What Environmental Claims Can You Still Make in the EU from 27 September 2026?

What changes from 27 September 2026?

New definitions, misleading-practice controls and Annex I prohibitions become part of the national consumer-law rules that Member States must apply. The result is a sharper distinction between a specific evidenced product fact and a vague or over-broad environmental impression.

What law changed?

Directive (EU) 2024/825, commonly called the Empowering Consumers for the Green Transition Directive, amends two existing consumer-law instruments:

• Directive 2005/29/EC, the Unfair Commercial Practices Directive (UCPD); and
• Directive 2011/83/EU, the Consumer Rights Directive (CRD).

For environmental claims, the central changes are to the UCPD. They add definitions and targeted rules for environmental claims, sustainability labels, future environmental performance, comparison services and several practices placed on the UCPD's Annex I list. An Annex I practice is prohibited in all circumstances covered by the UCPD, without a separate case-by-case assessment of whether it altered the consumer's decision.

The CRD amendments add harmonised consumer information about legal guarantees, durability and repairability. Those changes matter to product information at the point of sale, but they should not be confused with the environmental-claim rules described here.

The amended rules apply to business-to-consumer commercial practices before, during and after a transaction. They can therefore reach packaging, online listings, adverts, product names, brand presentations, symbols and imagery where these communicate or imply an environmental message to consumers. They do not regulate a product's physical composition as such, and they are not a general business-to-business claims code. Other EU and national rules may still apply outside this scope.

What the date actually means

27 September 2026 is not “the Green Claims deadline”. It is the date from which national measures implementing Directive (EU) 2024/825 must apply.

A Directive binds Member States as to the result to be achieved, but national measures give effect to it. National authorities and courts enforce those measures, and the Court of Justice of the European Union gives authoritative interpretations of EU law.

Cross-border businesses should therefore use the EU text as the common baseline and maintain a country check for transposition, enforcement authority, remedies and any permitted national detail. Complete, uniform transposition could not safely be assumed at the verification date. On 28 May 2026, the European Commission announced infringement action against 20 Member States for failing to notify complete transposition. The Commission's June 2026 FAQ also described transposition as ongoing. Later notifications do not remove the need to verify the target country's current law.

The application date also matters to products already on the market. The Commission's coordinated consumer-enforcement note says the rules apply to commercial practices from 27 September 2026, including claims on existing products. It describes practical steps such as stickers or additional information and a proportionate enforcement approach for genuine transition difficulties. That is not an extension of the legal application date.

Can businesses still make environmental claims?

Yes. The safer question is not “Is this environmental word allowed?” but:

What overall impression will the average consumer take from this communication, and can the business prove that impression for the exact product, scope, place and time in which it appears?

The amended framework separates several situations.

Changing a broad headline into a detailed sentence does not automatically make the claim lawful. Specification can take a claim outside the new definition of a generic environmental claim when it is clear and prominent on the same medium. The resulting specific claim can still mislead through inaccuracy, omitted qualifications, an unsuitable baseline, an exaggerated visual presentation or inadequate evidence.

Generic environmental claims

A generic environmental claim is, in outline, an environmental claim made in written or oral form, including through audiovisual media, that is not contained in a sustainability label and whose specification is not provided clearly and prominently on the same medium.

The Directive's recitals give examples such as “environmentally friendly”, “eco-friendly”, “green”, “nature's friend”, “ecological”, “environmentally correct”, “climate friendly”, “gentle on the environment”, “carbon friendly”, “energy efficient”, “biodegradable” and “biobased”. Whether a particular use is generic depends on its context and the impression it creates.

From the application date, a generic environmental claim is prohibited unless the trader can demonstrate recognised excellent environmental performance that is relevant to the claim. The amended UCPD defines that performance through three routes:

1. compliance with the EU Ecolabel Regulation;
2. compliance with an officially recognised national or regional EN ISO 14024 Type I ecolabelling scheme; or
3. top environmental performance in accordance with other applicable EU law.

