Green Claims Directive EU: the proposal is stalled, and what you may say about a product is already law

The Green Claims Directive is not law, and you do not wait for it: the rules on what you may say about a product’s environmental credentials already apply. Directive (EU) 2024/825Directive (EU) 2024/825, Empowering Consumers for the Green TransitionThe whole regulationClick opens the law on the EU Publications Office. applies from 27 September 2026 (Art. 4(1) of Directive (EU) 2024/825). It bans vague claims such as “eco-friendly”, climate neutral claims that rest on offsetting, and sustainability badges you made yourself, and it applies to a seller outside the EU as to one inside: the Commission’s Questions and Answers say the Unfair Commercial Practices Directive covers commercial practices relevant to consumers in the Single Market whether the trader or product comes from the EU or from a third country.

What you do:

1. Take vague green words off your listings, packaging and ads: “eco-friendly”, “green”, “environmentally friendly”, “climate friendly”, “sustainable”, “biodegradable”, “natural” where it reads as an environmental promise. Keep one only if the product holds the EU Ecolabel, a recognised national ecolabel or top environmental performance under other EU law (for example class A on the energy label), in each case relevant to that claim, or if you say exactly what you mean in clear and prominent terms next to it, on the same page or pack. “Sustainable” cannot rest on an ecolabel alone, because it reaches social characteristics too (Annex I point 4a, Art. 2(p)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 2, point (p)Click opens the article on EUR-Lex. and Art. 2(s)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 2, point (s)Click opens the article on EUR-Lex. of Directive 2005/29/EC; recital 10 of Directive (EU) 2024/825).
2. Remove “climate neutral”, “CO2 neutral”, “carbon positive” and “climate compensated” from a product when the claim rests on offsetting (Annex I point 4c of Directive 2005/29/EC). Without offsets, an unqualified “climate neutral” is still a generic claim: it needs the specification in clear and prominent terms on the same medium, or recognised excellent environmental performance (Annex I point 4a of Directive 2005/29/EC; Commission Questions and Answers, question 6).
3. Show a sustainability label only if a certification scheme stands behind it or a public authority established it. A badge you drew yourself has to go (Annex I point 2a and Art. 2(r)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 2, point (r)Click opens the article on EUR-Lex. of Directive 2005/29/EC).
4. When a claim covers only one part, say which part: “packaging made from recycled material”, not “made with recycled material” (Annex I point 4b of Directive 2005/29/EC; recital 11 of Directive (EU) 2024/825).
5. Keep a promise about the future (“net zero by 2030”) only if a detailed, realistic plan with measurable, time-bound targets stands behind it and an independent expert verifies it regularly (Art. 6(2)(d)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 6, paragraph 2, point (d)Click opens the article on EUR-Lex.).
6. Do not sell a legal duty as a feature. If the law already forbids a substance in every product of the category, “without that substance” is not a selling point (Annex I point 10a of Directive 2005/29/EC).
7. Claim durability and repairability only where they hold, and pass on the producer’s durability information to the buyer (Annex I points 23f to 23h of Directive 2005/29/EC; Art. 6(1)Directive 2011/83/EU, Consumer Rights Directive (consolidated text of 27 September 2026)Article 6, paragraph 1Click opens the article on EUR-Lex.). The rules are in the next sections.
8. Keep the evidence for each claim. A court or authority can require it, and can treat the claim as inaccurate if you do not supply it (Art. 12Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 12Click opens the article on EUR-Lex.).

Do nothing, and a claim that falls under a ban of Annex I is unfair in all circumstances (Art. 5(5)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 5, paragraph 5Click opens the article on EUR-Lex.), and the Commission’s Questions and Answers add that nobody has to show the practice changed a consumer’s decision. Courts or authorities can order you to stop, national law sets the fines, and a consumer can claim remedies. The section “What happens if you do nothing” gives the figures.

The Green Claims Directive is neither adopted nor withdrawn, and no source sets a date for it

The Commission announced on 20 June 2025 that it intends to withdraw the proposal, and the trilogue that was to meet on 23 June 2025 was cancelled. The proposal was not formally withdrawn. The Commission’s own work programme for 2026 still lists it as pending, and the Parliament shows it as blocked. In October 2026 the position is this:

The Parliament’s procedure file shows the status “Awaiting Council’s 1st reading position” and lists 16 December 2024 as its last key event. None of the sources read on 6 October 2026 names a date for new talks. The proposal could be revived, changed or withdrawn, and no source says which.

