What Is Directive (EU) 2024/825?

Directive (EU) 2024/825 strengthens EU consumer protection against misleading environmental and sustainability communications.

It introduces:

• New prohibited greenwashing practices
• Stricter treatment of generic environmental claims
• Conditions for displaying sustainability labels
• Restrictions on offset-based product claims
• Rules for future environmental promises
• Requirements concerning product durability and reparability information
• Stronger controls over environmental comparison services

The Directive does not primarily regulate the physical composition of products. It regulates how products, services, brands and businesses are presented to consumers through advertising, packaging, selling interfaces and other commercial communications.

Is This the Same as the EU Green Claims Directive?

No.

The rules applying from 27 September 2026 come from the already adopted Directive (EU) 2024/825.

The separate proposed Green Claims Directive was intended to introduce additional requirements for substantiating, communicating and verifying explicit environmental claims. It has not been adopted.

As of the European Parliament’s 20 June 2026 update, the file was listed as blocked. The Commission announced in June 2025 that it intended to withdraw the proposal, and the planned third trilogue was cancelled. However, the Commission’s 2026 Work Programme continued to list the proposal as pending.

Businesses should therefore avoid referring to the September 2026 requirements as though the separate Green Claims Directive had been adopted.

Key EU Anti-Greenwashing Compliance Dates

The precise enforcement procedures, remedies and national implementation details may differ between Member States. Businesses should therefore review the national laws applicable in every EU market where their consumer-facing claims appear.

Who Is Affected?

The Directive’s anti-greenwashing provisions operate through the Unfair Commercial Practices Directive and focus on business-to-consumer commercial practices.

They are particularly relevant to:

• Consumer-product manufacturers
• Brand owners and private-label companies
• Importers and distributors repeating supplier claims
• Retailers and online sellers
• Companies supplying consumer services
• Marketing and communications teams
• Sustainability and ESG teams
• Product compliance and regulatory teams
• Packaging and product-development departments

Purely business-to-business communications fall outside the harmonised scope of the Directive. However, other EU instruments and national laws may still regulate misleading environmental representations in B2B relationships.

Mandatory corporate sustainability reports are generally not consumer-facing commercial communications. However, information taken from those reports may fall within scope when reused voluntarily in product advertising, websites, packaging or marketing directed at consumers.

What Counts as an Environmental Claim?

The Directive defines an environmental claim broadly.

A claim may be communicated through:

• Text
• Spoken statements
• Product names
• Brand or company names
• Labels and symbols
• Logos
• Packaging artwork
• Images and colours
• Advertising
• Online product pages
• Social media content

A communication may qualify as an environmental claim when it states or implies that a product, product category, brand or business:

• Has a positive or zero environmental impact
• Causes less environmental damage than an alternative
• Has improved its environmental impact over time

Environmental claims can therefore be explicit or implied. The assessment depends on the complete commercial context and the impression received by the average consumer.

Five Anti-Greenwashing Requirements Requiring Attention

1. Generic Environmental Claims Face Strict Conditions

A generic environmental claim is an environmental statement whose meaning is not specified clearly and prominently on the same communication medium.

Examples listed in the Directive include:

• Green
• Eco-friendly
• Environmentally friendly
• Ecological
• Climate-friendly
• Carbon-friendly
• Gentle on the environment
• Energy efficient
• Biodegradable
• Biobased

Generic environmental claims are prohibited when the business cannot demonstrate recognised excellent environmental performance relevant to the claim.

Recognised excellent environmental performance may include:

• Compliance with the EU Ecolabel Regulation
• Compliance with officially recognised national or regional EN ISO 14024 Type I ecolabelling schemes
• Top environmental performance established under another applicable EU law

The recognised performance must be relevant to the complete claim. Evidence showing good performance in one limited area may not justify a much broader expression such as “sustainable” or “environmentally friendly.”

Generic claim versus specific claim

Generic claim:
“Climate-friendly packaging”

More specific claim:
“100% of the energy used to produce this packaging comes from renewable sources”

Providing a clear specification on the same packaging, advertisement or online selling interface can mean that the statement is no longer treated as generic. However, the specific claim must still be accurate, substantiated and compliant with the wider rules against misleading actions and omissions.

The Commission services’ Q&A also refers to existing guidance stating that, when space is limited, the connection between the main claim and its supporting explanation should remain understandable. Where there is no space to specify the claim properly, it should generally not be made.

2. Sustainability Labels Must Meet Defined Conditions

A sustainability label is a voluntary trust mark, quality mark or equivalent symbol that promotes a product, process or business by reference to environmental or social characteristics.

Displaying a sustainability label will be prohibited when it is neither:

• Based on a certification scheme meeting the Directive’s requirements; nor
• Established by a qualifying public authority

The Directive does not simply require a label to be “recognised.” It defines specific criteria for certification schemes.

