Cosmetics: Greenwashing Risk 2026
The cosmetics industry is under dual scrutiny: the EU Cosmetics Regulation (1223/2009) already prohibits animal testing, making 'cruelty-free' without additional context a trivial claim. From 27 September 2026, EmpCo prohibitions will additionally apply to 'natural', 'organic' and 'eco-friendly' without external certification.
Typical claims in Cosmetics
- „natural cosmetics"
- „organic"
- „eco-friendly"
- „sustainably packaged"
- „vegan"
- „cruelty-free"
- „free from microplastics"
Concrete examples (red/amber)
- 'Natural cosmetics' without COSMOS/NATRUE certification
- 'Organic cream' without organic certification
- 'Cruelty-free' — for EU cosmetics a trivial claim since 2013 EU requirement
EmpCo-compliant alternatives
Instead of: „Natural cosmetics with nourishing ingredients"
Better: „COSMOS Natural certified cosmetics (95% natural ingredients, 5% organic content)"
Why: Generic replaced by specific certification + percentages.
Instead of: „Produced cruelty-free"
Better: „Leaping Bunny certified since 2024 (no animal testing beyond EU minimum standard)"
Why: EU requirement turned into USP — Leaping Bunny also audits suppliers and third countries.
Recommendations
- COSMOS or NATRUE certification
- Link INCI list
- State packaging recycling rate
- Leaping Bunny instead of just 'cruelty-free'
Recognised certificates
COSMOS
International natural cosmetics standard, defines organic content + purity of ingredients.
NATRUE
European natural cosmetics standard with 3 levels.
EU-Bio (DE-ÖKO-XXX)
EU organic label with control body number.
Leaping Bunny
Internationally recognised cruelty-free certification, goes beyond EU requirement.
Frequently asked questions
Is 'cruelty-free' sufficient as a USP?
No — since 2013 animal testing on cosmetics has been banned EU-wide. The claim is a trivial claim and from 2026 subject to legal challenge under EmpCo Annex I No. 10. Instead use 'Leaping Bunny certified'.
What is the difference between COSMOS and NATRUE?
COSMOS (international, 2 levels): Natural (≥ 95% natural ingredients), Organic (≥ 95% organic). NATRUE (European, 3 levels) with clearer organic content levels. Both are recognised substantiation.