Changes and adjustments in generation 4

Nordic Ecolabelling may continuously decide on changes, adjustments, and extensions to the applicable criteria.

Below is an overview of the changes implemented in Generation 4, listed by version.

On 11^th November 2025 Nordic Swan Ecolabelling decided adjustments in the criteria for Nordic Swan Ecolabelling for Cosmetic. Please find the new version 4.6 on our website here. As well as the background document.

Requirements

O35 Cardboard packaging for liquid products: Sustainable material and design for recycling; specifying that only printing done on the cardboard of the packaging must be done with water-based inks.

Minor adjustments

In addition to this change some minor adjustments have been made to the text to clarify the requirements and corrections of spelling errors. The main changes are the following:

O15: Update of table 2 regarding acute toxicity.
O33: Under “Material composition” the requirement text has been divided so that the materials PE and PP stand separately.
O36 Under “Label matrial” it is specified that it is the polymer composition of the label (excluding adhesive and print) that must comply with the material purity limits.

Appendices

There has also been changes in appendices. We recommend that you use criteria version 4.6 as well as the new versions of Appendix 1 and 4 in the future. Previous versions of Appendix 1, 2 and 4 can still be used.

Appendix 1: There are changes in the requirement O15.
Appendix 2: There are changes in requirement O15.
Appendix 4: There are changes in requirements O36 and O38.
Appendix 5: There are changes under “Printing”.
Appendix 6: Correction of the material factor for aluminum.

Calculation sheets

There are updates for the following Calculation sheets, that must be used from now on, since there are errors in the old versions! Find the sheets here: Application tools:

Calculation sheet for Leave-on: in the tab “Degradability and toxicity” the compliance with req. O20 is now based on total organic active content. And some minor changes have been made.
Calculation sheet for WUR/emptying level/packaging: The tab for “label coverage of a cylindrical botte” has been updated and fixed so that A2 = 0 if h2 or a are empty.

In September and October 2025 Nordic Swan Ecolabelling decided several adjustments in the criteria for Nordic Swan Ecolabelling for Cosmetic. Please find the new version 4.5 on our website here. As well as the background document.

Requirements

O5 Classification of ingoing substances

The exemption for titanium dioxide is made permanent for products that are not loose powder, in spray form, toothpaste, or lip products (lip balm, lipstick, lip gloss, lipliner, and similar).

O6 Microplastics

Exemption for high-molecular-weight crosslinked acrylate-based polymers that function as rheology modifiers/thickeners (e.g. carbomers and acrylates/C10-30 alkyl Acrylate Crosspolymer) in leave-on products applies until 17. October 2029, provided that a detailed phase-out plan is prepared by the applicant.

O7 Excluded substances

We now allow quaternary ammonium compounds that are not anaerobically biodegradable.

O25 Wipe material

The newly published criteria for Protective and Absorbent Hygiene Products 7.0 have been added as an alternative for showing fulfilment the requirement for wipe material.

O32 Packaging and materials

Pipettes/droppers may be made of virgin glass and are thus exempted from the requirement on a minimum content of recycled glass.

O33 Plastic packaging: Design for recycling

Pipettes/droppers are exempted from the requirement on monomaterial in plastic components. Furthermore, dispensing systems in products sold to the professional market are also exempted from the requirement on monomaterials in plastic components but must not contain PVC or other halogenated plastics.

O36 Labels and print for all packaging materials: Design for recycling of packaging

We now allow label coverage up to 70% on PET packaging for containers ≤ 500 ml if an independent third-party waste handling facility can demonstrate NIR-sorting according to RecyClass Sorting Evaluation Protocol.

O37 Amount of packaging: Weight-Utility Ration (WUR)

The material factor for aluminium has been adjusted to 1.6 instead of 2.1 in earlier versions.

