Green Claims: Banned Environmental Claims from 27.09.2026

It is Directive (EU) 2024/825 on empowering consumers for the green transition – often referred to as "EmpCo" or "ECGT". It was adopted in February 2024 and amends two existing EU consumer-protection directives: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU).

An important clarification is worth making here, because there is a lot of confusion online: there was also a separate proposal called the "Green Claims Directive", which would have set out much more detailed proof and verification requirements for individual environmental claims. In June 2025 the Commission announced its intention to withdraw that proposal, and the trilogue negotiations scheduled for later that month were cancelled as a result – but the proposal was not formally withdrawn, and its status remained unresolved at that point. Directive (EU) 2024/825, described here, is unaffected by that and is applied from the deadline regardless of what happens to the other proposal.

Member states had to transpose the directive into national law by 27 March 2026. It is applied – meaning binding for businesses – from 27 September 2026.

The directive does not provide for a transition period for stock already produced or existing marketing materials. There is also no exemption for small or medium-sized businesses. This sets it apart from some other EU rules that give smaller businesses more time.

What's banned are blanket, unsubstantiated environmental claims – wording that implies a positive environmental effect without a concrete, provable fact behind it. Commonly cited examples include terms like "environmentally friendly", "climate friendly", "green", "eco", "nature-friendly" and similar.

What matters is not the individual word but the principle behind it: a claim about the entire product or company is only permitted if it relies on a recognised proof – for example the EU Ecolabel or a comparable, independently verified basis. Without such proof, the claim counts as generic and is therefore not permitted, regardless of whether it happens to be true.

Not across the board, but in practice the ban affects the vast majority of current cases. Explicitly banned is a climate-neutrality claim when it is based on the purchase of carbon offset certificates rather than an actual reduction of emissions within the company itself – regardless of how high-quality the underlying certificates are.

The problem for many sellers: the overwhelming majority of "climate neutral" claims currently on the market are based on exactly this offsetting model, not on a verified, actual reduction of the company's own emissions. Anyone wanting to keep using the claim after the deadline will need to review not just the wording, but the underlying climate accounting itself.

Self-created or self-certified sustainability labels are explicitly one of the newly banned practices – regardless of what the label looks like or what text accompanies it. Under the directive, a sustainability label is only permitted if it is based on a recognised certification scheme backed by an independent, verifiable review process.

In practice this means: a green leaf symbol or a self-designed "Eco" label that simply appears on your own packaging, without being backed by genuine external certification, falls under this ban. This kind of issue can't be caught by a plain text check like our checker – graphic labels and symbols need to be reviewed separately.

The directive applies EU-wide, across all 27 member states. Like any EU directive, it isn't directly applicable law – it requires each member state to transpose the same substantive core into national law. The underlying principles and the application date are therefore identical everywhere.

Differences can arise in practical enforcement: which authority is responsible, how actively it checks, and exactly how sanctions are structured is up to each member state. For sellers active in several EU countries – for example across different Amazon marketplaces – this means the substantive standard is the same everywhere, even though enforcement risk may vary by country.

Caution is warranted here with blanket figures. The directive itself does not set a single, fixed, EU-wide fine – member states must provide for 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 is not available, a minimum ceiling of €2 million applies. National rules can go further than this.

That doesn't mean every small seller will automatically be fined 4% of turnover over one problematic word. It does mean this shouldn't be treated as a purely marketing question.

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.