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EU green claims rules from September 2026: what brands need to know

Dave Hoogakker
February 20, 2024
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5 min read
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EU green claims rules from September 2026: what brands need to know

From 27th September 2026, EU Member States are required to apply new rules on environmental claims introduced by Directive (EU) 2024/825, known as the Empowering Consumers for the Green Transition Directive.‍

These rules restrict several types of environmental claim, including generic terms such as “eco-friendly” where the required environmental performance cannot be demonstrated. They also cover sustainability labels, claims based on carbon offsetting and claims about future environmental performance.

This article explains which rules apply from September 2026 and how the changes affect environmental claims, labels and marketing.

EU green claims rules at a glance

Date

What happened

March 2023

The European Commission proposed the separate Green Claims Directive, intended to introduce detailed requirements for substantiating and verifying environmental claims.

February 2024

The EU adopted Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive.

March 2024

The European Parliament adopted its first-reading position on the proposed Green Claims Directive.

June 2025

The Commission announced its intention to withdraw the Green Claims Directive proposal. A planned third trilogue was cancelled.

March 2026

Deadline for EU Member States to transpose Directive 2024/825 into national law.

27th September 2026

Member States must apply their implementing measures for Directive 2024/825.

What is the Empowering Consumers for the Green Transition Directive?

This Directive introduces new protections against misleading environmental claims and labels. For brands, it means some claims and labelling practices will be banned outright, while others will still need to meet the wider rules on misleading commercial practices.

The rules don't only apply to packaging. Environmental claims on websites, in advertising and across other marketing materials are covered too.

Consumers themselves aren't always sure which environmental claims to trust. In the European Commission’s 2024 Consumer Conditions Survey, 62% of people said they found it difficult to tell which products and services were environmentally friendly. The same percentage said environmental claims weren’t always trustworthy.

Is the Green Claims Directive still happening?

The Green Claims Directive is separate from the rules coming into force in September 2026. It was proposed in 2023, but has not been adopted, so its requirements are not currently law.

Negotiations stalled in June 2025 and there is no date for them to restart. The proposal is still officially pending, although the European Parliament lists it as blocked.

For now, brands should focus on the rules that are coming into force under the Empowering Consumers for the Green Transition Directive, rather than treating proposals from the Green Claims Directive as requirements they already have to meet.

Which environmental claims are banned from 27th September 2026?

Directive 2024/825 adds several environmental practices to the EU's blacklist of unfair commercial practices. For brands, the main restrictions on environmental claims and labels are:

Claim or practice

What the rules say

Example

Generic environmental claims

Generic claims cannot be made where the required recognised excellent environmental performance cannot be demonstrated.

Claims such as “eco-friendly”, “green” and “environmentally friendly” need evidence of recognised excellent environmental performance.

Offset-based product claims

A business cannot claim that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions when that claim is based on offsetting emissions.

Claims such as “climate neutral” or “CO2 neutral” are prohibited where they are based on carbon offsetting.

Misleading sustainability labels

Sustainability labels must be based on a certification scheme or established by a public authority.

A green badge that looks like an independent sustainability certification may be misinterpreted as a sustainability label.

Whole-product claims based on one feature

An environmental claim about an entire product or business cannot be based on an environmental feature that applies only to one part or activity.

If only the packaging contains recycled material, describing the whole product as “made from recycled material” could mislead consumers.

Future environmental performance

Claims about future environmental performance need commitments set out in a detailed implementation plan with measurable and time-bound targets, along with the independent expert verification required by the Directive.

Statements about becoming carbon neutral or reducing environmental impacts by a future date need evidence behind the commitment.

The Directive also covers product durability, repairability, software updates and commercial guarantees, so brands should check the wider requirements as well as the rules on environmental claims.

‍Does this mean words such as “green” and “eco-friendly” are completely banned?‍

No single list of words can tell you whether every environmental claim is compliant.

The Directive prohibits a generic environmental claim where recognised excellent environmental performance relevant to the claim cannot be demonstrated.

It specifically gives examples of generic claims including terms such as, or equivalent to:

  • Environmentally friendly
  • Eco-friendly
  • Green
  • Nature's friend
  • Ecological
  • Environmentally correct
  • Climate friendly
  • Gentle on the environment
  • Carbon friendly
  • Energy efficient
  • Biodegradable
  • Biobased

Context is important. A specific, properly supported statement about an environmental characteristic is different from putting an unqualified “green” claim on a pack.

Brands should therefore review the complete claim: its wording, prominence, supporting evidence and the impression consumers are likely to take from it.