Minor adjustments

In addition to this change some minor adjustments have been made to the text to clarify the requirements and corrections of spelling errors. The main changes are the following:

In the chapter “What is a Nordic Swan Ecolabelled cosmetic product?” the wording“Contain no microplastics” has been removed.
In chapter “1.2 Definitions” we have added “Products for consumer use” and “Products for professional use”. And added valves under “Dispensing systems”.
O5: Tocopherol acetate (DID no 2609) - Clarification.
O21: Clarification of documentation for flavourings.
O30:Clarification of legislation in the documentation requirements.
O39: Updated the requirement about pictograms for recycling.

Appendices

There has also been changes in appendices. We recommend that you use criteria version 4.5 as well as the new versions of Appendix 1 and 4 in the future. Previous versions of Appendix 1, 2 and 4 can still be used.

Appendix 1: There are changes in the requirements O7, O21-O22 and in the header concerning professional or consumer product.
Appendix 2: There are changes in requirements O6-O7, O21-O22.
Appendix 4: There are changes in requirements O32, O33, O34 and O36.
Appendix 8:In conjunction with the changes in O25, appendix 8 containing requirements for fluff pulp has been removed, as this is now covered by the criteria for hygiene products. Instead, a new appendix 8 has been added, giving an overview of documentation requirements per criteria document referenced in requirement O25 Wipe material.

Calculation sheets

There are updates for the following Calculation sheets, that must be used from now on, since there are errors in the old versions! Find the sheets here: Application tools:

Calculation sheet for Rinse-off: A slight improvement by automatically setting aNBO and anNBO to 0 if the substance is inorganic.
Calculation sheet for Leave-on: There was an error in how the fulfilment of requirement O20 was calculated. This has now been corrected by adding two more columns (G and H) which were needed to calculate the fulfilment of the requirement correctly. An error in the calculation of O19 has also been fixed.
Calculation sheet for WUR/emptying level/packaging: has been updated with the new material factor for aluminium: 1.6.

A new version of the criteria has been added for Nordic Swan Ecolabelling for Cosmetic products, see version 4.4.

In June 2025, Nordic Swan Ecolabelling decided to adjust a requirement as well as the backgrounddocument.

The following requirements have been adjusted:

O20 Biodegradability and aquatic toxicity

Added that cera alba (beeswax), CAS No. 8012-89-3 are exempted from the requirement.

O32 Packaging and materials

The size restriction on aluminium packaging has been removed.
Changed the exemption for small metal parts and clarified that it applies to dispensing systems.

O33 Plastic packaging: Design for recycling

Desing for recycling specifying that small parts in dispensing systems are exempted from the requirement on separability, however the dispensing system as a whole must be separable from the container.
Small parts in dispensing systems are also exempted from the requirement on materials but must not contain PVC or other halogenated plastics.
Desing for recycling specifying that packaging made from soft plastic (e.g. pouches) must contain ≥ 95% polyethylene (PE) and pouches to the professional market are exempted from the requirement until June 30th, 2028.

O37 Amount of packaging: Weight-Utility Ratio /WUR)

Weight-Utility-Ratio (WUR) has been adjusted such that the limit value for the category stick and roll-on has been eased to accommodate for lip balm in two-pack, which is makes it easier to handle the product in retail

In addition to this change, several minor adjustments have been made to the text to clarify the requirements and corrections of spelling errors. The main changes are the following:

1.2 Other definitions: Added ”Dispensing systems”.

O5: Titanium dioxide restriction is deleted.

1.6 Packaging requirements, several changes in this section: The recyclability of primary packaging made from plastic can be documented with a Recyclability certificate from RecyClass showing that the primary packaging is fully recyclable with a minimum recyclability score of B. See requirements O33 and O36 for further information.

O32: Documentation requirement it is clarified that “a comprehensive overview of all primary packaging components and specification of materials of all components (bottle, cap, pump, lid, etc.)” must be submitted.

O33: it is clarified that “All other components must either live up to the requirements below or the primary packaging* must have a Recyclability certificate from RecyClass showing that the primary packaging is fully recyclable with a minimum recyclability score of B”.

O33: Changed the heading to “Material compositions”.

