If you sell products on Amazon, Etsy or your own online shop and use terms like "environmentally friendly", "sustainable", "eco-friendly", "green" or "climate neutral", you should review your listings now.
Because from 27 September 2026, new rules against misleading environmental and sustainability claims apply across the European Union. The legal basis is Directive (EU) 2024/825 – Empowering Consumers for the Green Transition, known as EmpCo or ECGT.
The directive was adopted on 28 February 2024, published in the Official Journal of the European Union on 6 March 2024, and must be applied from 27 September 2026. Member states had to transpose the necessary national rules by 27 March 2026.
This doesn't just affect big brands. Small online sellers, marketplace sellers and vendors on Amazon, Etsy and other platforms must also review their commercial claims.
What exactly is changing?
The new rules expand existing EU rules against unfair commercial practices. Particularly relevant for online sellers are new rules on:
- generic environmental promises,
- sustainability labels,
- claims about a product's overall environmental performance,
- climate-related claims,
- claims about future environmental performance,
- and misleading presentation of properties that are already legally required.
Importantly: not every environmental word is automatically banned. What matters is whether the claim can be substantiated under the new rules and whether it creates a misleading overall impression for the consumer.
Among other things, the directive introduces new so-called "blacklist" practices. These are practices that count as unfair regardless of a case-by-case assessment.
1. "Environmentally friendly", "Eco", "Green" and "Sustainable"
Particularly common on product pages are phrases like:
| Claim | Also seen as | Problem |
|---|---|---|
| Environmentally friendly | eco-friendly | very general environmental claim |
| Ecological | ecological | generic environmental claim |
| Eco-friendly | eco-friendly | generic environmental claim |
| Green | green | can imply a comprehensive environmental benefit |
| Climate friendly | climate friendly | environmental/climate claim |
| Sustainable | sustainable | very far-reaching term |
| Biodegradable | biodegradable | concrete environmental performance must be provable |
| Biobased | biobased | concrete claim about material origin |
The EU directive explicitly cites "environmentally friendly", "eco-friendly", "green", "ecological", "climate friendly", "biodegradable" and "biobased" as examples of generic environmental claims.
But does that mean these words are banned outright from 27 September? No – not across the board. A generic claim like this becomes problematic when the seller cannot demonstrate a recognised excellent environmental performance that is actually relevant to that specific claim.
The directive recognises such a proven environmental performance, under certain conditions, in things like:
- the EU Ecolabel,
- officially recognised environmental labels under EN ISO 14024,
- or a corresponding excellent performance under other relevant EU law.
In practice this means: the more generic the claim, the higher the risk.
2. "Climate neutral" – especially important for Amazon sellers
Even more important is the new rule for claims like climate neutral, CO2-neutral, CO2-neutral certified, carbon positive, climate net zero, climate compensated, reduced climate impact, or limited carbon footprint. The directive explicitly names these claims as examples.
Particularly problematic are claims where the alleged climate neutrality is achieved through offsetting outside the company's own value chain. The EU's reasoning is that consumers may get the impression the product itself causes no or very little environmental burden.
Example: A seller sells a product for €29.99 and writes "This product is climate neutral." The seller calculates the emissions caused and then buys carbon credits (CO2 certificates) to offset them. This exact kind of claim is especially critical under the new rule. A good carbon-offset project does not automatically make such a product claim permissible.
The directive explicitly distinguishes between a product's actual lifecycle impact and offsetting emissions outside the product's value chain. That doesn't mean companies can't talk about climate projects or investments in them at all – provided the communication is not misleading and complies with EU law.
3. A self-designed green label isn't enough
Another important point concerns sustainability labels. The new blacklist bans displaying a sustainability label if it is not based on a suitable certification scheme or was not established by a public authority.
A seller can't simply create their own logo – say, "100% ECO PRODUCT" – and present it on packaging, product images or in an Amazon listing as if it were an official sustainability label. The directive requires that any such sustainability label be backed by a certification scheme or established by public authorities. A certification scheme must, among other things, be transparent, open to eligible traders, and involve objective monitoring by an independent third party.
