There is a date on the calendar that most beauty founders have not put in their launch plan, and it is close. From 27 September 2026, European Union consumer law treats a generic environmental claim — “eco-friendly”, “green”, “climate neutral”, “kind to the planet” — as a prohibited commercial practice unless the trader can demonstrate recognised, excellent environmental performance. That single change rewires how a clean and sustainable brief has to be commissioned, because the words on the carton stop being a copywriting decision and become an evidence decision. This piece is about what that evidence looks like when the product is being made by somebody else.
Written and researched by Evelyn Chong, Cosmetic Chemist & OEM Industry Analyst · Article type: Independent Editorial · Scope: what the clean, sustainable and science-backed direction in personal care means for brands commissioning products through an OEM (Original Equipment Manufacturer), with Malaysian, ASEAN and European Union reference points · Research period: August 2026 · Last reviewed: August 2026 · Corrections: via the site contact page.
Quick answer: what does a buyer have to prove for a clean or sustainable claim?
A buyer must be able to show, on request, the specific factual basis for every naturality, sustainability or free-from statement on the pack — a calculated natural-origin content figure, a valid certificate from a named certification body, a life-cycle assessment, or test data. None of the common frameworks supplies this automatically: ISO 16128 is a calculation method rather than a certification, COSMOS and NATRUE certify only what has been audited, and an environmental score covers only the impacts it was designed to measure. Before approving artwork, list every green word on the pack and write next to each one the document that supports it. A word with no document has no place on the carton.
Key takeaways
- Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive, applies from 27 September 2026, with Member State transposition due 27 March 2026. It bans generic environmental claims without demonstrated excellent performance, and future-facing claims such as “carbon neutral by 2030” without a verifiable implementation plan.
- The separate Green Claims Directive — the substantiation-and-verification proposal that would have sat alongside it — stalled in 2025. Brands that concluded “the EU dropped the green rules” have confused the two instruments; the one with the near-term deadline is still arriving.
- ISO 16128 produces a natural-origin index. It does not certify, does not maintain a banned-ingredient list, does not assess environmental impact, and rests on supplier declarations that no third party verifies.
- Malaysia’s cosmetic claims guideline is more specific than most brands expect: a certification mark such as ECOCERT may be acceptable but must be substantiated, a Good Manufacturing Practice reference such as ISO 22716 may not be used as a product claim at all, and natural ingredients must not be used to imply that a product is safe.
- The expensive part of a clean brief is rarely the ingredient. It is preservation, stability, and the re-testing that every substitution triggers.
- Ask for the evidence pack at quotation stage, not at artwork stage. By artwork stage the formula is frozen and the only remaining variable is the wording — which is the wrong variable to be adjusting.
Who this is for
This is written for founders, private label buyers, brand managers and sourcing leads commissioning a clean, natural or sustainability-positioned product from an external manufacturer, who will personally sign off the claims on the pack. It is a commercial and evidence view rather than a formulation tutorial: what to specify, what to collect, and where a clean brief quietly becomes expensive. If the brand itself is still being designed around sustainability, the groundwork in our guide to starting a sustainable beauty brand with an OEM manufacturer comes first, and how to evaluate an OEM skincare manufacturer covers the partner-selection stage this article assumes you have reached.
What changes on 27 September 2026, and does it matter outside Europe?
From 27 September 2026, European Union consumer law treats a broad set of vague environmental statements as unfair commercial practices. Directive (EU) 2024/825 amends the Unfair Commercial Practices Directive and the Consumer Rights Directive, and the text is on EUR-Lex. Three of its provisions matter most to a personal care brand.
First, generic environmental claims are prohibited unless the trader can demonstrate recognised excellent environmental performance relevant to the claim, with the EU Ecolabel given as the worked example. “Eco”, “green”, “environmentally friendly” and “nature’s choice” on a bottle of shower gel, with nothing behind them, is precisely the practice being targeted. Second, claims about future environmental performance require a clear, time-bound, independently verified implementation plan; a carbon-neutrality pledge printed on a carton now comes with an audit trail attached. Third, sustainability labels must rest on a certification scheme or be established by public authorities — which removes the self-designed leaf-and-globe badge as an option.