A qualifying scheme must include:

• Publicly available requirements
• Transparent, fair and non-discriminatory access
• Requirements developed with relevant experts and stakeholders
• Procedures for addressing non-compliance
• Suspension or withdrawal of label use when requirements are not met
• Objective monitoring carried out by a competent and independent third party

Items companies should review

Businesses should inventory:

• Internally created green seals
• Supplier sustainability badges
• Private certification marks
• “Responsible,” “approved” or “planet-friendly” icons
• Logos that resemble independent certification
• Environmental trust marks embedded in product artwork

A badge created by a company’s own marketing team may become risky when consumers could interpret it as an independent or certified sustainability label.

The Commission services’ Q&A also indicates that a label established by a non-EU public authority may still need to be based on a qualifying certification scheme. This remains non-binding guidance and should be considered together with applicable national implementation.

3. Claims Must Match Their Actual Scope

The Directive prohibits environmental claims about an entire product or an entire business when the claimed benefit relates only to:

• One component
• The packaging
• One production site
• One product variant
• A specific and unrepresentative business activity

For example, a statement such as “made with recycled material” may mislead consumers if it appears to describe the whole product when only the packaging contains recycled material.

Before approving a claim, companies should ask:

1- Does it refer to the product or the packaging?

2- Does it cover the whole product or one component?

3- Does it apply to every SKU?

4- Does it apply to every supplier or production site?

5- Does it cover the full life cycle or one stage?

6- Does it relate to the entire company or one activity?

A properly scoped environmental claim should identify what is covered and avoid creating a broader impression than the evidence supports.

4. Offset-Based Product Climate Claims Are Restricted

The Directive prohibits claims that a product or service has a neutral, reduced or positive greenhouse-gas impact when the claim is based on offsetting greenhouse-gas emissions.

Examples identified in the Directive include:

• Climate neutral
• CO₂ neutral certified
• Carbon positive
• Climate net zero
• Climate compensated
• Reduced climate impact
• Limited CO₂ footprint

These statements cannot be used to imply that a product itself has no or lower climate impact merely because the company purchased offsets outside the product’s value chain.

Claims based on the product’s actual life-cycle performance and real, verifiable reductions within its value chain may be treated differently. They still require appropriate substantiation and must not mislead consumers.

Companies may communicate investments in carbon-credit projects or environmental initiatives, provided that the communication is transparent and does not imply that the product itself is climate neutral.

Practical distinction

Product-performance statement:
What is the actual greenhouse-gas performance of the product across its defined life cycle?

Environmental-investment statement:
Which external climate or carbon-credit project did the company financially support?

These messages should not be combined in a way that makes the external investment appear to eliminate the product’s own emissions.

5. Future Environmental Promises Need a Credible Plan

Future-facing environmental statements may be misleading when they are not supported by:

• Clear and objective commitments
• Publicly available information
• Verifiable commitments
• A detailed and realistic implementation plan
• Measurable and time-bound targets
• Resources allocated to implementation
• Regular verification by an independent third-party expert
• Verification findings made available to consumers

Examples include:

• Net zero by 2030
• Climate positive by 2035
• Fully sustainable by 2030
• Zero environmental impact by 2040

The Directive does not establish one universal verification frequency. The appropriate frequency will depend on the claim, implementation plan and circumstances.

The Commission services’ Q&A indicates that the complete plan does not necessarily have to appear on the same medium as the headline claim. Consumers may be directed to the information, for example through a clear QR code or accessible webpage.

Can Colours, Leaves and Nature Images Create Compliance Risk?

Potentially, but not automatically.

The use of green or blue colours, leaves, water drops, animals, forests or similar visual elements does not by itself always create an environmental claim.

The relevant question is whether the complete presentation is likely to make the average consumer expect an environmental benefit.

Visual elements may contribute to an implied environmental claim or may resemble a sustainability label when combined with:

• Environmental wording
• Product names
• Logos
• Statements about natural ingredients
• Certification-like layouts
• Sustainability badges

Companies should therefore review the overall consumer impression rather than assessing words, colours and images separately.

Does the Directive Apply to Existing Stock?

Yes. There is no general old-stock exemption.

From 27 September 2026, businesses must ensure that consumer-facing environmental claims and sustainability labels comply with the new provisions, including claims on products or packaging manufactured, ordered, distributed or placed on retailers’ shelves before that date.

The Consumer Protection Cooperation Network published a common understanding in June 2026 to support a coherent and proportionate enforcement approach to genuine old-stock situations.

However, this document:

• Is not a formal CPC position
• Is not a legally binding interpretation
• Does not create a safe harbour
• Does not establish an automatic transition period
• Does not prevent authorities or courts from acting in individual cases

The document states that traders are expected to move towards compliance without delay and in good faith. Authorities may consider genuine transitional difficulties, such as packaging cycles, stock volumes, earlier purchase orders, supply-chain dependencies, product shelf life and the feasibility of corrective measures.