O33: for closures used on squeezable upside-down bottles it clarified that “To qualify for this exemption, the primary packaging* must obtain a Recyclability certificate from RecyClass with a minimum recyclability score of B”.

O33: the documentation requirement is updated to the changes.

O36: it is clarified that “To enable recycling of the packaging, labels* must either meet the requirements below. For plastic packaging, the primary packaging** can instead have a Recyclability certificate from RecyClass showing that the primary packaging is fully recyclable with a minimum recyclability score of B”.

O36: For packaging made from polyethylene (PE) and polypropylene (PP) it is clarified that “The label must be of the same material as the packaging, i.e. ≥ 99% polyethylene (PE) or ≥ 95% polypropylene (PP) with a density < 1 g/cm3”.

O36: It is clarified that “Exemption: Fold-out (cross-over) labels of PP are allowed on PE packaging”.

O36: For packaging made from PET it is clarified that

“The label must be of ≥ 99% polyethylene (PE) or ≥ 95% polypropylene (PP) with a density < 1.00 g/cm3.

An exemption is made for oil-based products where labels of PET (not PET-G, cPET or foamed PET) are permitted”.

O36: the documentation requirement is updated to the changes.

O37: documentation requirements: deleted “together with a technical data sheet”.

Appendix 1: There are changes in the following requirements no.: O4, O33 and O36.

Appendix 4: There are changes in the following requirements no.: O33 and O36.

We recommend that you use criteria version 4.4 as well as the new versions of Appendix 1 (dated 26 August 2025) and Appendix 4 (dated 26 August 2025) in the future.

It should be noted that the previous versions of Appendix 1 and 4 can still be used.

Calculation sheet for WUR/emptying level/packaging has also been updated:

Updated calculation for ” WUR Stick + roll on”

NOTE! The new WUR calculation sheet (4_4) must be used, as there are errors in the old version!

In June 2025, Nordic Swan Ecolabelling decided to adjust a requirement as well as the background.

The following requirements have been adjusted:

O33 Plastic packaging: Design for recycling

It has been specified that this requirement does not apply to labels
Sealing foil made of plastic has been exempted (separability + materials)
For “Small metal, glass or plastic parts in pumps” the text “PVC and other halogenated plastics are not allowed” is deleted (separability)
Labels is deleted (separability)
Nitril rubber (NBR) is now allowed in closures for refill deodorants (materials)

O36 Labels and print for all packaging materials: Design for recycling of packaging

Density limit for PET labels has been changed back to 1,0 g/cm³ (Label material)
The requirement for printing inks to be non-bleeding has been removed (Print)

O37 Amount of packaging: Weight-Utility Ratio /WUR)

It is clarified that pump bottles are regular pump bottles
The packaging type foam pump bottles has been introduced
An update to the constants a and b for airless packaging have been made as there was an error in version 4.2
In the criteria document, a 0 was missing in the limit value for wet wipes, and this has been corrected (the calculation sheet had the correct value from start)

In addition to this change, several minor adjustments have been made to the text to clarify the requirements and corrections of spelling errors. The main changes are the following:

1.2 Other definitions: Adding labels in ”Packaging component”

Appendix 1: Nitrilgummi (NBR) closures for refill deodorants is added in O33, and non-bleeding has been deleted in O36.

Appendix 4: Nitrilgummi (NBR) closures for refill deodorants is added in O33, og non-bleeding is deleted from for printing ink.
Appendix 6: Er opdateret iht. ændringer i kravteksten.

We recommend that you use criteria version 4.2 as well as the new versions of Appendix 1 (dated 24 June 2025) and Appendix 4 (dated 24 June 2025) in the future.

It should be noted that the previous versions of Appendix 1 and 4 can still be used.

Calculation sheet for WUR/emptying level/packaging has also been updated:

New tab for ”WUR Foam pump bottle”
Airless: New values in the calculation formula for the constants a and b
Regular pump bottle: correction has been made as the weight of the pump was previously counted twice
Refill packaging (multiple tabs): Weight of glass was not included in the calculation for refill packaging, and this has now been corrected.