The performance must support the particular claim. An award whose criteria do not address biodegradability does not justify a generic “biodegradable” claim. A label or top-performance status is not a general licence for every green statement.

A specific statement can be different. “This bottle contains 70% post-consumer recycled PET by mass, excluding the cap and label” identifies the characteristic and scope on the same medium. It is no longer simply the word “green”. It still needs accurate evidence, an appropriate calculation method and a presentation that does not imply more than the fact supports.

Icons and product presentation also matter. Leaves, water drops, green imagery, sounds or symbols may imply an environmental claim or look like a voluntary trust mark. The assessment is based on the overall impression on the average consumer, not only the literal words.

Sustainability labels

The amended UCPD defines a sustainability label broadly as a voluntary public or private trust mark, quality mark or equivalent that sets apart and promotes a product, process or business by reference to environmental or social characteristics. Mandatory labels required by EU or national law are excluded from that definition.

Displaying a sustainability label becomes an Annex I prohibited practice unless the label is:

• based on a certification scheme meeting the Directive's requirements; or
• established by a public authority.

The certification route is more than an attractive badge. The scheme must be open under transparent, fair and non-discriminatory terms; set requirements developed with relevant experts and stakeholders; have procedures for non-compliance and withdrawal; and use third-party monitoring whose competence and independence are based on international, EU or national standards and procedures.

An own-brand green badge can fall within the label definition even if the business calls it an icon, range marker or trust mark. Teams should inventory every mark, including visual marks applied by a marketplace or retailer, identify its scheme or legal basis and record who verifies continued eligibility.

Whole-product and whole-business claims

The amended Annex I also prohibits making an environmental claim about the entire product or the trader's entire business when it concerns only a certain aspect of the product or a specific activity of the business.

This is a scope problem. A recycled lining does not make an entire coat “recycled”. Renewable electricity at one factory does not by itself make the whole business “green”. If the evidence covers only an input, component, facility, life-cycle stage or region, the communication should make that boundary clear and prominent.

Offsetting and climate-neutral claims

The rule does not make carbon offsetting itself illegal. It prohibits claiming, on the basis of greenhouse-gas offsetting, that a product has a neutral, reduced or positive environmental impact in terms of greenhouse-gas emissions.

Examples in the Directive's recitals include “climate neutral”, “CO2 neutral certified”, “carbon positive”, “climate net zero”, “climate compensated”, “reduced climate impact” and “limited CO2 footprint” when the product proposition depends on offsetting. Buying credits outside the product's value chain cannot be presented as if the product itself has no, lower or positive climate impact.

The prohibition is directed at product claims. It does not prevent a business from reporting investments in environmental initiatives or carbon-credit projects, provided the communication is transparent, not misleading and compliant with the rest of EU law. The Commission's FAQ also distinguishes company-level offsetting claims from the product-specific Annex I prohibition, although company claims remain subject to the UCPD and the rules on future performance where relevant.

A product climate claim based on real and verifiable reductions in the product's own life cycle may still be possible. It needs a defined product, life-cycle boundary, baseline, method, period and evidence. “18% lower cradle-to-gate greenhouse-gas emissions than the 2024 version of this model” communicates a different proposition from “carbon neutral because we offset the emissions”. The former is not automatically lawful; its comparison and substantiation still need review.

Future environmental-performance claims

Claims such as “net zero by 2030”, “climate positive by 2035” or “100% recyclable by 2028” describe future environmental performance. Under amended Article 6(2)(d) UCPD, such a claim is liable to be misleading, following a case-by-case assessment, when it is not supported by:

• clear, objective, publicly available and verifiable commitments and targets;
• a detailed and realistic implementation plan showing how the commitments and targets will be achieved;
• measurable and time-bound targets and other relevant implementation elements, including allocation of resources; and
• regular verification by an independent third-party expert, with the expert's findings made available to consumers.