The obvious objection from a Malaysian or wider ASEAN brand is that none of this is their law. That is true, and commercially it is beside the point for three reasons. Export ambition is the first: a brand that intends to sell into the European Union at any point is designing artwork today that has to survive there later, and re-artworking a range is a five-figure exercise. Retailer and marketplace policy is the second — large retail groups tend to harmonise packaging compliance to their strictest market rather than maintain parallel specifications. Contract manufacturing gravity is the third: an OEM serving European customers builds its documentation systems to the European standard, and those systems then serve everybody on the floor.
There is a related confusion worth clearing up, because it has produced a lot of misplaced relief. The Green Claims Directive — a separate and more demanding proposal that would have required substantiation and third-party verification of explicit environmental claims before use — was announced in June 2025 as one the European Commission intended to withdraw, and negotiations were paused. Coverage of that pause was widely read as the EU abandoning its green-claims agenda. It did not. The instrument with the near-term application date is Directive 2024/825, and it was adopted, transposed and is coming into application on schedule.
Does ISO 16128 mean a product is certified natural?
No. ISO 16128 is a calculation framework, not a certification scheme, and that distinction is the single most common source of confusion in clean-beauty sourcing. ISO 16128-2:2017 sets out criteria for classifying cosmetic ingredients as natural, natural-origin, organic or organic-origin, and the arithmetic for rolling those up into an index for a finished product. That is all it does. It does not audit, it does not police a banned-ingredient list, it does not evaluate green chemistry or environmental impact, and the ingredient data feeding the calculation comes from supplier declarations that no certification body checks. NATRUE, the natural-cosmetics association, published a factsheet setting out its position on those limitations, and the criticism most worth understanding is the threshold effect: an ingredient qualifying at just over half natural raw material can contribute to a headline naturality percentage alongside one that is entirely natural.
That is not an argument against using ISO 16128. It is an argument for describing it accurately. “98% natural origin, calculated per ISO 16128” is a defensible sentence. “ISO-certified natural” is not a sentence that exists.
| Framework | What it actually is | What it proves | Who verifies it | What it does not cover |
|---|---|---|---|---|
| ISO 16128-1 / -2 | Definitions and a calculation method for natural and organic origin content | A stated natural-origin or organic-origin index, computed to a published method | Nobody — it is based on supplier declarations | Certification, banned ingredients, processes, environmental impact, packaging |
| COSMOS-standard | A private certification standard for organic and natural cosmetics, audited annually | That the audited product and its ingredients met the standard’s criteria at audit | Approved certification bodies, including Ecocert, Soil Association and ICEA | Carbon footprint, social claims, performance efficacy |
| NATRUE label | A private certification label with three tiers of naturality | Conformity with NATRUE’s ingredient and process criteria for the certified tier | Independent approved certifiers | Life-cycle impact, packaging end-of-life, efficacy |
| EcoBeautyScore | A sector environmental scoring system built on the EU Product Environmental Footprint method | A comparative A–E environmental rating across a product life cycle | The EcoBeautyScore Association’s governed methodology and tool | Naturality, organic content, ingredient safety, social sourcing |
| “Clean beauty” | A marketing position with no legal or standardised definition | Nothing in itself — it means whatever the brand’s own published criteria say | Nobody, unless the brand publishes and applies its own list | Everything, unless separately evidenced |
One entry in that table is newer than the rest and is worth watching. EcoBeautyScore is a non-profit sector initiative co-developed with a large group of cosmetics and personal care companies and associations, built on the European Union’s Product Environmental Footprint methodology. It scores a product from A to E across its life cycle and began appearing on European market products from mid-2025. For a smaller brand it is not a realistic near-term requirement. It matters as a signal of direction: the industry’s own answer to unverifiable green wording is a measured, comparative, life-cycle number — the same direction the regulation is pushing.
What does Malaysia’s regulator actually allow on a natural or organic pack?
Malaysia regulates cosmetic claims through the National Pharmaceutical Regulatory Agency (NPRA) under the ASEAN Cosmetic Directive notification system, and its Guideline for Cosmetic Claims (Annex I, Part 8, August 2022) is more specific about this territory than most brands expect. Four provisions bear directly on a clean or sustainable positioning.
On certification marks, the guideline states that the use of a symbol, logo or statement related to GMP certification — ISO 22716 is the example given — is unacceptable, while other symbols or statements not related to GMP, with ECOCERT given as the example, may be acceptable and must be substantiated. In practice that is a clear instruction: an organic certification mark can go on the pack if you hold the certificate covering that product, but a manufacturing-quality standard cannot be used as a consumer-facing badge at all, however proud the factory is of it.