Possible old-stock corrective measures

Depending on the circumstances, reasonable measures may include:

• Removing or correcting online claims
• Updating advertising and promotional materials
• Changing future packaging orders
• Applying corrective stickers
• Removing non-compliant labels
• Adding corrective information at physical or online points of sale
• Coordinating with suppliers, retailers and distributors
• Documenting the actions taken and the reasons behind them

These measures do not guarantee that enforcement action will be avoided. The assessment remains case-specific and subject to national authority and court decisions.

Environmental Claim Examples and Better Compliance Direction

The legality of an individual claim will always depend on its context, presentation, evidence and the consumer impression it creates.

Where Should Companies Look for Environmental Claims?

Because the definition covers written, graphic, symbolic and implied communications, reviewing only the wording printed on the main product label will not be sufficient.

Practical EU Environmental Claims Compliance Process

Step 1: Create a central claims register

Record every environmental claim and the exact channel where it appears.

Include:

• Exact wording
• Product and SKU
• Component or packaging layer
• Country and language
• Sales channel
• Artwork or webpage version
• Publication date
• Evidence owner
• Approval status
• Planned review date

Step 2: Classify each claim

Categories may include:

• Generic environmental claim
• Specific environmental claim
• Sustainability label
• Product-wide claim
• Component-level claim
• Carbon or climate claim
• Comparative claim
• Future environmental promise
• Mandatory legal label
• Voluntary environmental communication

Correct classification helps determine which legal test, evidence and approval process should apply.

Step 3: Assess the full consumer impression

Do not assess the wording alone.

Review:

• Main headline
• Qualifying language
• Font size and placement
• Product images
• Colours
• Leaves, water drops and nature imagery
• Logos and certification marks
• QR codes
• Footnotes
• The proximity of supporting information
• Whether the claim appears to describe the whole product

Step 4: Define the claim scope

Document whether the claim concerns:

• The complete product
• One component
• Primary packaging
• Secondary packaging
• A specific facility
• A specific production process
• One product version
• A product family
• One market or all markets

Step 5: Link the claim to supporting evidence

Depending on the statement, the evidence file may include:

• Supplier declarations
• Bills of materials
• Certificates
• Test reports
• Product carbon-footprint calculations
• Life-cycle assessments
• Chain-of-custody records
• Material weights
• Energy records
• Purchase documents
• Calculation methodologies
• Independent verification reports

Evidence should relate to the correct product, version, supplier, facility and reporting period.

Step 6: Review all sustainability labels

For every label, record:

• Scheme owner
• Public or private status
• Publicly available scheme requirements
• Certification process
• Independence of the verifier
• Monitoring arrangements
• Suspension and withdrawal procedures
• Products and sites covered
• Certificate validity dates

Step 7: Separate climate claims from carbon-credit communications

For each claim, identify:

• The product’s actual emissions
• The calculation boundary
• Life-cycle stages covered
• Actual value-chain reductions
• Carbon-credit purchases
• External climate-project investments
• Whether the wording implies product neutrality

Step 8: Review future promises

Every future-facing claim should have:

• A defined baseline
• Clear scope
• Measurable milestones
• A target date
• Allocated resources
• Named responsibilities
• A realistic implementation plan
• Independent verification
• Accessible verification findings

Step 9: Establish cross-functional approval

A suitable process may involve:

1- Product or packaging owner

2- Procurement or supplier management

3- Sustainability specialist

4- Product compliance or regulatory affairs

5- Legal review

6- Marketing approval

7- Final artwork and version control

Marketing should not publish an environmental claim before the supporting product data and compliance assessment are complete.

Step 10: Prepare an old-stock correction plan

Prioritise measures that can be implemented quickly:

• Correct digital claims first
• Stop new packaging orders containing high-risk statements
• Update active advertisements
• Prepare stickers or point-of-sale notices
• Notify retailers and distributors
• Record practical constraints and corrective actions

Step 11: Monitor changes continuously

Reassess claims when there is a change to:

• Supplier
• Material
• Formula
• Packaging
• Product design
• Factory
• Energy source
• Certification
• Calculation method
• Regulation
• Marketing artwork

A claim that was previously accurate may become misleading when its supporting data changes.

Environmental Claim Evidence Checklist

Each claim file should contain, where relevant:

• Approved wording
• Claim category
• Product and SKU scope
• Component or packaging scope
• Countries and channels
• Supporting evidence
• Data source and owner
• Calculation method
• Assumptions and limitations
• Certificate validity
• Independent verification
• Legal and compliance approvals
• Artwork or webpage version
• Approval date
• Review date
• Corrective-action history

This creates a defensible record when evidence is requested by authorities, customers, retailers, auditors or internal stakeholders.

