Three instruments decide what you may print, and all three land inside eight weeks. From 27 September 2026 the European Union bans generic environmental claims on products unless you can demonstrate recognised excellent environmental performance — and the guidance names “environmentally friendly”, “green”, “ecological” and “biodegradable” as exactly the kind of words it means.
The practical rule that follows is short. Vague adjectives are now the liability; specific, documented statements are the asset. “Made with 50% post-consumer recycled PET” survives every instrument below. “Eco-friendly” survives none of them.
The three dates that change what you can print
For a brand with artwork in production and a container on the water, these three dates are a single operational question: which words survive?
PPWR, Regulation (EU) 2025/40
Replaces the old packaging directive. Recyclability by design, recycled-content minimums, harmonised sorting labels and minimisation phase in between 2027 and 2040.
Does the pack meet recyclability-by-design as those provisions arrive?
Directive (EU) 2024/825
Generic environmental claims, whole-product claims based on one attribute, and uncertified sustainability labels become banned commercial practices.
Can every green word on the pack be evidenced?
California SB 343
Chasing arrows and recyclability statements restricted to material actually collected and sorted for at least 60% of Californians. Applies by manufacturing date.
When exactly was this run manufactured?
You may have read that the EU Green Claims Directive was withdrawn — the Commission announced that intention on 20 June 2025. That was a separate, additional proposal about substantiating and verifying claims. Its withdrawal changed nothing about Directive (EU) 2024/825, which was adopted in February 2024 and applies on schedule. Enforcement risk went up in 2026, not down.
What counts as a generic claim in the EU
A generic environmental claim is one made without specifying, on the same medium, what it actually refers to. From 27 September 2026 it is prohibited unless you can demonstrate recognised excellent environmental performance relevant to the claim. Three practices become banned outright.
- A sustainability label with no recognised certification scheme behind it. The in-house green leaf logo your studio designed is now a compliance problem rather than a design asset.
- A claim about the whole product that relates to only one aspect of it. This is the one that catches beauty packaging most often. A PCR bottle inside an otherwise virgin-plastic set does not make the set recycled.
- A generic claim with no demonstrable excellent performance. “Eco-friendly”, “green”, “ecological”, “biodegradable” and “climate neutral” all sit here.
The directive treats implicit claims the same as written ones. Green ink, leaf motifs and earth imagery carry an environmental message on their own, so a carton that says nothing but looks like a claim is still a claim. Raise this with the design team before artwork reaches repro, not after.
What the FTC Green Guides require in the US
The US position is older and, on biodegradability, stricter in practice than most brands assume. Under the FTC Green Guides, an unqualified degradable أو biodegradable claim requires competent and reliable scientific evidence that the entire item completely breaks down and returns to nature within one year after customary disposal. The Guides are explicit that items destined for landfills, incinerators or recycling facilities cannot meet that standard — which is where the overwhelming majority of cosmetic packaging goes.
Compostable has its own test: evidence that all materials break down into usable compost safely and in roughly the same time as the material they are composted with. If the item cannot be composted safely at home, or municipal composting is not available to a substantial majority of consumers, the claim must say so.
In the US the fix for both words is usually qualification, not deletion.
California SB 343 and the chasing arrows
SB 343 is why the recycling triangle is disappearing from US packaging. From 4 October 2026 the chasing-arrows symbol, any other recyclability symbol, and any statement of recyclability may only be used where the material is:
- collected by recycling programmes serving at least 60% of California’s population;
- sorted by high-volume facilities serving at least 60% of those programmes; and
- sent to reclaimers meeting Basel Convention requirements.
Plastic packaging additionally must not carry components, inks, adhesives or labels that defeat recyclability under the Association of Plastic Recyclers design guide. Two consequences follow for beauty.
- Decoration decisions are now claim decisions. A metallised finish or a full-wrap label can be the reason a bottle loses the right to say “recyclable”.
- The law runs on manufacturing date, not sale date. Packaging produced before 4 October keeps its labeling regardless of when it sells — which makes the production date on your current run worth knowing precisely.
Claim by claim: what each word now costs
| Claim | Status after autumn 2026 | Evidence it needs |
|---|---|---|
| “Eco-friendly”, “green”, “sustainable” (bare) | Effectively unusable in the EU | Recognised excellent environmental performance for the specific attribute. In practice, replace with a specific statement |
| “Biodegradable” (unqualified) | High risk in both markets | EU: demonstrable performance. US: complete breakdown within one year after customary disposal |
| “Compostable” | Usable if qualified | Certification to EN 13432 in the EU or ASTM D6400 in the US, plus a statement of where composting is possible |
| “Recyclable” | Usable where true in fact | California: the 60% collection and sorting test plus APR design-guide compatibility. EU: recyclability by design under PPWR |
| “Made with X% PCR” | Low risk and strengthening | Supplier documentation and mass-balance or batch traceability for the stated percentage |
| “Refillable” | Low risk | A refill that exists and is available in the market where the claim is made |
| “Mono-material” | Low risk | A bill of materials showing one polymer family across body, cap and label |
| “Plastic-free” | High risk | Every component, including liners, wipers and coatings, which are frequently plastic |
| An own-design green leaf logo | Banned in the EU unless certified | A recognised third-party certification scheme |
What this changes in packaging development
The shift pushes the claim upstream into structural design, because most of these words are decided at material and tooling stage rather than at artwork stage. Three levers carry most of the weight.
