Greenwashing in cosmetics - how to spot misleading marketing?

Greenwashing is a strategy that consists of ostensibly presenting a product as ecological, natural or environmentally friendly, even though this is not reflected in the actual formulation or production process.. In the cosmetics industry, this phenomenon is becoming particularly apparent, with consumers increasingly opting for products labelled as 'bio', 'vegan' or 'eco', and some companies trying to capitalise on these expectations without any real coverage of ingredients or actions. In this article, we look at what greenwashing in cosmetics really is, how to recognise it, and what, in the context of the greenwashing says the OCCP.

Greenwashing - what does it mean in practice?

Greenwashing - what is it? It is a marketing exercise that aims to create the impression that a brand or product is more environmentally friendly than it actually is. In practice, this means, for example, the use of green colour, leaves on packaging, catchy slogans about 'naturalness', while the cosmetic composition contains only synthetic components and the company does not take any real action for the environment.

It is common to find cases where a single ingredient of natural origin is a trace part of the formula and the whole product is advertised as 'natural' or 'organic'. Such a message may be perceived as credible, especially in the absence of consumer knowledge of cosmetic market regulation.

Greenwashing - definition in the context of cosmetics

Greenwashing - The definition is not explicitly included in Polish law, but these actions can be assessed through the prism of the applicable regulations on counteracting unfair market practices. For the producer, this implies the need to be fully transparent with regard to declarations of composition, production process and labelling.

In practice, if a product contains the term 'natural' and does not meet the criteria for naturalness according to, for example, 'natural', the product will not be considered natural. ISO 16128 standards or has not gone through the appropriate procedures to confirm the declarations - this may be called into question. In the event of serious irregularities OCCP may consider such action as misleading to the consumer.

Greenwashing - what to look out for?

Greenwashing often manifests itself in the use of phrases such as: "eco formulation", "natural care", "nature-friendly cosmetic" - without actually confirming these declarations. The consumer in Poland, as in other countries, does not always have access to full data on ingredients or the production process, which facilitates abuse.

Examples of greenwashing in the Polish reality include:

• using one natural ingredient in a microscopic concentration and advertising the entire product as 'natural',
  
• lack of certification while displaying symbols confusingly similar to certification marks,
  
• promoting cosmetics as "environmentally safe", despite the fact that the production process generates significant amounts of waste or CO₂ emissions.
  

In production, it is therefore worth ensuring transparency - starting with cosmetics formulation and implementation processdown to the final marketing labels.

Greenwashing - examples from the cosmetics industry

Greenwashing - examples of this procedure can be multiplied. In the context of cosmetics, we often encounter packaging with plant graphics when the product composition contains almost exclusively synthetic components. The manufacturer declares that the product or its packaging is biodegradable, but does not provide any testing, certification or information on the decomposition time of the material.

It is also worth mentioning situations where a company declares that there is no animal testing, even though such testing has been banned in the European Union for many years. This is not a distinction, but a legal standard.

Greenwashing and the OCCP - position and consequences

Greenwashing and the OCCP is a topic that has gained in importance in recent years. The Office of Competition and Consumer Protection is increasingly analysing cases of organic marketing and checking whether manufacturers' declarations are misleading. In case of doubt, it can request documentation to substantiate the messages used on packaging, the website or in advertisements.

The absence of such data or the use of empty slogans may be treated as an unfair market practice and the trader may be penalised. Therefore, even before a product is launched on the market, it is worth ensuring transparency and consulting a team that knows how to assess the compliance of the declaration with the real composition - e.g. by working with an experienced safety assessor.

New greenwashing regulations

New EU regulations on greenwashing in the cosmetics industry introduce significant changes to environmental communication and producer responsibility. Directive 2024/825 of the European Parliament and the Council, also known as the Greenwashing Directive, was adopted on 17 January 2024 and came into force on 26 March 2024. EU member states have until 27 March 2026 to implement its provisions into national law, and the legislation will take effect from 27 September 2026.

Key changes for the cosmetics industry:

1. Prohibition of general environmental declarations without confirmation
2. Certification requirement for environmental labels
3. Transparency in environmental impact statements
4. Obligation to document sustainability claims
5. Liability for unfair practices

How to avoid greenwashing when creating cosmetics?

To avoid greenwashing, it is important to ensure that any marketing message is supported by real data. It will be helpful to:

• clearly defining what is meant by the terms used ('natural', 'bio', 'vegan', etc.).
• consistency of the marketing message with the actual composition,
• documentation proving the origin and quality of the ingredients,
• consultation of labels and slogans with regulatory experts,
• thoughtful cosmetics formulation with transparency and security in mind.
  

Every step - from formulation development to stability testing - is worthwhile to be carried out in a place that not only knows the regulations, but also understands the communication risks. Such a service is offered by the cosmetics laboratory, which supports manufacturers in both testing and assessing what can actually be communicated to the customer without fear of greenwashing.

If you want to create cosmetics in an honest and compliant way - benefit from the knowledge and experience of our cosmetics laboratory.