Directive (EU) 2024/825 applies from 27 September 2026 and reaches you through national law

The Directive has no transition period beyond the application date. The Commission’s Questions and Answers say so for sustainability labels: a label on the market on 27 September 2026 must comply, and a scheme that does not meet the definition must be adapted or its label removed from commercial communications.

National law. The Directive changes the Unfair Commercial Practices Directive, which each country has turned into its own law. On 6 October 2026, 21 of the 27 countries had notified a national measure for Directive (EU) 2024/825Directive (EU) 2024/825, Empowering Consumers for the Green TransitionThe whole regulationClick opens the law on the EU Publications Office. to the Commission: Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, the Netherlands, Romania and Slovakia. Not every entry is a new law for this Directive: the four Czech texts notified are all older than it. No notified measure shows for Malta, Poland, Portugal, Slovenia, Spain or Sweden. A notification list can lag the law, so a country that is not on it may still have passed a law. For those countries the Directive is the text to read.

Germany shows what a national text looks like. The annex of its Unfair Competition Act (UWG), the list of practices always unfair towards consumers, carries the new points: number 2a on a sustainability label without a certification scheme or state establishment, 4a on a generic environmental claim without demonstrable recognised excellent environmental performance, 4b on a claim about the whole product or business that concerns one aspect, and 4c on an offset-based claim of neutral, reduced or positive greenhouse gas impact (UWG, Anhang zu § 3 Absatz 3). Germany notified a law amending the UWG for this Directive, and Austria notified an amendment to its own Act against Unfair Competition.

An environmental claim is any message that says or implies a positive or zero impact, in any form

The Unfair Commercial Practices Directive now defines an environmental claim as any message or representation, not mandatory under Union or national law, in any form, including text, pictures, symbols, labels, brand names, company names or product names, in a commercial communication, that states or implies that a product, product category, brand or trader has a positive or zero impact on the environment, is less damaging than others, or has improved its impact over time (Art. 2(o)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 2, point (o)Click opens the article on EUR-Lex.). In practice:

• A brand or product name can be a claim. Words such as “green”, “eco”, “natural” or “climate neutral” in a name count when they create an environmental association for the average consumer. A name that merely contains “green” or “blue” does not, when in context nobody would expect an environmental benefit (Commission Questions and Answers, question 3).
• Pictures and colours can imply a claim. A leaf or a water drop next to a logo or a statement about sustainability or natural ingredients may read as an environmental claim or as a trust mark. Images and colours alone are not a generic claim, which needs written or spoken words (Commission Questions and Answers, questions 2 and 5).
• The bans protect consumers. Business-to-business communication is outside the Unfair Commercial Practices Directive and its Annex I bans, but not outside the law: it falls under Directive 2006/114/EC on misleading advertising, and a country may extend consumer-style protection to businesses in its own law. Content from a mandatory sustainability report is outside the consumer rules too, until you use it in advertising or marketing aimed at consumers (Commission Questions and Answers, question 1).
• Mandatory information is not a claim. The definition leaves out anything mandatory under Union or national law, such as the EU energy label.

A generic claim is banned unless you can show recognised excellent environmental performance

A generic environmental claim is an environmental claim in written or spoken form, not on a sustainability label, where the specification of the claim is not given in clear and prominent terms on the same medium (Art. 2(p)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 2, point (p)Click opens the article on EUR-Lex.). Making one without being able to demonstrate recognised excellent environmental performance relevant to the claim is banned in all circumstances (Annex I point 4a of Directive 2005/29/EC). Recital 9 lists examples: “environmentally friendly”, “eco-friendly”, “green”, “nature’s friend”, “ecological”, “environmentally correct”, “climate friendly”, “gentle on the environment”, “carbon friendly”, “energy efficient”, “biodegradable” and “biobased”.

Two ways out. State the claim specifically on the same medium, such as the same listing, the pack or the advertising spot, and it is no longer generic, though it must still be true. Or hold recognised excellent environmental performance, which means one of three things (Art. 2(s)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 2, point (s)Click opens the article on EUR-Lex.; Commission Questions and Answers, question 7):

1. Compliance with the EU Ecolabel, Regulation (EC) No 66/2010Regulation (EC) No 66/2010, EU Ecolabel (consolidated text of 14 November 2017)The whole regulationClick opens the law on the EU Publications Office..
2. Compliance with a national or regional EN ISO 14024 type I ecolabelling scheme officially recognised in an EU country. The Commission names the Nordic Swan, the Blue Angel, the Austrian Ecolabel and the Dutch Milieukeur.
3. Top environmental performance in accordance with other Union law, such as class A under the energy labelling Regulation (EU) 2017/1369Regulation (EU) 2017/1369, Energy Labelling Regulation (consolidated text of 1 May 2021)The whole regulationClick opens the law on the EU Publications Office..

