A new EU law, the Empowering Consumers for the Green Transition Directive (Directive (EU) 2024/825, or ECGT Directive), will apply across Europe starting September 27, 2026.
This directive sets strict new standards for how sustainability and environmental credentials can be communicated to consumers, affecting everything from store shelves and product catalogues to websites and promotional materials. As an authorized certification body, ETKO wants to ensure our partners and retailers are fully prepared.
The Good News: COSMOS-Certified Products Are Safe
If your stock products carry the COSMOS ORGANIC or COSMOS NATURAL mark, you can breathe a sigh of relief.
The COSMOS certification scheme is fully recognized as an independent certification scheme under the new Directive.
Currently certified products are completely compliant to sell and stock after the September 27, 2026 deadline.
No product recalls or relabeling will be required based on this criteria alone.
Where You Must Take Action: Retailer Communications
The ECGT Directive doesn’t just target product manufacturers; it applies to anyone selling to consumers, meaning retailers are directly on the hook. Under the new rules, a misleading environmental claim is the responsibility of whoever makes it to the consumer.
Here is what you need to review immediately:
Generic Section & Category Labels: Banners like "Green Beauty," "Eco Cosmetics," or "Natural & Sustainable" are now classified as generic environmental claims. These are banned unless every single product grouped under that label can individually demonstrate recognized environmental performance. Simply having a few COSMOS-certified products in the mix is no longer enough to justify a generic "organic" or "natural" section header.
Promotional Materials & Ads: Broad terms like "eco-friendly" or "green" used in flyers, social media, or web banners must be substantiated product-by-product. Referencing the COSMOS mark is perfectly fine, but applying broad green language to uncertified products next to them is a violation.
Own-Label / Private Label Products: If you sell cosmetics under your own brand, you carry the same responsibility as a manufacturer. Current COSMOS certification is your strongest asset here. If your private label uses environmental language but lacks certification, it must be reviewed before September.
Practical Steps to Take Before September 2026
Audit Your Language: Review all in-store and online environmental language, including shelf-edge labels, website categories, and catalogues.
Verify Certifications: Check that the COSMOS-certified products you stock carry active, current certificates. You can verify status anytime at cosmos-standard.org.
Evaluate Other Trust Marks: Ensure any other sustainability labels you display are based on a qualifying certification scheme or established by a public authority.
Strengthen Private Labels: Consider pursuing COSMOS certification for your own-label environmental products to secure your market position.
Need assistance? ETKO is here to help you navigate these transitions and ensure your private labels meet the gold standard of compliance. For further official guidance, keep an eye on cosmos-standard.org.