On safety, the guideline is explicit that products containing natural ingredients should not mislead consumers into assuming the product is safe because it is natural. A great deal of clean-beauty copy sits exactly there — in the implied equation of natural with gentle, and synthetic with harmful. That framing is a claims risk in Malaysia independently of whether it is scientifically defensible. It is also where clean positioning collides with sensitive-skin positioning, a tension examined in our analysis of what sensitive-skin claims require buyers to verify.
On numbers, quantitative performance claims such as 99.9%, in 3 days or 10x are acceptable if substantiated by relevant evidence. A naturality percentage is a quantitative claim. If the pack says 96%, somebody must be able to produce the calculation. And on safety wording generally, phrases implying an absence of any side effects — “no harmful effects”, “no toxic or adverse effects” — are not allowed at all.
The guideline also reserves NPRA’s right to disallow any other word, phrase or graphic it considers misleading, improper or not factual. That residual power is why a buyer should treat the claims review as a live risk assessment rather than a checklist exercise. The same guideline shapes an entirely different category in the same way — see how it constrains the vocabulary of skin longevity and anti-ageing marketing, where cell renewal and DNA repair language sits in the unacceptable column.
What does a clean brief actually cost inside an OEM quotation?
The instinctive assumption is that clean costs more because natural raw materials cost more. Sometimes they do. But in most projects the raw material differential is the smallest line in the change, and treating it as the whole picture is how budgets get set wrongly. The table below sets out where the money actually moves when a conventional brief is rewritten as a clean and sustainable one.
| What the brief changes | What the consumer is promised | Where the cost really lands | Evidence the buyer should hold |
|---|---|---|---|
| Restricted preservative palette | “Free from parabens and formaldehyde donors” | Reformulation cycles, tighter pH and water-activity control, and a preservative efficacy test on the final formula in the final pack | A challenge test report (ISO 11930) on the exact formula, in the exact primary pack |
| Higher natural-origin index | “95% natural origin” | Sensory rework — naturals behave differently in texture, colour and odour — plus batch-to-batch variability management | An ISO 16128 calculation sheet with supplier declarations for every raw material |
| Certified organic content | A COSMOS or NATRUE label on pack | Certification and annual audit fees, a restricted supplier list, certified-ingredient premiums, segregated production and documentation | A valid certificate naming the product and the certification body, with its expiry date |
| Reduced or eliminated water | “Waterless” bars, powders, concentrates | A different manufacturing line and process entirely — often the largest single cost step, and sometimes not available at the incumbent factory | Process capability confirmation and a stability protocol matched to the new format |
| Sustainable packaging | Recycled content, refillable, mono-material | Compatibility and stability re-testing against the new material, plus tooling or minimum-order commitments on components | Compatibility and stability data in the new pack, and recycled-content documentation from the component supplier |
| Life-cycle scoring | An environmental rating on pack | Data collection across the supply chain, which depends on supplier cooperation the brand may not control | The completed assessment, its scope boundaries and its assumptions |
The pattern running through that table is that every clean substitution triggers a test, and the test is usually more expensive than the ingredient. A preservative change is not a swap; it is a swap plus a challenge test plus a stability study, and if the pack material changes at the same time, it is those tests again. This is also why the cheapest clean quotation is so often the one to distrust — not because the supplier is dishonest, but because the tests were never in the number. Our checklist of cosmetic product testing before a first batch is a reasonable way to sanity-check whether a quotation has budgeted the work it implies.
What should a buyer ask before approving the artwork?
The most useful discipline here is mechanical rather than clever. Print the artwork, circle every environmental, naturality or free-from word on it, and require a named document against each circle before sign-off. The questions below are the ones that most reliably reveal whether that document exists.
- Which version of the formula does this natural-origin figure describe, and on what date was it calculated? A figure calculated on a pre-stability formula is a figure for a product you are not selling.
- Can I see the supplier declarations behind the calculation? ISO 16128 rests on them entirely. A supplier who cannot produce them has an index without a basis.
- Does the organic certificate name this product, and when does it expire? A factory-level certificate is not a product-level certificate, and certificates lapse.
- What was the challenge test result, and on which pack? Preservation is the highest-risk consequence of a clean brief, and the primary pack is part of the test.
- If I sell this in the European Union, which words on this pack would you remove? A supplier who has been serving European customers answers this immediately. One who has not treats it as a strange question, which is itself the answer.