The performance has to be relevant to the whole claim. Recital 10 gives two cases: “energy efficient” can rest on the energy label, but “biodegradable” cannot rest on the EU Ecolabel when the Ecolabel criteria for that product set no biodegradability requirement; and “conscious”, “sustainable” or “responsible” cannot rest only on environmental excellence, because they reach social characteristics as well.

Climate neutral and carbon neutral product claims based on offsets are banned, and net zero promises need a verified plan

Claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of those emissions is banned in all circumstances (Annex I point 4c of Directive 2005/29/EC). Recital 12 gives the examples “climate neutral”, “CO2 neutral certified”, “carbon positive”, “climate net zero”, “climate compensated”, “reduced climate impact” and “limited CO2 footprint”. What stays allowed:

• A claim based on the product’s own life cycle. A claim of neutral, reduced or positive impact is allowed when it rests on the actual life-cycle impact of that product, not on offsets outside its value chain. The Commission’s example is “reduced CO2 impact”, stated in clear and prominent terms on the same medium and based on real improvements in production (recital 12; Commission Questions and Answers, question 10). Point 4c does not clear the wording itself. The Commission says generic claims such as “carbon-neutral”, “climate neutral”, “carbon compensated” or “carbon positive” are prohibited unless the trader can demonstrate recognised excellent environmental performance relevant to the claim (Annex I point 4a), so a bare “climate neutral” needs the specification next to it even when no offsets are involved (Commission Questions and Answers, question 6).
• Advertising your investment in a climate project. Point 4c does not stop you from advertising investments in environmental initiatives, including carbon credit projects, as long as the information is not misleading (recital 12).
• A claim at company level. Point 4c covers products. A claim about the business based on offsets stays under the general misleading-practice rules (Commission Questions and Answers, question 10).

A claim about future performance, such as a transition to climate neutrality by a date, is misleading when it lacks clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan with measurable and time-bound targets and allocated resources, regularly verified by an independent third-party expert whose findings consumers can see (Art. 6(2)(d)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 6, paragraph 2, point (d)Click opens the article on EUR-Lex.). This one is judged case by case, not banned outright. The Commission says the findings and the plan can sit behind a QR code that leads to your website, and that the Directive gives no interval for “regularly”. The Commission services suggest best practice of annual or biennial reviews, or extra verification when something significant changes (Commission Questions and Answers, question 12).

A sustainability label must rest on a certification scheme or come from a public authority

Displaying a sustainability label that is not based on a certification scheme or not established by public authorities is banned in all circumstances (Annex I point 2a of Directive 2005/29/EC). A sustainability label is any voluntary trust mark, quality mark or equivalent, public or private, that sets apart and promotes a product, process or business by its environmental or social characteristics (Art. 2(q)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 2, point (q)Click opens the article on EUR-Lex.). A certification scheme is a third-party verification scheme whose public terms meet four conditions (Art. 2(r)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 2, point (r)Click opens the article on EUR-Lex.):

1. It is open to every trader willing and able to comply, on transparent, fair and non-discriminatory terms.
2. Its requirements are set by the scheme owner in consultation with relevant experts and stakeholders.
3. It has procedures for non-compliance, including withdrawing or suspending use of the label.
4. A third party, whose competence and independence from both the scheme owner and the trader rest on international, Union or national standards, monitors compliance by an objective procedure.

Three points from the Commission’s Questions and Answers matter to a non-EU seller. A scheme owner and a trader may be the same entity if the scheme meets the criteria, but the monitoring third party must be a separate legal entity. A label established by the public authority of a country outside the EU is barred unless it also rests on a certification scheme, because the Commission reads “public authorities” as EU public authorities. And a trade mark is unlikely to be a sustainability label, except a certification mark within the meaning of Article 27 of the Trade Mark Directive, which you may display only if a public authority established it or a certification scheme stands behind it (questions 3, 8 and 17).

