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The European Union (EU) is taking significant steps toward combating greenwashing and ensuring that consumers have access to accurate and transparent information on the environmental impact of cosmetic products. The proposed EU Green Claims Directive (GCD) aims to establish clear criteria for companies to substantiate the truthfulness of the green claims they make on cosmetic products. This blog aims to summarize the EU GCD requirements in conjunction with this initiative.
Key Principles of the EU GCD for Cosmetics
The proposed EU GCD aims to establish clear guidelines and requirements for companies making environmental claims on cosmetic products. The key principles of the GCD for the cosmetics industry include:
- Minimum Requirements for Substantiating Environmental Claims
- Claims must be based on a product’s full life cycle, considering factors like raw materials, manufacturing, packaging, and disposal.
- Claims must use both primary and secondary data and should be verified by independent accredited bodies before use.
- Brands must specify whether claims refer to the whole product or just certain components (e.g., packaging).
- Mandatory Verification and Certification
- Environmental claims must be verified and certified by independent accredited bodies before they can be used on products.
- A certificate of conformity recognized across the EU is required for all verified claims.
- Exemptions for Small Businesses
- Cosmetic companies with fewer than ten (10) employees and an annual turnover or balance sheet under 2 million EUR are exempt from third-party verification, unless they choose to obtain a certificate.
- Environmental Labeling Schemes
- Any environmental labeling schemes used by cosmetic companies must comply with new EU-level requirements, including:
- Criteria developed by experts and reviewed by stakeholders.
- Transparent information on ownership, decision-making, and objectives.
- Systems for dispute resolution and suspension/withdrawal of labels.
- Restrictions on New National Labels
- Member states will not be able to create new national environmental labels. All new schemes must be established at the EU level.
- Private operator labels and third-country labels will require approval from the European Commission (EC) or an EU member state.
The cosmetics industry has broadly welcomed the EU GCD, recognizing its importance in fighting greenwashing and providing clarity. However, the industry has called for clear implementation rules to be established within the primary legislation, rather than through secondary acts.
Implementation of Sustainable Practices in Cosmetic Manufacturing
- Substantiate Environmental Claims: Conduct comprehensive audits of environmental claims on product packaging, marketing materials, and websites. Ensure that each claim is supported by robust scientific evidence throughout the product’s life cycle, demonstrating additional environmental benefits beyond legal requirements, using both primary and secondary data.
- Obtain Third-party Verification: Prior to using any environmental claims, seek verification from accredited third-party bodies. These entities will evaluate claim substantiation and communication, issuing a certificate of conformity for EU-wide validity. Small businesses with fewer than ten (10) employees and an annual turnover of 2 million EUR may opt out, unless they are seeking certification.
- Comply with Environmental Labeling Schemes: Ensure compliance of environmental labeling schemes with new EU standards, including expert-developed criteria, transparent decision-making information, and robust systems for dispute resolution and label management. Avoid utilizing new national labels to align with GCD regulations.
- Enhance Transparency and Consumer Education: Provide clear and accessible information to empower consumers, avoiding ambiguous terms like “natural” or “eco-friendly”. Communicate initiatives aimed at reducing environmental impact throughout the product life cycle, which aid consumers in distinguishing genuinely sustainable choices.
- Stay Informed and Adaptable: Stay updated on Regulatory changes and GCD updates through industry associations, consultants, or the EC. Ensure that internal teams are knowledgeable and agile in adapting to the new EU GCD requirements, utilizing technology solutions for efficient compliance and marketing adjustments, as required.
Challenges in Complying with the EU GCD
While the EU GCD aims to promote transparency and sustainability, cosmetic manufacturers may face several challenges:
- Complexity of Data Collection: Gathering comprehensive life cycle data for products can be resource-intensive.
- Cost of Verification: Independent verification and certification can be costly, particularly for smaller businesses.
- Evolving Regulations: Keeping up with Regulatory updates and changes requires continuous effort and adaptability.
- Consumer Perception: Educating consumers and gaining their trust in verified green claims can be challenging.
To conclude, the EU GCD establishes important guidelines for cosmetic manufacturers, aiming to prevent misleading environmental claims and ensuring that consumers receive accurate information on a product’s environmental impact. By setting strict rules for proving these claims and requiring independent verification and certification, the GCD promotes honesty and sustainability in the industry. Staying updated on these regulations is crucial. Freyr provides expert guidance to help you meet these standards and ensure that your products are environmentally responsible. Join Freyr to adopt sustainable practices and comply with regulations effectively!