The independent expert must be free from conflicts of interest, have relevant experience and competence and be able to monitor progress regularly. The Directive does not prescribe a universal verification frequency or a single method. The Commission FAQ mentions annual or biennial checks as examples of good practice, not a fixed statutory interval.

A distant ambition without named milestones, resources, ownership, monitoring and published verification findings is not enough. Product-data governance should also record when the plan or product changes, because a previously defensible claim can become stale.

Specific product-level claims

Specific claims remain possible in principle, but no wording operates in isolation. Consider the following examples as explanatory contrasts, not legal approval for any business.

Claims such as “longer lasting”, “reduced carbon” or “more repairable” are comparisons. State what is being compared, the measurement method, the relevant period and the material difference. The amended UCPD also requires providers of services that compare products and communicate environmental or social characteristics to give information about the comparison method, the products and suppliers compared, and the measures used to keep the information up to date.

Do not advertise a legal requirement applying to all products in the relevant category as if it were a distinctive feature of one offer. Nor should a business advertise an irrelevant benefit that does not result from a feature of the product or business. These are separate controls from the generic-claim rule.

Evidence and substantiation

The UCPD already required environmental claims to be truthful, clear, specific and substantiated. The 2024 Directive adds specific definitions, material characteristics and prohibited practices; it does not replace the underlying misleading-practice test.

A useful evidence chain answers five questions:

1. Fact: What exact fact does the public claim depend on?
2. Provenance: Who generated or supplied the evidence, by what method?
3. Coverage: Which product, component, supplier, facility, batch, variant, market and time period does it cover?
4. Currency: Is the evidence still valid after a specification, supplier, method, scheme or product change?
5. Ownership: Who approves the claim, monitors the evidence and withdraws or corrects it when conditions change?

A certificate is not self-explanatory. Record its scope, issuer, scheme, subject, validity dates and relationship to the exact marketed product. A supplier declaration may establish one input fact but not the whole-product impression. A life-cycle assessment may be methodologically strong yet still fail to cover a changed bill of materials or the comparative baseline stated in the advert.

Evidence should exist and be reviewable before publication. Keep the public wording, qualification and underlying record version together, so a channel cannot continue to display a sentence after its evidence has expired.

What product data should sit behind a claim?

The fields below are a governance model, not a list of statutory data fields in Directive (EU) 2024/825.

The claim should be a governed object, not free text copied between a spreadsheet, product-information system, advert and marketplace listing. A product change should trigger an evidence-coverage check. A scheme change or certificate expiry should trigger review of every linked claim and channel.

What marketing teams should do now

1. Inventory all explicit and implied environmental claims across product names, packaging, imagery, filters, badges, product pages, advertising and social content.
2. Classify generic claims, sustainability labels, whole-product impressions, offset-based product claims, comparisons and future-performance claims.
3. Remove or escalate any practice that matches an Annex I prohibition. Do not assume a footnote elsewhere repairs a claim whose specification must be clear and prominent on the same medium.
4. Rewrite supported claims around the precise fact, scope, baseline and conditions. Review the overall visual impression as well as the words.
5. Link every retained claim to current evidence and a named owner. Set review and withdrawal triggers.
6. Map publication locations, including existing stock, retailers and marketplaces, so approved changes reach every channel before 27 September 2026.
7. Obtain legal review for the markets and claims that remain material or uncertain. This resource is not a determination that a particular claim is lawful.

What product-data and compliance teams should do now

Build a claim register that uses stable product and evidence identifiers. Separate facts from claims: “supplier declaration reports 62% recycled content for material lot A” is an evidence fact; “this trainer is sustainable” is a consumer-facing proposition with a much broader impression.

Apply coverage rules at component, variant, batch and market level. Record methodology and baseline versions. Connect certificates to the certified subject, not merely to the supplier name. Treat dates and change history as data. Make the publication status reversible so a withdrawn claim can be removed from every channel.

