EU Anti-Greenwashing Rules Take Effect, Tightening Standards for Environmental Claims

Key Takeaways

• New Rules Now Apply: EU measures implementing Directive (EU) 2024/825 have applied since September 27, 2026, strengthening consumer protections against greenwashing and misleading sustainability claims.
• Generic Green Claims Face Stricter Limits: Businesses cannot use broad claims such as “eco-friendly,” “green” or “climate friendly” without demonstrating recognized excellent environmental performance relevant to the claim.
• Offset-Based Product Claims Are Prohibited: Companies cannot claim a product has a neutral, reduced or positive greenhouse gas impact when that claim is based on offsetting emissions.
• Sustainability Labels Need Independent Foundations: Sustainability labels must be established by a public authority or based on a certification scheme that meets the directive’s requirements.
• Future Environmental Promises Need Evidence: Claims about future environmental performance must be supported by verifiable commitments, measurable and time-bound targets, a detailed implementation plan and regular independent third-party verification.

Deep Dive

New consumer protection rules against greenwashing began applying on September 27, bringing into force a set of restrictions that reach directly into the words, labels and environmental promises businesses place in front of consumers. Directive (EU) 2024/825, adopted in February 2024, amends the EU’s Unfair Commercial Practices Directive and Consumer Rights Directive. Member States had until March 27, 2026, to transpose it into national law. Those measures have now entered into application.

The changes are meant to deal with a problem European regulators have been circling for years: environmental marketing that gives a consumer a clear impression without giving them much that can be checked. The new rules make some of those boundaries considerably harder.

Generic environmental claims such as “environmentally friendly,” “eco-friendly,” “green,” “climate friendly” and “biodegradable” are prohibited where a business cannot demonstrate recognized excellent environmental performance relevant to the claim. Broader language such as “sustainable” and “responsible” can also fall within the prohibition when it suggests environmental characteristics that have not been demonstrated.

That does not make environmental marketing itself unlawful. It changes what a business must be prepared to stand behind. A specific claim that can be substantiated is treated differently from a broad green assertion. The directive gives the example of stating that 100% of the energy used to produce a particular package comes from renewable sources. The difference is a practical one. The consumer is being told what is environmentally better about the product rather than being left to supply the meaning of “green” for themselves.

The same logic follows a claim across the boundaries of a product. An environmental benefit belonging to one part of a product cannot be presented as though it belongs to the whole thing. Recycled packaging does not make the product inside it recycled. Renewable electricity at some of a company’s facilities does not make its entire business run on renewable energy.

For compliance teams, those boundaries matter because greenwashing is often made in the space between the literal words of an advertisement and the larger conclusion a consumer is invited to draw from them. The directive is aimed squarely at that space.

Carbon claims now meet an even clearer prohibition. Businesses cannot claim that a product has a neutral, reduced or positive greenhouse gas impact when that conclusion rests on offsetting emissions. The directive specifically identifies expressions such as “climate neutral,” “CO2 neutral certified,” “carbon positive,” “climate net zero,” “climate compensated” and “reduced climate impact” as examples of claims that can create the impression that the product itself has such an impact because greenhouse gas emissions have been offset.

Companies can still tell consumers that they invest in environmental initiatives or carbon-credit projects. What they cannot do is use those investments to give a product environmental characteristics it does not itself possess.

The restriction lands at a particularly sensitive point in corporate climate marketing. Buying an offset and reducing the emissions associated with producing a product are not the same act. From September 27, EU consumer law gives businesses considerably less room to allow the first to be presented as the second.

Sustainability labels face a similar test of what sits behind the symbol. A business can no longer display a sustainability label unless it is based on a certification scheme meeting the directive’s requirements or has been established by a public authority. The certification schemes themselves must satisfy conditions intended to keep the labels from becoming self-awarded seals of environmental virtue, including publicly available terms and independent monitoring of compliance.

The rule does not merely police what a label says. It asks who stands behind it. There is another category of environmental claim that cannot be settled by examining what a company has already done: the promise about what it will do next.

Businesses making claims about future environmental performance need clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan. That plan must contain measurable and time-bound targets and the other elements necessary to achieve them, including the allocation of resources. Progress must be regularly verified by an independent third-party expert, with the findings made available to consumers. A distant environmental target, in other words, cannot survive merely because the date for proving it wrong has not arrived.

The directive goes further than greenwashing. It also strengthens protections against practices associated with early obsolescence and is designed to give consumers better information about the durability and reparability of goods and their legal guarantee rights. The European Commission describes the measure as an attempt to make the EU’s horizontal consumer law better suited to the green transition.

Some of those changes are now visible at the point of sale. Since September 27, consumers can begin seeing a harmonized EU notice explaining their legal guarantee rights and a new EU GARAN label for qualifying commercial durability guarantees. The mandatory notice tells consumers that products sold in the EU carry legal guarantee protection of at least two years, although some Member States provide longer periods.

The GARAN label serves a different purpose. Producers can use it when they voluntarily offer, at no additional cost, a commercial durability guarantee lasting more than two years and covering the entire product rather than only individual components. The Commission adopted the implementing regulation establishing the notice and label in September 2025.

There is, inevitably, stock already sitting on shelves with packaging designed before the new requirements began to apply. National authorities in the EU Consumer Protection Cooperation Network have developed a common approach to those cases. The Commission says the arrangement is intended to support coherent enforcement where products or packaging carrying environmental claims or sustainability labels were already manufactured, ordered, distributed or placed on shelves before September 27.

It is not a license to wait out the inventory. Authorities expect traders to have acted in good faith and taken timely steps toward compliance. But they can consider the realities of packaging cycles, stock volumes, supply-chain dependencies and the feasibility of correcting old material. Where the circumstances justify it, regulators may favor guidance and corrective action before sanctions rather than require the destruction or recall of stock where doing so would impose disproportionate costs or itself create unnecessary environmental harm.

That transition period will eventually pass, but the language on the package will remain. For companies selling into the EU, the compliance problem now begins much earlier than the moment somebody approves a green logo or signs off on an advertising campaign. Someone has to establish what the environmental claim actually covers, what evidence supports it, whether the evidence matches the impression the consumer will receive and whether a label has a legitimate scheme standing behind it.

There was always risk in saying more about a product than the evidence could bear. Since September 27, EU consumer law has become much more specific about where that line is drawn.

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