- What is the evidence for the packaging claim? Recycled-content and recyclability statements are claims like any other, and they usually belong to a component supplier two steps removed from the conversation.
Two red flags deserve naming. The first is a supplier who describes claims as a marketing decision rather than a technical one — that division of labour is precisely how unsupported wording reaches a carton. The second is any offer to raise a naturality percentage without changing the formula. There is only one way that arithmetic moves, and it is by changing what is in the bottle.
Frequently asked questions
Is “clean beauty” a regulated term anywhere?
No. Clean beauty has no legal definition in Malaysia, the European Union, the United States or any other major market, which means it carries whatever meaning the brand assigns to it. That is a liability rather than a freedom, because a consumer-protection authority assesses the overall impression the packaging creates, not the word in isolation. Brands that use the term durably tend to publish their own restricted-substance list and apply it consistently, so that the phrase points to something verifiable.
Does a natural product need less preservative testing?
It needs more, not less. Restricting the preservative palette generally narrows the margin of microbiological safety, so the preservative efficacy test on the final formula in its final pack becomes both more informative and more necessary. Natural extracts and botanical waters can also add nutrient load that supports microbial growth. Budget the challenge test as a certainty in a clean brief, not a contingency.
Can we put our factory’s ISO 22716 certification on the pack in Malaysia?
No. The NPRA cosmetic claims guideline states that a symbol, logo or statement related to GMP certification, giving ISO 22716 as its example, is unacceptable. Certifications not related to GMP, such as ECOCERT, may be acceptable and must be substantiated. Manufacturing-quality credentials belong in supplier documentation and trade communications, not on the consumer-facing carton.
We only sell in Southeast Asia. Can we ignore Directive (EU) 2024/825?
Legally yes; commercially it depends on where you intend to be in three years. The directive binds traders selling to consumers in the European Union, so a purely domestic brand sits outside its scope. The practical argument for designing to it anyway is that artwork and evidence packs are expensive to rebuild, export ambitions usually arrive faster than compliance systems, and large retail buyers increasingly apply their strictest market’s standard across a whole range.
Is a higher natural-origin percentage better for the skin?
Not inherently, and Malaysia’s claims guideline warns specifically against implying that a product is safe because it contains natural ingredients. Naturality is a compositional statement about where materials originate, not a performance or tolerance statement. Skin tolerance is established by testing the finished formula, not by reading its origin index.
Who is responsible if a claim turns out to be unsupported, the brand or the manufacturer?
The brand whose name is on the pack carries the consumer-facing responsibility in most jurisdictions, including under the Malaysian notification framework where the notification holder is accountable for the product as placed on the market. Contractual arrangements can allocate cost between brand and manufacturer, but they do not move regulatory or reputational exposure. That is the practical reason to collect the evidence yourself rather than assume it exists somewhere in the supply chain.
Sources and further reading
- Directive (EU) 2024/825 — Empowering Consumers for the Green Transition; transposition due 27 March 2026, application from 27 September 2026.
- NPRA, Guideline for Cosmetic Claims — Guidelines for Control of Cosmetic Products in Malaysia, Second Edition, Annex I Part 8, August 2022.
- ISO 16128-2:2017 — criteria for natural and organic cosmetic ingredients and products.
- NATRUE factsheet on ISO 16128 — a critical reading of the standard’s scope and limits.
- COSMOS-standard and the EcoBeautyScore Association — the certification and the environmental-scoring routes respectively.
- Source / inspired by: Azelis Personal Care, “Clean, sustainable, and science-backed”, from the Azelis Personal Care inspiration hub, which prompted this analysis.
- Further reading from the manufacturing side: ORIZI Group’s R&D team on why a clean and natural brief becomes a preservation problem before it becomes a marketing one.
Limitations of this analysis
This article summarises regulatory instruments and voluntary frameworks as they stood in August 2026 and is not legal advice. Directive (EU) 2024/825 takes effect through national transpositions, so specific wording and enforcement practice vary by Member State and should be checked for each target market. Certification scheme criteria are revised periodically; always work from the current version of a standard rather than a summary of it. No formulations, test reports or supplier documents were reviewed in preparing this piece, and no manufacturer was assessed. Where a claim on a real product is at stake, the substantiation file for that product is the only authority that matters.
This article is general industry analysis for brand owners and sourcing teams. It is not regulatory, legal or formulation advice, and it does not assess any specific product, supplier or claim. Verify requirements for your own market and product with the relevant authority and with qualified advisers before relying on them.