The EU Ecolabel is voluntary, and a product from outside the EU applies to a competent body in any EU country where it is sold

The EU Ecolabel is a voluntary scheme (Art. 1 of Regulation (EC) No 66/2010). It is the label that settles the generic-claims question most directly, because compliance with it is recognised excellent environmental performance. The steps in the Regulation:

1. Apply. An operator applies to a competent body. For a product that originates outside the Union, the application goes to a competent body in any of the EU countries in which the product is to be or has been placed on the market (Art. 9(1)(c) of Regulation (EC) No 66/2010).
2. Meet the criteria for your product group. The label may be used only on products that comply with the criteria applicable to them and for which it has been awarded (Art. 9(2) of Regulation (EC) No 66/2010). The operator bears the costs of testing and assessment and pays the fees (Art. 9(4) and 9(5) of Regulation (EC) No 66/2010).
3. Sign the contract, then use the label. The competent body concludes a contract on the terms of use. You may place the label on the product only after that, and you also place the registration number on it (Art. 9(8) and 9(9) of Regulation (EC) No 66/2010).
4. Keep within the licence. The label may appear on the product and its promotional material. It may not become a component of a trade mark (Art. 9(11) and 9(13) of Regulation (EC) No 66/2010).

A label or logo that confuses with the EU Ecolabel, and any false or misleading advertising of it, is prohibited (Art. 10(1) of Regulation (EC) No 66/2010). That ban binds everyone, holder or not: do not use a logo that can be mistaken for the EU Ecolabel. The steps above bind only a holder.

Whole-product claims, irrelevant benefits, comparisons and legal requirements are judged separately

• A claim about the whole product when only part is meant. Banned in all circumstances (Annex I point 4b of Directive 2005/29/EC). Recital 11 gives the examples: “made with recycled material” when only the packaging is recycled, or implying that a business uses only renewable energy when several of its sites still use fossil fuels. You may still make accurate, verifiable claims about the whole business if they do not overstate the benefit.
• A benefit that is irrelevant. Advertising benefits to consumers that are irrelevant and do not result from any feature of the product or business is misleading, case by case (Art. 6(2)(e)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 6, paragraph 2, point (e)Click opens the article on EUR-Lex.). The Commission’s examples: “gluten-free” on bottled water is irrelevant; “nickel-free” on jewellery can be fine, because some jewellery does contain nickel (Commission Questions and Answers, question 11).
• A comparison service. If you run a service that compares products or suppliers on environmental or social characteristics or on durability, reparability or recyclability, the method of comparison, the products compared, their suppliers and the measures that keep the information up to date are material information (Art. 7(7)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 7, paragraph 7Click opens the article on EUR-Lex.).
• A legal requirement sold as a feature. Presenting a requirement that the law imposes on all products of the category on the Union market, imported ones included, as a distinctive feature of your offer is banned in all circumstances (Annex I point 10a of Directive 2005/29/EC). The ban does not reach a requirement that covers only some products of the category, such as products not made outside the Union (recital 15; Commission Questions and Answers, question 16).

Durability, repair and software update claims have seven bans of their own

Directive (EU) 2024/825Directive (EU) 2024/825, Empowering Consumers for the Green TransitionThe whole regulationClick opens the law on the EU Publications Office. also adds practices tied to early obsolescence to Annex I. For a seller, the reach differs by role: recitals 19, 20 and 24 say a producer is expected to know the facts, and a seller who is not the producer is caught once reliable information is available to it, such as a statement from a competent national authority or information from the producer. Then the ban applies whether or not the seller is actually aware of that information, for example because it neglects it (recital 19).

The same Directive adds information you give before the contract. You tell the buyer the reparability score where there is one, whether or not the producer passes it on. Where the producer gives you the information, you also tell the buyer the minimum period of software updates and, where there is no reparability score, the availability and estimated cost of spare parts and the repair restrictions (Art. 6(1)(lc)Directive 2011/83/EU, Consumer Rights Directive (consolidated text of 27 September 2026)Article 6, paragraph 1, point (lc)Click opens the article on EUR-Lex., Art. 6(1)(u)Directive 2011/83/EU, Consumer Rights Directive (consolidated text of 27 September 2026)Article 6, paragraph 1, point (u)Click opens the article on EUR-Lex., Art. 6(1)(v)Directive 2011/83/EU, Consumer Rights Directive (consolidated text of 27 September 2026)Article 6, paragraph 1, point (v)Click opens the article on EUR-Lex.). Smartphones and tablets carry a reparability score since 20 June 2025 (Commission Questions and Answers, question 19). You also tell the buyer about environmentally friendly delivery options where available (Art. 6(1)(g)Directive 2011/83/EU, Consumer Rights Directive (consolidated text of 27 September 2026)Article 6, paragraph 1, point (g)Click opens the article on EUR-Lex.). You do not have to search for the producer’s information yourself (recital 36). The harmonised label for a producer’s durability guarantee of more than two years and the legal-guarantee notice are on EU warranty law, and the repair duty of the manufacturer is on EU right to repair.