What about “carbon neutral” claims?

This is one of the most significant changes for brands using environmental claims.

The Directive prohibits claims, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.

That includes claims such as “climate neutral”, “CO2 neutral certified”, “carbon positive”, “climate net zero” and “climate compensated” where they are based on offsetting. This does not amount to a general ban on communicating information about carbon credits or environmental projects. 

‍What do the rules say about sustainability labels?

Under the new rules, displaying a sustainability label that is not based on a certification scheme or established by a public authority is prohibited.

Be careful with environmental symbols on packaging too. A leaf or globe paired with environmental wording, for example, could look like a sustainability label even if it was only intended as a design element.

Do the EU environmental rules apply to UK and US brands?

Being based outside the EU does not mean a business can disregard EU consumer rules when selling into EU markets.

The Directive requires EU Member States to implement these rules through national law. UK and US brands selling to EU consumers, therefore, need to ensure that environmental claims used in those markets comply with the applicable national implementing rules.

For UK brands exporting consumer products to the EU, this can mean reviewing environmental claims on packaging, websites and marketing material intended for those markets.

It also makes version control important. Wording that is being used for the UK market should not automatically be assumed to be suitable for an EU pack or campaign.

‍What are the green claims rules in the UK?

The UK has its own consumer protection regime. The CMA's Green Claims Code sets out principles businesses should consider when making environmental claims. Among other things, claims should be truthful and accurate, should not omit important information and should be capable of being substantiated.

In addition, the consumer protection provisions of the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) have applied since 6th April 2025. They replaced and updated the previous Consumer Protection from Unfair Trading Regulations.

The CMA now has direct consumer enforcement powers and businesses that break consumer law can face fines of £300,000 or up to 10% of worldwide turnover, whichever is higher.

Do any other European countries have eco-labelling legislation?

Some European countries have additional environmental labelling requirements. For example: 

‍France launched its environmental cost display for clothing on 1st October 2025. The voluntary scheme allows participating brands to display a garment's environmental cost in impact points.

‍Italy requires environmental labelling on packaging to help consumers identify and dispose of packaging materials correctly. The requirement became mandatory in January 2023, following several postponements.

If your product is sold in several European markets, it’s worth checking the environmental and disposal labelling requirements in each country where it will be sold.

What should brands review now?

With the EU measures applying from 27th September 2026, environmental claims already in use deserve a fresh review.

  • Start with the environmental claims you're already using. Check what each one says and whether you have the evidence to support it.

  • Look at future claims too. If you’re promising an environmental improvement by a certain date, you’ll need a realistic plan for achieving it, measurable targets and independent expert verification.

  • Don't just update your packing. Look for the same claims on your website, retailer listings, adverts, point-of-sale material and social content.

  • Artwork needs a final check as well. When a claim appears, how prominent it is and how close it is to any qualifying wording can change how consumers interpret it.

‍Hooley Brown helps brands validate product claims, labels and artwork before products go to market.

‍Need help reviewing your environmental claims? Schedule a call with our product compliance team.

Environmental product claims FAQs

‍When do the new EU green claims rules start?

EU Member States were required to transpose Directive (EU) 2024/825 by 27th March 2026. The national measures implementing the Directive must apply from 27th September 2026.

‍Is the EU Green Claims Directive in force?

No. It hasn't been adopted, so the proposed Green Claims Directive does not currently create legal obligations for businesses. Negotiations stalled in June 2025 and, while the proposal remains officially pending, the European Parliament currently lists it as blocked.

‍Are “eco-friendly” claims banned in the EU?

The new rules prohibit generic environmental claims such as “eco-friendly” where recognised excellent environmental performance relevant to the claim cannot be demonstrated. That doesn't mean every use of the words “eco-friendly” is automatically banned: the wording, context and evidence behind the claim all need to be considered.

‍Can brands still say a product is carbon neutral?

Not if the claim that the product has a neutral, reduced or positive greenhouse-gas impact is based on carbon offsetting. Brands using terms such as “carbon neutral” should check what the claim is based on before continuing to use it.

‍Do UK brands have to follow the EU green claims rules?

Yes, if they're selling or marketing products to consumers in EU countries. They need to comply with the rules in those markets, while claims aimed at UK consumers need to comply with UK consumer protection law, including the DMCC Act.

‍This article was first published in February 2024 and most recently reviewed in September 2026. Regulations, standards and enforcement guidance can change. Always verify current requirements and seek professional advice for your specific situation.

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