New rules for packaging, ingredients and green claims
The EU Packaging Regulation has applied since 12 August 2026 and the new rules on green claims since 27 September 2026, and substance bans for cosmetics, textiles and food packaging come on top. COBACK reads the new publications every day and shows which of them could affect your products, brands and markets, and why.
Topics and rules
What is changing, who in the company works with it and which legal acts are behind it.
Packaging
The Packaging and Packaging Waste Regulation has applied directly in every Member State since 12 August 2026. In Germany the Packaging Law Implementation Act replaced the Packaging Act on the same day. Harmonised sorting labels follow from 2028, rules on recyclability and recycled content from 2030. Packaging development, procurement and producer registration are affected.
Examples
- Packaging and Packaging Waste Regulation (EU) 2025/40
- German Packaging Law Implementation Act (VerpackDG)
Food contact
Since 12 August 2026 food packaging containing PFAS above the limits of the Packaging Regulation may no longer be placed on the market. Bisphenol A is banned in food contact materials. The general transition period ended on 20 July 2026; for some products, such as cans for fruit, vegetables and fish or professional food production equipment, it runs until 20 January 2028. Quality assurance, packaging procurement and supplier management are affected.
Examples
- Food Contact Materials Framework Regulation (EC) No 1935/2004
- Bisphenol A Regulation (EU) 2024/3190
- Plastics Regulation (EU) No 10/2011
Ingredients in cosmetics
The Commission regularly adds substances newly classified as carcinogenic, mutagenic or toxic for reproduction to the list of substances banned in cosmetics, for example with effect from 1 September 2025. Intentionally added microplastics are banned in rinse-off cosmetics from 17 October 2027 and in most leave-on products from 17 October 2029. Research and development, regulatory affairs and raw material procurement are affected.
Examples
- Cosmetic Products Regulation (EC) No 1223/2009
- Regulation (EU) 2025/877 (Omnibus VII)
- Microplastics restriction, Regulation (EU) 2023/2055
Substance restrictions in products
From 10 October 2026 the PFHxA restriction under Annex XVII to REACH applies to consumer clothing, footwear and mixtures. The new Toy Safety Regulation bans PFAS, bisphenols and endocrine disruptors in toys in principle. It has been in force since 1 January 2026 and applies from 1 August 2030. Product development, quality assurance and procurement are affected.
Examples
- Annex XVII to REACH Regulation (EC) No 1907/2006
- PFHxA restriction, Regulation (EU) 2024/2462
- Toy Safety Regulation (EU) 2025/2509
Labelling and green claims
Since 27 September 2026 generic environmental claims such as “eco-friendly” are banned unless recognised excellent environmental performance can be shown. So is the claim that a product has a neutral, reduced or positive climate impact because greenhouse gas emissions were offset. In Germany the amended Act against Unfair Competition implements these rules, alongside the labelling duties for food and textiles. Marketing, packaging design and legal are affected.
Examples
- Empowering Consumers for the Green Transition Directive (EU) 2024/825
- German Act against Unfair Competition (UWG)
- Food Information to Consumers Regulation (EU) No 1169/2011
- Textile Labelling Regulation (EU) No 1007/2011
Sustainable products and supply chains
Since 19 July 2026 large companies may no longer destroy unsold clothing, clothing accessories and footwear; for medium-sized companies this applies from 19 July 2030. By 17 June 2027 the Member States have to transpose the amended Waste Framework Directive, which requires producer responsibility for textiles and footwear. The Deforestation Regulation applies to cocoa, coffee, palm oil, soy, rubber, wood and cattle from 30 December 2026, and for most micro and small companies from 30 June 2027. Procurement, sustainability and logistics are affected.
Examples
- Ecodesign for Sustainable Products Regulation (EU) 2024/1781
- Deforestation Regulation (EU) 2023/1115
- Directive (EU) 2025/1892 amending the Waste Framework Directive
Markets outside the EU
In the US the Modernization of Cosmetics Regulation Act requires facility registration, product listing and reporting of serious adverse events to the FDA. The FTC measures environmental marketing there against its Green Guides, and California's Proposition 65 requires warnings for certain substances. In the UK producers have paid fees for household packaging since 2025. Regulatory affairs and the country subsidiaries are affected.
Examples
- Modernization of Cosmetics Regulation Act of 2022 (MoCRA)
- FTC Green Guides, 16 CFR part 260
- California Proposition 65
- Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (UK)
The path of a change
Example: a new substance ban under the Cosmetics Regulation
01Law database
A regulation appears in the Official Journal of the EU that adds substances newly classified as toxic for reproduction to the list of substances banned in cosmetics. COBACK reads it together with the day's other publications.
02Relevance
The check against the digital twin gives a relevance score of 74. The reasoning names your skin care line sold in the EU and the passage of the regulation it relies on.
03Open questions
What is open is whether one of the substances is contained in bought-in fragrance compounds. COBACK asks that question and R&D confirms it for two products. The head of regulatory affairs then marks the regulation as relevant.
04Task
This creates tasks with steps, owners and deadlines ahead of the date of application: R&D reformulates the two products by 26 February 2027, procurement obtains new declarations from the fragrance suppliers and the packaging team updates the ingredient lists.
Working with COBACK
Sources for consumer products
Every day COBACK reads new publications, for example from EUR-Lex, ECHA and the US Federal Trade Commission, along with official journals, parliaments and specialist media. Everything new ends up in one place.
Linked to your range and markets
Each relevance score from 0 to 100 comes with its reasoning, the source and the product lines, group companies and markets from your twin it relies on. Where a fact is missing, such as a packaging material, COBACK asks.
Tasks for the departments
A person on your side decides whether a change is relevant. It then becomes tasks with steps, owners and deadlines for R&D, packaging, marketing or procurement.
Optional module for substances in products
Manufacturers can add the product compliance module. It checks bills of materials against the REACH Candidate List, Annex XVII to REACH, RoHS and PFAS lists, shows data gaps and produces reports.
Frequently asked questions
Does COBACK cover packaging law in several countries?
Yes. COBACK reads new publications from the EU and European countries, the Americas and Asia, and from international bodies, including the German Federal Law Gazette, legislation.gov.uk and the US Federal Register.
Does COBACK review our marketing claims?
No. COBACK shows which new rules on green claims could affect your products and markets and, once you have decided, turns them into tasks, for marketing for example. Your specialists review individual claims.
How do we find out about a new assessment?
New assessments appear in your COBACK workspace. COBACK does not send e-mails or push notifications.
Do we have to upload our product data?
No. The digital twin is filled from connected systems such as SharePoint, Google Drive or Confluence, from public registers, from your website and from a questionnaire.
