Yes, with no size threshold. Directive (EU) 2024/825 applies to all companies marketing products bearing environmental claims in Europe, whatever their size. It has applied since 27 September 2026 in countries that have transposed it; in France, the transposing law has not yet been passed. Once in force, a cosmetics SME communicating "eco-responsible" or "carbon-neutral" will be non-compliant, even with an LCA: a generic claim requires an officially recognised ecolabel, and neutrality through offsetting is prohibited.
Read the source article: What is the environmental impact of cosmetics?