Environmental claims on a cosmetic follow the same bans, plus the cosmetic claims rules

A cosmetic is a product like any other under these bans: “eco-friendly” on a shampoo is a generic claim, and a self-made badge that promotes environmental or social qualities is a sustainability label. The six criteria for any cosmetic claim, the proof in the product information file and the claims that turn a cosmetic into a medicine are on cosmetic claims. Recycling symbols on packaging are on packaging recycling symbols.

Authorities and courts have already acted on environmental claims, under rules that applied before 27 September 2026

The general misleading-action rules caught environmental claims before the new bans. A practice is misleading if it contains false information or deceives, or is likely to deceive, the average consumer in any way, including by its overall presentation and even if the information is factually correct, about the main characteristics of a product (Art. 6(1)(b)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 6, paragraph 1, point (b)Click opens the article on EUR-Lex.), which since this Directive names environmental and social characteristics and circularity aspects. Three sourced examples:

• A sweep of online shops, 2020. Consumer authorities from 24 EU countries, two EEA countries and the United Kingdom assessed 344 sustainability claims, mostly in web shops, in November 2020. In almost half of the cases they had reason to believe the claim might be false or deceptive. In 57.5 % of the cases the trader did not give enough information to assess the claim, and in 37 % the claim used vague wording such as “environmental friendly”, “eco-friendly” or “sustainable”.
• Germany, 27 June 2024. The Federal Court of Justice held that advertising with an ambiguous environmental term, here “klimaneutral” for fruit gums whose maker supported climate projects through a partner without a CO2-neutral production process, is regularly allowed only if the advertisement itself explains what the term means (judgment I ZR 98/23). A product called climate neutral because of offsets is the case that point 4c now bans outright.
• Italy, 4 August 2025. The competition and consumer authority fined Infinite Styles Services Co. Ltd, the company that runs Shein’s websites in Europe, EUR 1 million for misleading and omissive green claims. It found claims on a circular system and recyclability false or confusing, “green” fibres promoted without saying the line was a marginal part of the range, and emission targets that were vague and contradicted by rising emissions in 2023 and 2024.

Claims on old stock count from 27 September 2026, and online claims are reviewed first

The Commission’s Questions and Answers say traders must make their environmental claims and labels comply from 27 September 2026 “including for existing products or old stock”, meaning goods or packaging already made, ordered, distributed or on shelves before that date (question 18). Where a claim on packaging does not comply, covering or correcting it with stickers, or adding information at the point of sale, are practical options.

The Consumer Protection Cooperation network, the national authorities, agreed a common understanding in June 2026. Old stock does not exempt you, and you move towards compliance without delay and in good faith (principle 1). Authorities may phase enforcement where there are genuine and specific transitional difficulties, and may look first at claims already dealt with under the earlier rules, at online claims, at the practices most harmful to consumers, at non-packaging claims and marketing materials, and at products with a short shelf-life (principle 2). They expect reasonable and proportionate efforts and records of the steps and their timing, for example removing or correcting online claims, updating advertising, changing future packaging and orders, stickers and corrective information (principle 4). They may refrain from requiring destruction or recall (principle 5). The document is not a formal position of the network or a binding interpretation, and it names no length of transitional period: the duration depends on the product group and the case (principle 2, note 6).

What happens if you do nothing

Penalties are national. Each country sets its own, and they must be effective, proportionate and dissuasive (Art. 13(1)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 13, paragraph 1Click opens the article on EUR-Lex.). Where a coordinated action under Regulation (EU) 2017/2394 leads to penalties, countries must provide for fines with a maximum of at least 4 % of the trader’s annual turnover in the countries concerned, or at least EUR 2 million where the turnover is not known (Art. 13(3)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 13, paragraph 3Click opens the article on EUR-Lex., Art. 13(4)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 13, paragraph 4Click opens the article on EUR-Lex.). Courts or authorities can order you to stop, or prohibit an imminent practice, without proof of loss or intent (Art. 11(2)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 11, paragraph 2Click opens the article on EUR-Lex.). Persons or organisations with a legitimate interest, competitors included, can take legal action or bring the practice before an administrative authority (Art. 11(1)Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 11, paragraph 1Click opens the article on EUR-Lex.). A consumer harmed by an unfair practice has proportionate and effective remedies, including compensation and, where relevant, a price reduction or termination of the contract (Art. 11aDirective 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 11aClick opens the article on EUR-Lex.). An unproven claim also works against you in court: where you do not furnish the evidence a court asks for, it can treat the claim as inaccurate (Art. 12Directive 2005/29/EC, Unfair Commercial Practices Directive (consolidated text of 27 September 2026)Article 12Click opens the article on EUR-Lex.).