 that risky substances continue to persist in cosmetics, fueling consumer anxiety despite EU efforts to tighten ingredient bans. The article highlights the disconnect between regulatory announcements and actual market availability, noting that some hazardous ingredients remain present in products sold within the Union. This scrutiny adds pressure on regulators to enforce existing restrictions more aggressively and close loopholes in the current framework.
German Legal Alerts for Environmental Advertising Compliance
German law firm CHG Czernich Rechtsanwälte issued a warning on September 8 for companies selling in the EU to review their environmental advertising immediately. The alert emphasizes that the new EmpCo-Richtlinie (Empowerment of Consumers Directive) makes generic ecological promises legally risky, requiring specific, certified evidence for any sustainability claim. This guidance is critical for international brands operating in the DACH region, as non-compliance could lead to swift competitive law actions.
Cosmed Newsletter Highlights Global Regulatory Shifts
The French cosmetics industry association Cosmed released its September newsletter (No. 278), detailing upcoming changes in China, Turkey, and Ukraine, alongside discussions on SCCS opinions and wastewater REP (Extended Producer Responsibility) regulations. The newsletter underscores the global nature of compliance challenges, noting that brands must navigate diverging standards across major markets simultaneously. It also highlights the importance of staying updated on SCCS safety assessments, which form the basis for many EU ingredient restrictions.
Local view
In France, Alternatives économiques continues to drive public discourse by questioning the efficacy of current bans, arguing that consumer concerns about health risks remain valid due to lingering hazardous substances. In Germany, MS Aktuell and IHK Schwaben have focused heavily on the practical implications of the September 27 green claims ban, advising retailers and manufacturers to remove unverified "bio" or "eco" labels from shelves to avoid legal pitfalls.
Context & numbers
The deadline for compliance with the EU Green Claims Directive is fixed at September 27, 2026, leaving less than three weeks for final adjustments. The directive aims to eliminate vague environmental claims, impacting thousands of cosmetic SKUs across the EU. In parallel, the US FDA continues to implement MoCRA requirements, with facility registration renewals and product listing updates remaining active priorities for 2026.
On the radar
- September 27, 2026: Full enforcement of EU Directive (EU) 2024/825 on green claims; all unverified environmental labels must be removed from EU markets.
- Ongoing MoCRA Audits: US brands should continue auditing product listings and safety substantiation files as FDA enforcement ramps up following the initial registration phases.
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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