In May 2025, Nordic Swan Ecolabelling decided to adjust following requirements:

O6 Microplastics: where a complete exemption to the requirement is introduced for sunscreen products. The exemption is valid until 29 October 2029.
O27 User information: by allowing corresponding pictorgrams to be used and removed the requirement that the pictogram must be placed on the front side of the packaging.
O36 Labels and print for all packaging materials: Design for recycling of packaging: where an exemption is introduced allowing PET labels (not PET-G, cPET or foamed PET) on PET packaging for oil-based products.
O37Amount of packaging: Weight-Utility Ratio (WUR): where adjusted limit values for the packaging type Airless packaging was introduced.

In addition to this change some minor adjustments have been made to the text to clarify the requirements. The main changes are the following:

Adding the following clarification in O4: ”The requirement does not apply to substances derived from palm oil/palm kernel oil in raw materials where the substances amount to < 1% in the cosmetic product”.
The clarification of the requirement text in O14 for organic UV filters to:
All organic UV filters contained in the product must either:

Not be bioaccumulatiove in line with the testing methods in Appendix 7 having a BCF < 500 or log Kow < 4

or

Have a lowest toxicity with NOEC/EC_x > 0.1 mg/l or EC/LC50 > 10.0 mg/l.

Appendix 2 and Appendix 4 have also been adjusted in accordance with adjustments in the requirement texts. The changes regarding the following requirements:

Appendix 2:

O9-O11: Fragrance
O23-24: Decorative cosmetics and hair dyes

Appendix 4:

O36: Labels and direct print

We recommend that you in the future use criteria version 4.2 as well as the new versions of:

Appendix 1 (18 March 2025)
Appendix 2 (27 May 2025)
Appendix 4 (27 May 2025)

It should be noted that the previous versions of Appendix 1, 2 and 4 can still be used.

Calculation sheet for WUR/emptying level/packaginghas also been updated. This applies to the calculation for Airless (see O37 above).

On March 18, 2025, Nordic Swan Ecolabelling decided to adjust the following requirements:

O33 Plastic packaging: Design for cycling: Expand the exemption for membranes of silicone in closures on PET containers to also include PE and PP containers.

The new text of the requirements in the section "Materials" is:

”Closures used on squeezable upside-down bottles may include a membrane composed of floating silicone with a density < 0.95 g/cm³ for containers of PET and with a density > 1.0 g/cm3 for containers of PE and PP. Any silicone used with this exemption must contain less than 1000 ppm of D4, D5, and D6. The packaging must also attain a minimum recyclability score of B, as verified by a recyclability rate certificate by RecyClass”.

In addition to this change, a number of minor adjustments have been made to the text to clarify the requirements and corrections of spelling errors.

The main changes are the following:

Added definition of mix-it-yourself products (to be diluted 10 times) + similar text as in PG 026 for the same type of product, including specifications how these should be handled in all calculation requirements
Added in definitions that both toothpaste and mouthwash are considered rinse-off but must meet requirement O20 instead of O18-O19.
Small parts of glass and aluminum must not consist of recycled material.
Clarification in requirement O33 concerning barriers
Printing inks for plastic packaging must be non-bleeding and compliant in accordance with EuPIA's exclusion policy.

Appendix 1, 2, and 4 have also been adjusted according to adjustments in the requirements texts.

The biggest changes are:

Appendix 1:

Questions on squeezable upside-down bottles and silicone membrane
Questions on printing of labels on plastic packaging

Appendix 4:

Question on if direct print on a tube complies with the requirement on printing inks

We recommend that you use criteria version 4.1 as well as the new versions of Appendix 1, 2 and 4 (dated 18 March 2025) in the future. It should be noted that the previous versions of Appendix 1, 2 and 4 can still be used.

Calculation sheet for WUR/emptying level/packaging has also been updated. Glass has been added in several tabs and for "WUR Pump Bottles" pump weight is added.