Open any skincare site and count the green words. Eco. Clean. Conscious. Kind to the planet. Climate neutral. Sustainable.
We use none of them, and we are not going to. Part of the reason is a decision we made early. Part of it is a rule that arrives in Europe on 27 September 2026.
What changes on that date
Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive, was adopted in February 2024 and applies from 27 September 2026. It adds a set of practices to the list of things that are unfair in every circumstance, with no case-by-case assessment required.
Four of them are worth knowing as a reader, because they describe most of what is currently printed on packaging.
A generic environmental claim is prohibited unless the trader can demonstrate recognised excellent environmental performance relevant to the claim. Environmentally friendly, eco-friendly, green, sustainable. The words themselves are not banned. Using them without being able to show the performance behind them is.
A sustainability label is prohibited unless it is based on a certification scheme or established by a public authority. A leaf-shaped badge a brand designed for itself is not a certification. It now has to come from a scheme with third-party verification, or from a public body.
A claim about the whole product is prohibited when only one aspect qualifies. Recycled packaging is a fact about the packaging. It is not a fact about what is inside it.
A claim of neutral, reduced or positive greenhouse gas impact is prohibited where it is based on offsetting. This is the one that surprises people. A brand that buys offsets and prints climate neutral on the box will no longer be able to do so.
And one that will sound familiar
There is a fifth, and readers of an earlier piece here will recognise it immediately. It is prohibited to present a requirement imposed by law on every product in the category as though it were a distinctive feature of yours.
That is the same principle we wrote about in the context of free from claims. You cannot advertise obeying the law as an achievement, because every compliant product on the shelf is in exactly the same position. It applied to ingredient claims already. Now it applies to environmental ones.
Two things this does not mean
It does not mean that brands using these words have been breaking the law. Until 27 September the position is different, and much of what is printed today was written in good faith under the rules as they were. We are describing a change, not accusing anyone.
And it does not apply to us yet. This is an EU directive. Switzerland is not bound by it, and we are a Swiss company selling first in Switzerland. It becomes directly relevant to us when we sell into the European Union, which is planned for late 2027.
We are writing about it a year early because we would rather build to the stricter rule from the beginning than retro-fit our packaging when it arrives.
Why we had already decided
The honest reason we say none of this is not the directive. It is that we cannot substantiate it.
We make one product. We do not have a life cycle assessment. We have not measured our emissions. We do not know, with evidence we could put in front of someone, whether our packaging is better or worse than the alternative we did not choose.
A brand that cannot measure something should not describe it. That is the same standard we apply to what the product does to your skin, and there is no reason environmental claims should be held to a lower one.
We could buy a certification. We could design a green leaf and put it on the jar. Both would be legal today and one of them would not be legal in Europe in a fortnight. Neither would be true in the sense that matters, which is that we would not have done the work.
The test we apply
The same one, in a different subject. Can we state it plainly, can we show the evidence, and can we explain it without implying anything about products that chose otherwise.
If it fails any part of that, it does not go on the label, and it does not go on this website.
When we have measured something, we will publish the measurement and the method. Until then the honest description of our environmental performance is that we have not established it.
That is a worse sentence for marketing and a better one for you.