For future claims, maintain the public commitment, implementation plan, resources, milestones and independent findings as linked records. For labels, retain the scheme rules, public-authority basis or certification evidence and continuing eligibility.

Common misconceptions

“All environmental claims are banned.” No. Certain practices are prohibited, and all claims remain subject to misleading-practice controls. Specific and substantiated claims can still be made where the law and context support them.

“A detailed landing page fixes a vague claim on the pack.” Not necessarily. To fall outside the generic-claim definition, the specification must be clear and prominent on the same medium. Other misleading-practice rules still apply.

“Buying offsets is illegal.” No. The new Annex I rule concerns product greenhouse-gas impact claims based on offsetting. Transparent reporting of environmental investments is not automatically prohibited, but it must not mislead.

“A sustainability badge is only design.” It may be a sustainability label or an implied claim, depending on its use and consumer perception.

“The EU Ecolabel permits any green statement.” No. Recognised excellent performance must be relevant to the claim, and sector rules such as chemical labelling can impose additional restrictions.

“The Green Claims Directive starts on 27 September 2026.” No. The date belongs to national application of the measures implementing Directive (EU) 2024/825. The separate Green Claims proposal, procedure 2023/0085(COD), had not been adopted at the verification date.

Direct questions

Are environmental claims banned in the EU?

No. Businesses can still make specific, accurate and substantiated environmental claims. Several generic, label, scope, offsetting and future-performance practices are now expressly prohibited or conditioned.

Can I still say “sustainable”?

As a generic environmental claim, “sustainable” is high risk and may be prohibited unless it is supported by relevant recognised excellent environmental performance. Adding a clear and prominent specification on the same medium changes the generic-claim analysis, but the specific proposition and overall impression must still be accurate and substantiated.

Can I call a product carbon neutral?

Not when the product's claimed neutral greenhouse-gas impact is based on offsetting. A generic carbon-neutral claim also engages the generic-claim rule. Claims based on the product's actual life-cycle performance require precise scope, method and evidence and remain subject to all other misleading-practice rules.

Can I say a product contains recycled material?

Potentially. State the material, percentage basis, product or component covered and exclusions, and retain reliable evidence for the exact variant and period. Do not let a component-level fact imply that the whole product is recycled or environmentally superior.

What evidence do I need?

Evidence should establish the exact fact, method, boundary, product coverage, date and comparator behind the public wording. Its strength depends on the claim. Tests, calculations, certificates and supplier records must be connected to the precise product and kept current.

What changes on 27 September 2026?

National measures implementing Directive (EU) 2024/825 must apply from that date. The Directive adds targeted consumer-law rules and Annex I prohibitions for environmental claims and sustainability information. Check each target country's implementing law and enforcement position.

Is this the same as the Green Claims Directive?

No. Directive (EU) 2024/825 is adopted law. The separately proposed Green Claims Directive was still in the EU legislative procedure at the verification date and must not be presented as an enacted source of obligations.

Sources

Primary and official sources checked on 1 September 2026:

• Directive (EU) 2024/825, Official Journal text

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• National transposition measures for Directive (EU) 2024/825

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• European Commission, Questions and Answers on Directive (EU) 2024/825, June 2026

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• European Commission, Sustainable consumption

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• European Commission, coordinated action on environmental claims and existing products

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• European Commission, May 2026 infringement decisions on transposition

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• EU legislative procedure 2023/0085(COD), proposed Green Claims Directive: The Commission FAQ records preliminary Commission-service views and is not legally binding. National authorities and courts enforce the implementing law; the Court of Justice of the European Union is the authoritative interpreter of EU law.

  View official source

The Commission FAQ records preliminary Commission-service views and is not legally binding. National authorities and courts enforce the implementing law; the Court of Justice of the European Union is the authoritative interpreter of EU law.