Mono-material design
A jar whose body, cap and liner share one polymer family goes through an existing recycling stream. One with an ABS overcap and a PE liner usually does not.
Decided before the mould is cut, not after.
Post-consumer recycled content
A percentage is documentable in a way an adjective never is, which makes PCR the most defensible sustainability statement available to most beauty brands today.
Can the supplier evidence the number you want to print?
Refill formats
A refillable system moves the claim from what the pack is made of to what the buyer does with it — verifiable by inspection rather than by certificate.
Does the refill actually exist in that market?
At Jarsking we work in PCR plastics, refillable and airless formats, PLA and bamboo, applying design for manufacturing and design for recycling through mono-material approaches across a 30-strong packaging design team. Documentation covers ISO 9001, BSCI, RoHS, CE, REACH, MSDS and LFGB, with more confirmed per target market, plus supply-chain traceability — which is what turns a recycled-content number into a claim you can defend. What a specific component can achieve on recycled content, barrier performance or compostability is confirmed per project, because it depends on the formula, the market and the mould.
A pre-launch claims checklist
Seven steps, in order, before artwork goes to repro.
Step seven matters more than it looks. Enforcement asks for the artwork and the evidence together, and a file kept in a separate folder from the approval is the one nobody can find.
Frequently asked questions
Can I still say “biodegradable” on cosmetic packaging?
Only with evidence and, in most cases, qualification. In the EU from 27 September 2026 a bare “biodegradable” is treated as a generic environmental claim and is prohibited unless you can demonstrate recognised excellent environmental performance. In the US the FTC Green Guides require an unqualified claim to mean the entire item completely breaks down within one year after customary disposal, which packaging sent to landfill cannot achieve. A qualified, certified compostability claim is usually the defensible version.
Is “biodegradable” the same as “compostable”?
No, and the difference is the whole point. Biodegradable says only that micro-organisms can eventually break the material down; it sets no time limit and no conditions, and it is not certifiable on its own. Compostable is testable against a standard — EN 13432 in the EU, ASTM D6400 in the US — which specifies how completely and how quickly the material must break down, and under what conditions. If a claim has to survive scrutiny, it should be a compostability certification rather than a biodegradability assertion.
Does the withdrawal of the EU Green Claims Directive mean the rules relaxed?
No. The Commission announced its intention to withdraw that proposal on 20 June 2025, but it was an additional instrument about substantiating and verifying claims. The directive that actually bans generic environmental claims, Directive (EU) 2024/825, was adopted in February 2024 and applies from 27 September 2026 regardless. Enforcement risk went up in 2026, not down.
What is the safest sustainability claim to put on a beauty pack?
A documented recycled-content percentage — for example “bottle made with 50% post-consumer recycled PET”, where the supplier documentation supports the figure. It is specific, it refers to a named component rather than the whole pack, it is verifiable, and it does not depend on a waste-management system existing in the buyer's town. Refillability is a close second for the same reasons.
Do these rules apply if we only sell in the US?
The California and FTC rules apply directly. The EU directive applies to what is placed on the EU market, so a US-only brand is outside its scope today — but packaging is usually tooled once and sold in several markets, and retooling artwork per region is expensive. Most brands find it cheaper to write claims to the strictest applicable standard from the start.
Who is responsible for the claim, the brand or the packaging supplier?
The brand placing the product on the market carries the consumer-facing liability. The supplier's job is to provide the evidence that makes the claim defensible — material declarations, recycled-content documentation, certification records and traceability. That is why claim wording is worth raising at the development stage, when the supplier can still change the structure to support what you want to say.
Where this leaves your next launch
The direction of all three instruments is identical: adjectives out, evidence in. A brand leaning on “eco-friendly” has a real problem in eight weeks. A brand that can say “50% PCR, mono-material, refillable” has a stronger pack and a safer one, and it did not need a new word to get there.
Most of that is settled at structural design, well before artwork. If you are planning a launch into the EU or California and want to know which claims your current structure can support — or how to change the structure so it supports the claim you want — talk to our packaging team. We will look at the bill of materials, the decoration and the market, and tell you plainly which sentences survive.
Related reading: what actually breaks when you switch to eco-friendly packaging · biodegradable materials in packaging
