Over the last few years, the cosmetics industry has made considerable progress in terms of sustainability. Lighter packaging, recycled materials, reusable formats, monomaterial solutions, ecodesign, and materials of renewable origin are already part of many innovation projects.

But the context is changing. The question is no longer solely how to develop packaging with better environmental performance, but also how to demonstrate that performance and how to communicate to the consumer, precisely, what can truly be accredited.

Two European developments are especially relevant in this process: the Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), applicable from August 12, 2026, and Directive (EU) 2024/825, known as EmpCo, whose national provisions must be applied from September 27, 2026. The legal nature of both instruments is different: PPWR is a directly applicable Regulation, while EmpCo is a Directive that requires national transposition.

Although each standard addresses different aspects, both reinforce the same trend: greater transparency, better information, and a greater need to substantiate environmental claims.

PPWR: packaging enters a new stage

The PPWR establishes a harmonized framework for packaging and its waste throughout its life cycle. Among other aspects, it introduces requirements related to design, reuse, information, and certain characteristics of packaging. The Regulation itself foresees that certain conformity requirements will be based on technical information.

For the cosmetics industry, this means that certain decisions traditionally made primarily from design, marketing, or cost will increasingly have to incorporate environmental and regulatory criteria.

Some questions are especially useful:

• Is it necessary to use so much material?
• How is the packaging composed?
• Is it designed with its recyclability in mind?
• Does it contain recycled material and how is it demonstrated?
• What happens with the different components of the packaging?
• What technical information can we obtain from our suppliers?
• What requirements will be relevant for the specific format and on what date will they be applicable?

These questions should connect Packaging, R&D, Purchasing, Quality, Regulatory, and Sustainability. Packaging is no longer solely an aesthetic matter: it is also a technical, regulatory, and strategic issue.

EmpCo: when the environmental claim needs to be backed up

EmpCo modifies European consumer protection rules against certain unfair commercial practices. Among other measures, it introduces restrictions on certain generic environmental claims when excellent recognized environmental performance relevant to the claim cannot be demonstrated. It also addresses claims about the entirety of a product or company when, in reality, they only refer to a specific part or activity.

For a cosmetic brand, this makes it especially important to review the language used in packaging, e-commerce, advertising, websites, and social media.

Expressions such as "sustainable," "environmentally friendly," "green," "ecological," or "biodegradable" should not be analyzed solely from a creative point of view. It is necessary to ask what exactly the claim means and what evidence it is based on.

The Directive itself offers a very illustrative example: a claim about a product made with recycled material can be problematic if it creates the impression that the entire product is made with that material when in reality the characteristic only applies to the packaging.

From claim to evidence

A mature sustainability strategy can start with a simple sequence:

CLAIM → CRITERION → EVIDENCE → COMMUNICATION

First, what is to be communicated is identified. Then, what the claim means and what its criteria are is specified. Next, the available evidence is collected. Finally, the commercial message is adjusted to the actual scope of that evidence.

The goal is not to limit environmental communication, but to make it more precise and understandable.

Recyclable does not mean the same as recycled 

"Recyclable packaging" and "packaging with recycled material" are different claims.

The first refers to a characteristic related to the possibility of recycling the packaging under certain conditions. The second refers to the incorporation of material from recycling processes. Recycled content can also be expressed as a percentage and requires an adequate documentary basis.

Therefore, when faced with a broad expression like "sustainable packaging," it is useful to first identify which specific characteristic is to be highlighted.

The more precise the statement, the clearer it will be what needs to be demonstrated.

The scope of the claim can change its meaning

In cosmetics, product and packaging usually appear in the same communication. This makes differentiating the scope especially important.

It is not equivalent to state "The jar contains 80% recycled plastic" as to state "The product is made with 80% recycled material." The first sentence identifies the element to which the characteristic refers; the second can extend it to the complete product.

The precision of the scope is not a purely linguistic detail. It determines what evidence must exist behind the statement and helps prevent the consumer from receiving a broader impression than the characteristic actually accredited.

Where do certification and verification fit in?

Certification and verification can provide different tools and should not be confused with the claim itself.

A certification accredits compliance with the requirements of a standard or scheme within a defined scope. A verification can focus on a specific characteristic, information, or statement against certain criteria. The claim, on the other hand, is the message that the consumer ultimately receives.

Having a certification does not automatically mean that any environmental claim related to the product is covered by it.

Therefore, in addition to the certificate, it is advisable to review its scope, the applicable standard, the product or material covered, and the rules for using the associated declarations.

In certain projects, an independent review can help identify whether the available evidence is sufficient for the intended claim and whether there is consistency between technical documentation, certifications, and commercial communication.

Traceability will become increasingly important

To demonstrate certain environmental characteristics, companies will need reliable information throughout the supply chain. Depending on the claim, it may be relevant to have information on:

• packaging composition
• raw materials and suppliers
• recycled content and percentages
• transformation processes
• components, inks, adhesives, and closures
• technical documentation
• traceability
• recyclability assessments
• certifications and verifications

This makes packaging sustainability a cross-functional job. Packaging, Purchasing, Quality, Regulatory, R&D, Sustainability, and Marketing need to share information and criteria.

Five questions before launching an environmental claim

1. What exactly are we claiming?

Is there a specific characteristic we can communicate instead of using an overly broad term?

2. To what part of the product does it refer?

To the complete product, the packaging, a component, or a raw material?

3. What evidence do we have?

Could an independent third party review the documentation and understand how the conclusion was reached?

4. Does the certification or verification truly cover that claim?

The name of a standard or certificate does not replace a review of its scope.

5. Are we communicating more than we can demonstrate?

This question is especially useful before approving packaging, a campaign, or a website.

An opportunity to professionalize sustainability

PPWR and EmpCo should not be understood solely as new obligations. They can also help companies professionalize the management of their environmental claims.

A brand that knows what it claims, what criteria it applies, what evidence it has, what has been certified or verified, and how it should communicate is in a stronger position to manage its environmental messages.

This approach can also improve coordination between suppliers, internal teams, and technical partners, and facilitate more consistent communication across different markets.

From "sustainable packaging" to "demonstrable packaging"

The change can be summarized in one idea:

It's not just about a package having better environmental characteristics. It's about being able to identify what those characteristics are, demonstrate what is relevant, and communicate them precisely.

For a cosmetic brand, this means connecting design, packaging, suppliers, regulation, certification, evidence, and marketing.

In this context, having an independent technical interlocutor can be useful for organizing requirements, reviewing the scope of a certification or evaluation, and assessing the solidity of the evidence before converting it into a commercial message.

The choice of organization or expert will depend on the standard, the type of claim, the product, and the market. The important thing is that there is a clear methodology, defined criteria, and a verifiable correspondence between what is claimed and what can actually be demonstrated.

From this perspective, the objective should not be to simply find a seal or a commercial phrase, but to build a technical basis that allows for safe and transparent communication.

For companies that want to review these types of issues, an initial diagnosis of the packaging, the claims used, and the available evidence can be a practical starting point before deciding which certification, verification, or evaluation is appropriate.

In Spain, this type of analysis can be approached with specialized organizations that are familiar with both certification schemes and the particularities of environmental communication in the sector. Ecocert Ibérica can be one of the technical interlocutors to consider when the project fits within its areas of certification, evaluation, or verification.

The question a brand should ask itself before launching its next environmental claim is not only:

"Can we say that our packaging is sustainable?"

But:

"What specific environmental characteristic do we want to communicate and can we demonstrate it?"

This change in perspective will become increasingly relevant for the cosmetic industry.