Greenwashing Rules Are Live: What to Do With Your Old Stock, and Where to Go Next
The EU's greenwashing rules are no longer coming. Directive (EU) 2024/825 on empowering consumers for the green transition began to apply on 27 September 2026. For cosmetics and personal care brands, the more urgent question is not what future packaging should say, but what to do with the tubes, jars and bottles already printed and sitting in the warehouse.
What the directive changes
The directive updates EU consumer law on unfair commercial practices. Broadly, it targets vague or unprovable environmental messaging:
• Generic claims such as “eco-friendly”, “green” or “sustainable” are problematic unless the brand can back them with recognised excellent environmental performance.
• Sustainability labels that aren't based on a certification scheme, or set by a public authority, are restricted.
• Offset-based claims, such as saying a product is “climate neutral” because emissions are compensated elsewhere, are banned.
• Future promises, such as “net zero by 2030”, need a credible, verifiable plan behind them.
None of this is entirely new. Misleading environmental claims were already unfair commercial practices. The directive makes the rules sharper and harder to argue around.
The old stock problem
Printed packaging is a long-lead item. A tube ordered in spring with “eco” printed on the shoulder cannot be edited in September. Many brands are holding stock, or have stock in distribution, that carries wording that is now risky.
EU consumer authorities have signalled that old stock is not a free pass, but that enforcement will be proportionate. Sell-through stock is treated differently from a brand that has done nothing. In practice, regulators are likely to look at three things: how quickly the product turns over, how big the company is, and whether the brand can show it acted in good faith. Destroying sellable stock is generally seen as a poor outcome, both financially and environmentally.
For a more detailed look at the authorities' position, Cosmeservice has published a useful overview of the regulatory guidance on old stock: Greenwashing Directive: what to do with your old stock.
A practical plan for existing inventory
1. Start with what can be fixed today. Websites, marketplace listings, social posts, retailer sheets and adverts can all be edited immediately. There is little justification for leaving a risky claim online while the physical stock sells through.
2. Audit every SKU. List which products carry environmental wording, where it appears (pack, carton, leaflet, web) and how much stock exists. Sort them into three groups: fast sellers, slow sellers and items due for reprint anyway.
3. Choose a proportionate fix for the physical pack. Options include overstickering the claim, removing it in a re-labelling step, or adding clarifying information at the point of sale. Overstickering is usually cheaper than writing off goods.
4. Keep a paper trail. Record what you changed, when and who decided it. If an authority asks questions, a dated log carries far more weight than a promise to fix things later.
5. Fix the next print run. The most valuable step is making sure the next order of packaging does not repeat the problem. This is also the moment to reconsider the material itself.
Better claims, better materials
Removing a vague claim doesn't mean you have nothing to say. It means replacing adjectives with facts. “Eco tube” says nothing. A specific, measurable statement about what the pack is made from can survive scrutiny.
This is where material choices matter. Sugar cane tubes are one example. They are typically made from bio-based polyethylene, where the plastic's carbon comes from sugar cane rather than fossil oil. The resin is chemically the same as conventional PE, so these tubes generally fit existing PE recycling streams, and the renewable content can be verified by testing. That gives brands something concrete to communicate, as long as the wording is precise.
Norse Packaging supplies sugar cane tubes for brands looking to rework their packaging range ahead of the next print cycle. If you are planning a reprint anyway, it is a natural time to talk to them about specifications, minimum orders and lead times.
Wording that holds up, and wording that doesn't
Even good materials can be described badly. A few rules of thumb:
• Be specific. “Tube made with 90% bio-based plastic from sugar cane” is better than “planet-friendly packaging”. Only use the figure your supplier can certify.
• Don't confuse bio-based with biodegradable. Bio-based describes where the raw material comes from. It says nothing about what happens at end of life, and bio-based PE does not biodegrade.
• Don't overclaim recyclability. Say what is true in the markets where you sell, and remember that recycling depends on local collection systems, not just the material.
• Keep the evidence file. Certificates, test reports and supplier declarations should be stored and ready to produce.
• Avoid implied benefits. A green leaf icon or an earthy colour palette can create the same impression as a banned phrase.
The bottom line regarding greenwashing
The directive doesn't punish brands for having old stock, but it does reward those that can show they acted quickly and sensibly. Clean up digital channels now, document your decisions, handle physical stock proportionately, and use the next packaging order to build claims on real, verifiable specifics. Done well, this turns a compliance headache into a chance to make packaging choices you can stand behind.
© Norse Packaging - info@norsepackaging.com
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This blog is for informational purposes only and is not legal advice, so please consult a qualified professional about your specific situation.
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