Consumers all over the world are becoming increasingly and concerned about the sustainability of the products they buy and use. It is becoming more and more common to stand in front of a shelf and check both the package and the ingredients of the product before buying it.

Greenwashing or customer misleading
Cosmetic product claims such as «natural», «organic», or that the packaging is «recyclable» are known drivers that can influence consumer purchasing habits and have a commercial advantage. However, the combination of the fact that environmental claims may be qualified through self-declarations or third-party certifications, together with the lack of specific, harmonised requirements for such product claims, like natural or organic, leaves a regulatory gap exposing a notable risk to mislead the consumer via greenwashing. This begs the questions: What should we be aware of? How can we inform ourselves? What can we look out for?
Limits of existing regulation
The main problems lie with factors such as ingredient definitions, the lack of harmonised criteria, and product claims substantiation, which all limit the powers of authorities to enforce existing law. Taking the EU Cosmetics Regulation as an example, to-date although the law sets common criteria for product claims the legislation does not clearly define what is meant by a «natural» or «organic» claim. Therefore, there is no precise interpretation of how such claims apply to cosmetic products without being considered misleading. These regulatory gaps raise the risk of greenwashing through misleading claims and lower the ability of shoppers to easily distinguish between brands whose products are committed to environmental and social responsibility and those that pay lip service to these terms through inventive marketing. It’s precisely here that private standards allowing for third-party certification come into play to support producers whilst reassuring and orientating consumer choice.
Regulatory loopholes increase risk of greenwashing through misleading claims
In a bid to tackle greenwashing and support claims based upon verifiable criteria, one obvious solution for producers is to voluntarily opt to certify their products to well-established, recognisable, and transparent standards, such as that developed by NATRUE, which set label criteria. The data confirms it: according to a survey carried out by GlobalData, in the last quarter of 2021 two out of five (41%) European consumers believed that verified certifications are a key factor when buying goods, including beauty products and personal care.
Make it easier to identify the labels
But how can consumers know if a logo is truly reliable? The British Beauty Council‘s Sustainable Beauty Coalition (SBC) addressed this exact concern. It is clear shoppers want their beauty routines to go «easier» on the planet, but they don’t know where to start. So the SBC compiled the «Planet Positive Beauty Guide», a guide to help shoppers easily recognise respected standards and logos in the marketplace, to assist consumers in making greener beauty choices. The Guide includes definitions of the most used claims in relation to ingredients, packaging, or sustainable sources – among others – and also provides examples of verified certifications and logos, which can help buyers to know what to look for when making a purchase.

When it comes to various environmental claims the level of risk to be misled that the consumer faces may vary from country to country, as shown in NATRUE’s 2021 study. However, this risk is never completely removed. Recently, we’ve seen both national and European initiatives focusing on substantiation of green claims and added consumer protection in the advent of greenwashing. For example, in September 2021 the UK’s independent regulatory body, the Competition & Market Authority (CMA), published its Green Claims Code to help business and companies communicate their eco credentials on any type of product, service, or brand without misleading consumers. The need is evident: a recent international analysis carried out by the CMA found that as much as 40% of firms’ green claims could be misleading.
What to look for when reading a label?
Another problem that the shopper faces is labelling and understanding and interpreting all the information on-pack. When it comes to the regulatory status quo for cosmetics and for shoppers wanting to purchase a truly natural or organic cosmetic, the only assured way is to look for a certification label on the packaging. Unfortunately, logos and other iconographic claims on-pack may masquerade as if they were certification seals but are, in fact, self-declarations using a brand’s own graphics which, on closer inspection, do not correspond to any recognised standard and do not include any third-party verification process. Consequently, with so many labels on the market, whether self-made or from independent certification – and given not all label criteria are the same, it remains important that consumers look for certification seals, contact the brand and also contact the independent standard setter to table any questions they may have to ensure the product meets their expectations. When it comes to certification seals, consumers can also visit online database from the standard owner to identify and confirm those products that carry the seal, such as the NATRUE database. Lastly, to ensure a harmonised approach the label criteria should be applicable internationally, as NATRUE is, to guarantee consumers that the same benchmarks are met from cosmetic products with respect to claims like natural and organic regardless of where the product is marketed around the globe.
Overall, consumers should be aware that there may be noticeable differences between the labels, hence the need to appropriately orientate and inform themselves when it comes to the trustworthiness of claims and claim substantiation tools for natural and organic cosmetics.
Consumers should be aware that there can be significant differences between seals, hence the need for proper guidance and information
In this context, where we can be exposed to delusive information on the «green» nature of products, the risk of being misled by environmental claims has not gone away but rather become less blatant and more subtle.
The natural cosmetics sector is a dynamic and constantly growing sector within the industry, which for decades has been committed to helping to contribute to products focused on lower environmental impact, responsible sourcing and social sustainability. As the expansion of interest in the sector grows it is critical that the trust fostered in the sector is upheld, so it remains important to ensure the integrity and honesty of green claims for cosmetic products. Our advice is clear: ask yourself the factors important that are to you, contact the brand and/or standard owner with any questions you have, and when you purchase look for well-established, verifiable, and international labels!
Author: Paula Gómez de Tejada, Paula Gómez de Tejada Espinosa, Communications Officer at NATRUE
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Bio Eco Actual, Independent European Organic Press
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