Common Anti-Greenwashing Compliance Mistakes

Using ordinary evidence to justify an unqualified generic claim

A company may have evidence of one environmental improvement and still be unable to justify a broad expression such as “eco-friendly.” Generic claims require recognised excellent environmental performance relevant to the complete claim.

Explaining the claim only on a distant webpage

Supporting information should be sufficiently close and clearly connected to the main claim. A QR code should not be used to hide important qualifications.

Confusing the product with its packaging

A packaging benefit should not be presented as a benefit of the complete product.

Accepting supplier statements without validation

Supplier data should be checked for scope, date, product, facility, material and certificate validity.

Reusing one claim across a product family

Different models, suppliers, packaging versions or production locations may require separate evidence.

Creating an internal certification-style seal

A self-created badge may be interpreted as a sustainability label even when the company intended it only as decoration.

Using offsets to support product-neutrality wording

The purchase of offsets does not establish that the product itself has a neutral, reduced or positive greenhouse-gas impact.

Assuming existing stock is automatically protected

The CPC approach may support proportionate enforcement in genuine cases, but it does not create an exemption.

Which Teams Should Be Involved?

The process becomes especially important when one department creates the claim, another owns the product data and another publishes the final communication.

How ComplyMarket Can Support Environmental-Claims Data and Evidence Management

Environmental claims often depend on product data, material information, supplier documentation and evidence stored across multiple departments.

ComplyMarket can support companies by providing a structured platform for collecting supplier information, managing product and material data and coordinating compliance activities.

Centralise supplier and product evidence

ComplyMarket’s material and sustainability compliance software supports the collection of compliance and sustainability information from suppliers. It provides digital storage, supplier questionnaires and structured data from product and component level down to materials and substances.

Improve supplier engagement

Teams can use structured questionnaires, supplier accounts and automated communications to request declarations and supporting information rather than relying only on separate emails and spreadsheets.

Connect claims to product scope

A structured product-data model can help distinguish between:

• Product claims
• Component claims
• Packaging claims
• Supplier-specific evidence
• Material-level evidence
• Market-specific communications

This reduces the risk that evidence for one product or component is incorrectly reused for another.

Support collaboration and document control

ComplyMarket’s product compliance capabilities include assigning tasks, requesting documentation and collaborating with internal teams and suppliers through a shared platform.

Strengthen recycled-content claim controls

ComplyMarket’s recycled-content claims service describes workflows for substantiation, scope definition, supplier evidence, calculation methods, chain-of-custody controls, claim registers, approval and version management.

Maintain an auditable compliance process

Structured sustainability compliance management can help businesses document:

• Which requirements apply
• Which evidence has been collected
• Which information is missing
• Which claims are approved
• Which products require corrective action
• When documents or certifications need review

ComplyMarket supports the information, evidence and workflow needed for compliance decisions. It does not replace legal advice, independent scientific verification or the final technical and legal assessment of a specific environmental claim.

Frequently Asked Questions

Do the EU anti-greenwashing rules apply from 27 September 2026?

Yes. Member States had to adopt and publish national implementing measures by 27 March 2026 and must apply them from 27 September 2026.

Are all environmental claims prohibited?

No. The Directive prohibits specific practices and strengthens the assessment of potentially misleading communications. Specific environmental claims may still be used when they are accurate, properly scoped, substantiated and presented without misleading consumers.

Can a business continue using “eco-friendly”?

An unqualified generic claim such as “eco-friendly” requires recognised excellent environmental performance relevant to the claim. Providing a clear and prominent specification on the same medium may mean that the statement is treated as a specific rather than generic claim, but it must still comply with the wider consumer-protection rules.

Are self-created sustainability labels allowed?

A sustainability label must be based on a certification scheme meeting the Directive’s conditions or be established by a qualifying public authority. A self-created badge may be prohibited when it functions as a sustainability label without meeting those requirements.

Can a company call a product carbon neutral because it purchased offsets?

No. A claim that a product or service has a neutral, reduced or positive greenhouse-gas impact cannot be based on greenhouse-gas offsetting.

Can companies discuss carbon-credit investments?

Yes, provided the communication is transparent, accurate and does not imply that the product itself has no or lower climate impact because of the credits.

Are green colours and leaves automatically prohibited?

No. Their legal significance depends on context, presentation and the impression they create for the average consumer. They may contribute to an implied claim or sustainability label when combined with environmental wording or certification-style presentation.

Is existing stock exempt?

No general exemption applies. The CPC Network has described a possible proportionate enforcement approach for genuine transitional cases, but the document is non-binding and does not provide a guaranteed safe harbour.

Does the Directive apply to B2B communications?

The harmonised framework is focused on B2C commercial practices. Other EU or national laws may still regulate misleading B2B advertising and environmental claims.