4. A common mistake: applying one property to the whole product
Not permitted is an environmental claim about the whole product or the whole company when in fact only a single component or a specific activity is meant.
Example: A product is 30% recycled material. The seller writes "This product is made of recycled material." That can give the consumer the impression the entire product is made of recycled material. A more precise wording would be: "The packaging is 30% recycled plastic."
The difference is crucial: the second claim describes exactly what the environmental information relates to. The EU cites this exact principle in the directive's reasoning.
5. Future environmental promises are regulated too
Particularly relevant for brands and manufacturers are claims about future environmental performance, such as "climate neutral by 2030", "we will produce fully sustainably", or "our products will be 100% environmentally friendly by 2030".
Such claims can't simply be used as marketing promises. The directive requires that claims about future environmental performance rely on, among other things, clear, objective, publicly available and verifiable commitments, a detailed and realistic implementation plan, measurable and time-bound targets, and regular review by an independent third party.
6. Why is the EU introducing these rules at all?
This isn't just theoretical. An EU-wide study on environmental claims already showed how widespread such claims are: in the product sample studied, 76% of products carried an environmental claim. At the same time, 61% of consumers said it was difficult to identify which products were genuinely environmentally friendly, and 44% said they don't trust such environmental information.
An EU-wide review specifically of online sellers of second-hand goods (clothing, electronics and similar) also shows that environmental claims are a real compliance issue: in a review of 356 online traders, 34% presented environmental claims. Of those claims, 20% were not sufficiently substantiated and 28% were assessed as false, misleading, or potentially an unfair commercial practice.
That explains why the EU is increasingly putting this topic in the focus of consumer-protection authorities.
7. What does this mean for Amazon and Etsy?
The directive isn't aimed specifically at Amazon or Etsy. It covers commercial communication to consumers. That means the following areas can be relevant, among others:
| Area | What to check |
|---|---|
| Amazon title | environmental and sustainability claims |
| Amazon bullet points | "eco", "green", "sustainable" etc. |
| Product description | generic and specific environmental promises |
| A+ Content | text, icons and graphics |
| Product images | environmental claims and self-made labels |
| Packaging | claims and sustainability logos |
| Etsy title | environmental and sustainability claims |
| Etsy description | claims and their evidence |
| Own online shop | text, banners, product pages |
| Social media ads | environmental promises in posts and ads |
Especially important: images and graphic representations can also be part of an environmental claim. The EU deliberately defines an environmental claim broadly – it can consist of text, images, graphic or symbolic representations, and can also relate to labels, brand or product names.
8. What should sellers do now?
Waiting until 27 September is not a good strategy. A systematic Green Claims review for each product is recommended.
Step 1: Collect all environmental terms
Search through title, bullet points, description, A+ Content, product images, packaging, labels, shop pages, ads and social media. Look specifically for terms like: eco, green, sustainable, environmentally friendly, ecological, climate friendly, biodegradable, biobased, CO2-neutral, climate neutral.
Step 2: Ask this question for every claim
What exactly am I claiming? Not "This product is sustainable." but "The packaging is 80% recycled paper." The second example is far more specific.
Step 3: Gather evidence
For every environmental claim you should be able to trace: What exactly is being claimed? What does the claim relate to? What data supports it? Where does that data come from? What certification or testing exists? Is the claim current? Can a consumer verify the information?
Step 4: Replace generic claims with specific ones
A practical principle: the more specific the claim, the easier it generally is to understand and verify. Example: ❌ "Environmentally friendly packaging" – better: ✅ "Packaging made from 80% recycled paper." But the specific claim must of course also be true and provable. A specific false claim is no better than a generic false claim.
9. What about small businesses?
The new rules aren't a voluntary recommendation just for large companies. The directive applies to traders and commercial communication towards consumers. The fact that a business is small doesn't automatically make a potentially misleading environmental claim permissible.
At the same time, the specific enforcement measures and penalties are implemented through national legal systems. In Germany, this happens through the Third Act Amending the Act Against Unfair Competition (UWG). The Federal Ministry of Justice has confirmed that the new rules must be applied from 27 September 2026.
