How Do I Tell If a Skincare Brand Is Actually Sustainable or Just Greenwashing? A Safety Assessor 12 Point Check

A safety assessor reads cosmetic labels for a living, and sees something a consumer rarely does: the file behind the pack. The Product Information File holds the evidence for every claim a brand makes, or it does not, and the gap between the front of the box and the contents of the file is where greenwashing lives. In the UK the Competition and Markets Authority's Green Claims Code sets out what an environmental claim must be to be lawful, the Advertising Standards Authority rules on green claims in beauty advertising every month, and Regulation (EU) No 655/2013 on cosmetic claims, retained in Great Britain, requires every claim on a cosmetic to be truthful, evidence based, honest and fair. The rules exist. The trick is knowing how to apply them from the outside.

This guide gives you the assessor's twelve point check, written for anyone who wants to buy honestly and for any brand that wants to be trusted. It explains what the common greenwashing words actually mean, how to read the ingredient list against the front of the pack, which certifications can be verified and how, what free from claims are really doing, why packaging claims need a specific test, how to weigh carbon and sustainability language, where to look when a brand talks about sourcing, the difference between evidence and testimonials, and what the law lets you expect. It ends with a worked example of one product page taken apart in ten minutes. You will not need a chemistry degree. You will need to read the back of the box.

What does greenwashing actually mean in cosmetics?

Greenwashing is presenting a product, a brand or a practice as more environmentally or ethically beneficial than it is. In cosmetics it takes a few recognisable forms: vague language that implies virtue without stating a fact, imagery that suggests nature without a natural formula, claims about the absence of ingredients that were never a problem, certifications that do not exist or cannot be checked, packaging described as recyclable or biodegradable without the conditions that make it so, and single attributes, one recycled bottle or one natural ingredient, presented as if they described the whole product. None of this requires a lie. Most greenwashing is true in a narrow sense and misleading in the impression it creates, which is exactly the test the Green Claims Code and the cosmetic claims criteria apply.

The twelve point check

What do natural, clean, green and eco really mean?

Nothing, in law. None of the four has a legal definition in cosmetic regulation, so each means whatever the brand decides, and the claims criteria then judge whether that meaning is truthful and whether a consumer would be misled. A brand that says natural and defines it, for instance by stating a percentage of naturally derived ingredients calculated under ISO 16128, has made a claim you can check.

A brand that says natural above an ingredient list led by water, a synthetic emollient and a silicone has made a claim the list contradicts. Clean has the additional problem that it implies other products are dirty, which is the fairness objection the claims criteria raise. Green and eco usually describe packaging or sourcing rather than the formula, and need to say which.

This matters because cosmetic products placed on the UK and EU market must comply with the applicable EU cosmetics regulation or UK framework, including the rules governing cosmetic claims. Claims should not contradict the product's actual composition, safety information or supporting evidence.

Our guide to natural, organic and chemical-free claims goes deeper on each word.

How do I read the ingredient list against the front of the pack?

The ingredient list, headed Ingredients and written in INCI names, is the only part of the pack the law requires to be complete and in order. Ingredients appear in descending order of weight down to one percent, then in any order, so the first five or six names are most of the product.

Read them first. If the front says plant powered and the first names are Aqua, Cetearyl Alcohol, Dimethicone and Glycerin with the botanical extract twelfth, the botanical is a garnish.

If the front says organic and only one ingredient carries an organic marker, the product is not organic. Latin binomials are plant materials; long chemical names are usually synthetic or synthetically modified, which is not bad, but it is not what the front implied.

Aqua at the top is normal for a lotion and says nothing about greenness either way. Parfum near the bottom with a list of named allergens after it tells you the product is fragranced whatever the front says about being gentle.

The ingredient list should also be consistent with the formulation information held in the Product Information File (PIF) and the product's safety assessment report. The PIF provides the supporting documentation behind the finished cosmetic product and its safety assessment.

Why are free-from claims so often greenwashing?

Because most of them describe the absence of something that was never a problem in that product, or that is banned anyway, and the claim exists to imply that competitors are unsafe.

Paraben-free is the classic: parabens are lawful, assessed safe and widely used, and the claim trades on a scare that the science does not support. Sulfate-free on a leave-on cream is meaningless because sulfates are cleansing surfactants that would never be in it. Free from banned substances is a legal requirement dressed as a virtue.

In the UK and EU the claims criteria and the Commission's technical document say free-from claims are acceptable only where they give the consumer genuinely useful information, such as fragrance-free for someone with a sensitivity, and are not acceptable where they denigrate lawful ingredients.

The safety of a cosmetic product is assessed through the relevant Cosmetic Product Safety Report, including the toxicological evaluation and margin of safety where applicable. A free-from statement should therefore not be used as a substitute for the actual safety assessment report or evidence supporting product safety.

A brand leaning on free-from claims is telling you it would rather you looked at what is not in the product than at what is.

Which certifications can actually be verified?

A certification is only worth the register behind it. COSMOS, operated through Soil Association, Ecocert, BDIH, Cosmebio and ICEA, certifies natural and organic cosmetics against a published standard and lists certified products.

The Soil Association and Ecocert publish searchable databases. Leaping Bunny maintains a public list of approved cruelty-free brands. B Corp publishes every certified company with its score. Vegan Society and similar marks have registers.

If a logo appears on a pack, search the scheme's register for the brand or product; if it is there, the claim is verified, and if it is not, the logo is decoration.

Logos that a brand has designed for itself, and phrases such as certified natural with no scheme named, cannot be verified and should be treated as claims without evidence.

