In February 2026, the UK’s Advertising Standards Authority banned baby-care brand Kit & Kin from making unsubstantiated environmental claims. The words at issue were “eco” and “sustainable”, used across its nappies and wipes range. The ASA can order an advert to stop running but has no power to impose fines.
From 27 September 2026, an EU directive will introduce the same standard. Skincare brands using the same vocabulary now face fines of up to 4% of turnover.
What the directive prohibits
The relevant law is Directive (EU) 2024/825, known in the industry as the ECGT or EmpCo Directive. It was adopted on 28 February 2024 and amends two existing consumer laws rather than creating a standalone cosmetics regulator. Member states must transpose it into national law by 27 March 2026; enforcement will begin on 27 September 2026.
Most member states missed that deadline. On 28 May 2026, the Commission issued letters of formal notice to 20 member states for failing to confirm transposition. France, Spain, the Netherlands and Poland were among them.
Each state has two months to respond before the Commission can escalate. The September enforcement date is unaffected either way.
A separate proposal, the Green Claims Directive, would have gone further, requiring pre-approval and life-cycle assessments for every environmental claim. In June 2025, the European Commission paused that process after political pressure over the administrative burden on small businesses.
The proposal has not been formally withdrawn, but negotiations remain stalled, with no timeline for revival. The ECGT Directive is the one that matters for the September deadline.
Three categories of claim fall foul of it. Generic environmental claims – “eco-friendly”, “clean beauty”, “sustainable” – are banned outright unless tied to a specific, verifiable standard. Comparative claims, such as “the most hydrating”, require a public, established methodology.
Claims based on carbon offsetting are also prohibited. A product marketed as “carbon neutral” through tree-planting elsewhere still counts, regardless of the offset’s legitimacy.
National authorities must be able to fine cross-border infringements. The minimum ceiling is 4% of a company’s annual turnover in the relevant member state. Where turnover data is unavailable, they must be able to fine at least €2 million.
Italy’s transposition, Legislative Decree No. 30 of 20 February 2026, allows fines of up to €10 million per violation.
Where skincare marketing is exposed
The directive’s prohibited categories correspond directly to phrases already common on skincare packaging. “100% Eco-Pure” or “Clean Beauty” are generic claims with no legal definition.
“Carbon Neutral Moisturiser” relies on offsetting, now banned regardless of how legitimate the offset scheme may be. “The Most Hydrating Serum” is a comparative superlative that requires a publicly available methodology, not just a marketing line.
“Cruelty-Free” often describes the existing EU and UK ban on cosmetic animal testing – a legal requirement, not a voluntary achievement. “Dermatologist-Tested” is only meaningful if it refers to a documented clinical trial. Without one, it is a credential with nothing behind it.
The UK’s Advertising Standards Authority upheld a complaint against baby-care brand Kit & Kin in February 2026. The complaint was brought by Procter & Gamble. Kit & Kin’s website used “eco”, “sustainable”, and “Protecting Your World, Naturally” for its nappies and wipes.
The ASA ruled that “eco” and “sustainable” read as absolute claims. Both words implied the products caused no environmental harm across their full life cycle. Kit & Kin could not provide that evidence.
The claims were banned from being used again in their existing form.
The ruling did not involve skincare and predates the ECGT Directive’s enforcement date. But it shows UK regulators already applying the standard the directive codifies. An unqualified “sustainable” claim requires full life-cycle evidence, not a certification for one component of the product.
Boots No7’s “Future Renew” range faced the same test over efficacy rather than environmental claims. The regulator was different, but the underlying question was the same: what the evidence actually supports.
Reading the INCI list
The INCI list is the ingredient list required on all cosmetic packaging, under Article 19 of Regulation (EC) No 1223/2009. It is the tool for checking whether a marketing claim matches the formula behind it. Ingredients above 1% concentration must appear in descending order by weight.
Below that threshold, ingredients can be listed in any order. A highlighted “hero” ingredient can sit there at a symbolic, non-functional dose.
Preservatives such as phenoxyethanol rarely exceed 1% for safety; gelling agents like xanthan gum typically sit between 0.1% and 1%. Anything listed after these markers is very likely present below 1%. That is a useful way to spot an ingredient promoted up front but barely present in the formula.
A worked example: Neal’s Yard Remedies Organic Rosehip Oil
Neal’s Yard Remedies markets its Organic Rosehip Oil as “COSMOS Organic Certified” and “99.6% organic.” The ingredient list is four items: Rosa canina fruit oil, Tocopherol, Helianthus Annuus (sunflower) seed oil, and Limonene.
That list is confirmed against the brand’s own product listings and independently against five separate retailers, with no variation anywhere. The product has been Soil Association-certified under COSMOS Organic since 1991.
Run against the directive’s standard, the claim holds up cleanly. Four ingredients leave no room for a diluted “hero” ingredient sitting below the concentration needed to work. The certification comes from an independent accreditation body, not a brand-created badge — the distinction the ECGT Directive is built to enforce. The claim and the formula are the same thing.
Is “carbon neutral” banned on skincare packaging in the EU?
Yes, if the claim rests on carbon offsetting. Directive 2024/825 prohibits offset-based neutrality claims outright, regardless of how the offset scheme is run.
What happened to the Green Claims Directive?
The Commission announced its intention to withdraw the proposal in June 2025. It has not been formally withdrawn, and negotiations remain stalled with no revival timeline.
What’s the penalty for greenwashing under Directive 2024/825?
A minimum of €2 million applies where turnover can’t be established, or up to 4% of turnover for cross-border infringements. Italy’s transposition allows fines as high as €10 million per violation.
Does the directive apply to UK skincare brands?
Only for sales into the EU market. The UK’s Advertising Standards Authority already polices the same claims domestically. Its penalties stop at forcing an advert off air — it cannot fine.