10. How high can the penalties be?
Caution is warranted here with blanket claims. The directive itself does not set a fixed EU-wide penalty for every individual violation – member states must provide effective, proportionate and dissuasive sanctions.
For widespread infringements with a Union dimension, where several national authorities act in a coordinated manner, member states must provide for the possibility of fines with a maximum of at least 4% of the trader's annual turnover; where turnover isn't available, a minimum ceiling of €2 million applies. National rules can go beyond this.
That doesn't mean every small seller will automatically pay 4% of turnover over one problematic word. But it does mean this shouldn't be treated as a purely marketing question.
11. And what about older stock already in a warehouse?
The new rules apply from 27 September 2026. At the same time, European consumer-protection authorities published joint principles for so-called "old stock" situations in June 2026 – covering products or packaging with environmental claims or sustainability labels that were manufactured, ordered, distributed, or already in stock before 27 September 2026.
The authorities emphasise a proportionate, coordinated approach to such old stock and expect sellers to take timely steps to adjust their commercial practices. You shouldn't simply assume: "this product was made before 27 September, so I can keep using the claim indefinitely." That kind of blanket assumption would go too far.
12. Note: EmpCo is not the same as the Green Claims Directive
There is currently a lot of confusion here, because two EU initiatives are often mixed up.
EmpCo / ECGT – Directive (EU) 2024/825: was adopted on 28 February 2024, is current EU law, is applied from 27 September 2026, and amends in particular the rules against unfair commercial practices and consumer information requirements.
Green Claims Directive: This was a separate legislative proposal on environmental claims with a much more detailed system for substantiating and verifying explicit environmental claims. In June 2025, the European Commission announced its intention to withdraw the proposal, and the trilogue negotiations planned for 23 June 2025 were subsequently cancelled. The proposal was not formally withdrawn as a result – its further status remained open at the time of the cancellation.
For sellers, what matters is this: the new rules applying from 27 September 2026 come from Directive (EU) 2024/825 – EmpCo/ECGT. They should not be confused with a supposed "new Green Claims law".
13. The most important checklist for your listing
Before you publish or update a product listing, ask yourself these questions:
- Does my listing contain an environmental claim?
- Is the claim formulated specifically?
- Can I substantiate it objectively?
- Does the claim genuinely relate to the whole product – or only to one component?
- Am I using "eco", "green", "sustainable" or similar terms?
- Can I demonstrate the required recognised environmental performance?
- Am I using a sustainability label? Is it based on a suitable certification scheme?
- Am I using "climate neutral" or a similar climate claim? Is it based on carbon offsetting?
- Am I making promises about future environmental performance? Are those targets measurable, public and verifiable?
- Have I also checked product images and packaging?
Instead of manually checking every line against this list, you can also run your listing text straight through our free Green Claims Checker – it flags known problematic wording automatically.
Conclusion: not less environmental communication – better communication
The new EU rule doesn't mean sellers can no longer talk about sustainability, recycling or environmental aspects. The goal is rather to replace generic and potentially misleading claims with specific, traceable and provable information.
For online sellers, this means: don't just delete every green word. Instead, review each individual claim – what am I claiming, what does it relate to, and can I prove it?
Anyone who now systematically reviews their listings, product images, packaging and marketing materials doesn't just reduce legal risk. They also build something that matters more and more to customers: trustworthy product information.
Sources and further information
- Directive (EU) 2024/825 in full text (EUR-Lex, English)
- European Commission – study on environmental claims for non-food products (76%/61%/44% figures)
- European Commission – CPC sweep of 356 online traders (second-hand segment)
- German Federal Ministry of Justice – Third Act Amending the UWG
- European Parliament – status of the (separate) Green Claims Directive
Legal notice
This article is for general information only and does not constitute legal advice. The specific legal assessment of an environmental claim depends in particular on the product, the exact wording, the context, the evidence available, and the applicable national rules. For legally sensitive claims, an individual review by a suitably qualified professional is recommended.