Certification is separate from the regulatory safety assessment. A certified cosmetic still needs the applicable Cosmetic Product Safety Report, Product Information File, Responsible Person (RP) and other requirements relevant to the market in which it is placed on the market.

How do I judge packaging claims?

Recyclable, biodegradable, compostable and refillable each need conditions to mean anything. Recyclable depends on the material and the local system; widely recycled and check locally are the honest forms, and a pump with a metal spring in a plastic bottle is often not recyclable at all.

Biodegradable depends on the environment and the timescale; a material that biodegrades in an industrial composter over months is not biodegradable in a hedge, and glitter and microplastics are the frequent offenders.

Compostable should say home or industrial. Refillable should mean a refill is actually sold.

Packaging waste rules in the UK and EU are tightening the language, and a claim without conditions is a claim that will not survive them. Our guide to packaging regulations covers the legal side.

What about carbon neutral, sustainable and ethical?

Carbon neutral is a calculation and an offset, and it means something only when the brand states the scope of what was measured, the method, and the offsets bought and from whom; a carbon-neutral product that measured only the factory's electricity and bought cheap offsets is not what the words imply.

Sustainable is the broadest word of all and should be treated as a heading rather than a claim: ask what, specifically, is sustainable about the formula, the packaging, the sourcing and the manufacturing, and expect an answer on each.

Ethical usually refers to labour, sourcing or animal testing, each of which has its own evidence: a supplier code, a fair-trade certification, a Leaping Bunny listing.

A brand that uses the big words and can point to the small facts beneath them is telling the truth. A brand that uses the big words instead of the small facts is not.

For brands operating across the UK and EU, the claims assessment should sit alongside the wider cosmetic regulation requirements. The qualified safety assessor evaluates product safety, while the Responsible Person has obligations relating to the compliant placing of the product on the market. Relevant SCCS opinions, Regulation 1223/2009, safety data and the product's overall evidence may all form part of the regulatory picture.

What does the law let me expect?

In the UK the Green Claims Code, enforced by the Competition and Markets Authority, requires environmental claims to be truthful and accurate, clear and unambiguous, not to omit or hide important information, to compare fairly, to consider the full life cycle and to be substantiated. The Advertising Standards Authority applies the same principles to advertising, including social media, and publishes rulings against cosmetic brands regularly. The cosmetic claims criteria require every claim on a cosmetic to meet legal compliance, truthfulness, evidential support, honesty, fairness and informed decision making, and require the brand to hold the evidence in its Product Information File, which a regulator can demand. So a consumer is entitled to expect that any green claim on a cosmetic is backed by something the brand could produce, and a brand is on notice that it may be asked to produce it.

How does a brand avoid greenwashing by accident?

• Define every green word you use. Say what natural, clean and sustainable mean for your product, in numbers where possible.
• Keep a claims table. One row per claim, with the evidence, in the PIF.
• Certify where a scheme exists. And use the logo only for products on the register.
• Describe packaging with conditions. Widely recycled; industrially compostable; refill available.
• Drop free from claims about lawful ingredients. They fail fairness and invite complaints.
• Say what you have not yet done. Honesty about a conventional bottle beside a natural formula builds more trust than silence.
• Check the website, the pack and the adverts say the same thing.

Phoenix's label and claims review applies exactly this check before print, and the free Marketing Claim Checker flags the words that fail.

A worked example: one product page in ten minutes

A body lotion is presented as clean, green and plant powered, free from parabens and sulfates, in eco packaging, made by a brand that describes itself as sustainable. Check one: clean, green and plant powered are undefined, three fails. Check two: no certification, no study, no method, a fail. Check three: the ingredient list begins Aqua, Glycerin, Cetearyl Alcohol, Dimethicone, Isopropyl Myristate, with Aloe Barbadensis Leaf Juice ninth and Helianthus Annuus Seed Oil eleventh; plant powered is contradicted, a fail. Check four: paraben free and sulfate free on a leave on lotion, two fails, one of them meaningless. Check five: no logo, no register, a fail. Check six: eco packaging with no material, no recyclability statement, a fail. Check seven: nothing on sourcing or manufacturing, a fail. Nine fails in ten minutes. The product may be a perfectly pleasant lotion. Its page is greenwashing from top to bottom, and in the UK several of its claims are unlawful.

Myths we hear

• Natural means safe and synthetic means harmful. Neither is true; safety is assessed ingredient by ingredient at the level used.
• Paraben free means the brand cares. It usually means the brand has read the same scare articles as its customers.
• A leaf on the pack means something. It means a designer drew a leaf.
• Certified natural is a certification. Only if a named scheme with a register certified it.
• Small brands do not greenwash. Small brands greenwash by accident more often than large ones do on purpose.

What to do this week

• Take three products from your bathroom and run the twelve point check on each.
• For any certification logo, search the scheme's register.
• Read the first six ingredients on each and compare them with the front.
• If you are a brand, build your claims table and delete every claim without a row.
• Replace vague words with numbers and conditions.

Greenwashing survives because nobody checks. Ten minutes and the back of the box are all it takes to check, and a brand that welcomes the question is a brand worth buying from. Brands that want their claims to pass the check can book a claims review before the next print run.

Official sources and legislation

• CMA Green Claims Code
• Advertising Standards Authority
• Regulation (EU) No 655/2013 on cosmetic claims
• Regulation (EC) No 1223/2009 on cosmetic products
• OPSS guidance on cosmetic products regulations

Disclaimer: This article is general information, not legal advice. Regulations change and product decisions depend on your exact formulation, claims and market. Have your product assessed by a qualified professional before sale.