EU Greenwashing Rules 2026: What Businesses Need to Know Before 27 September

What changes on 27 September 2026? 

Directive (EU) 2024/825 on empowering consumers for the green transition entered into force in March 2024. EU Member States were required to transpose it into national law by 27 March 2026, and the relevant national measures must apply from 27 September 2026. 

The Directive strengthens the existing EU framework on unfair commercial practices by introducing more specific rules addressing misleading environmental claims, unreliable sustainability labels and certain claims about future environmental performance. 

According to the European Commission’s 2026 guidance, the requirements apply to business-to-consumer commercial practices. This includes communications directly connected with promoting, selling or supplying products and services to consumers. 

The rules can therefore affect: 

• product packaging and labels; 

• company and product websites; 

• online stores and marketplaces; 

• advertisements and promotional campaigns; 

• brochures and point-of-sale materials; 

• social media content; 

• product and brand names that communicate an environmental benefit; 

• sustainability information reused in consumer marketing. 

Corporate sustainability reports are not normally the primary target of these consumer protection rules. However, if information from a report is reused in advertising or other consumer-facing communications, that message may fall within their scope. 

Which environmental claims may create a risk? 

The new rules focus particularly on environmental messages that are broad, unclear or unsupported. 

Examples of generic claims include: 

• environmentally friendly; 

• eco-friendly; 

• green; 

• ecological; 

• climate friendly; 

• carbon friendly; 

• gentle on the environment; 

• biodegradable; 

• biobased. 

This does not mean that every use of these words is automatically prohibited. The wording, context, presentation and supporting evidence all matter. 

However, a generic environmental claim will be prohibited where the business cannot demonstrate recognised excellent environmental performance relevant to that claim. 

A broad statement such as “climate-friendly packaging” may therefore create a considerably greater risk than a specific statement explaining the measurable basis of the claimed benefit. 

For example: 

Too broad: 

“Environmentally friendly packaging.” 

More specific: 

“100% of the electricity used to manufacture this packaging comes from renewable sources.” 

A specific claim is not automatically compliant simply because it contains a number. It must still be accurate, relevant, up to date and supported by appropriate evidence. 

The overall impression also matters 

Environmental claims are not limited to words. 

The European Commission explains that colours, images, icons and the overall presentation of a product may also imply an environmental benefit. Leaves, trees, water droplets, natural landscapes, green colour schemes and similar design elements can contribute to the message perceived by an average consumer. 

Businesses should therefore assess the complete communication rather than reviewing the written claim in isolation. 

A technically correct sentence may still be misleading if its size, placement, imagery or surrounding wording gives consumers an exaggerated impression of the environmental benefit. 

New requirements for sustainability labels 

From 27 September 2026, sustainability labels used in consumer-facing communications will need to be established by a public authority or based on a certification scheme that meets the applicable requirements. 

Self-created green badges, leaves, trust marks and similar symbols may present a risk if consumers could interpret them as independent sustainability labels. 

The European Commission also states that existing sustainability labels must comply from the application date. The Directive does not provide a general additional transition period for labels already in use. 

Businesses should review: 

• environmental badges created internally; 

• supplier-provided labels; 

• certification marks; 

• labels displayed on packaging; 

• symbols used on websites and online stores; 

• labels originating outside the EU; 

• the rules and evidence behind each voluntary label. 

A recognisable or widely used logo should not automatically be assumed to meet the new requirements. The governance of the scheme, its criteria and the way compliance is assessed are important. 

Claims based on carbon offsetting 

The new rules also address climate claims based on greenhouse gas offsetting. 

Claims that a product has a neutral, reduced or positive environmental impact in terms of greenhouse gas emissions cannot be based solely on offsetting emissions outside the product’s value chain. 

This is especially relevant to expressions such as: 

• carbon neutral product; 

• climate neutral delivery; 

• CO₂-neutral packaging; 

• net-zero product. 

Businesses using these claims should determine what the statement refers to, which emissions are included and whether the claimed benefit results from actual reductions or from purchasing carbon credits. 

Information about financing climate projects may still be communicated where it is accurate and appropriately presented. The risk arises when offsetting is used to create the impression that the product itself has no, reduced or positive greenhouse gas impact. 

Claims about future environmental performance 

Statements about future goals may also be considered misleading if they are not supported by a credible implementation plan. 

A business communicating a future environmental target should be able to show: 

• a clear and objective commitment; 

• measurable and time-bound targets; 

• a realistic implementation plan; 

• resources allocated to achieving the target; 

• regular assessment by an independent third-party expert; 

• information that allows consumers to understand progress. 

General promises such as “we will become sustainable” or “we are on the way to net zero” may not be sufficient without a defined scope, baseline, timeframe and credible plan. 

Do the rules apply to existing products and packaging? 

Yes. According to the European Commission’s guidance, from 27 September 2026 businesses must ensure that relevant environmental claims and sustainability labels comply even when the products or packaging were manufactured, ordered, distributed or placed on shelves before that date. 

Where an existing claim creates a compliance concern, practical measures may include: 

• covering or correcting the claim with a sticker; 

• adding clear supplementary information; 

• updating the information at the point of sale; 

• changing the relevant online product description; 

• removing an unsupported label or claim. 

Businesses with substantial stocks of existing packaging should not assume that the rules apply only to newly produced materials. 

What about the proposed Green Claims Directive? 

The Empowering Consumers for the Green Transition Directive and the proposed Green Claims Directive are related, but they are not the same legislation. 

Directive (EU) 2024/825 has already been adopted and applies from 27 September 2026. 

The separate Green Claims Directive was proposed to introduce more detailed requirements for substantiating and communicating explicit environmental claims, including provisions relating to independent verification. As of September 2026, the European Commission still lists this proposal as pending on its official Green Claims page. 

Businesses should therefore avoid presenting the Green Claims Directive as adopted law or assigning it a final compliance deadline. Nevertheless, its policy direction reinforces an important principle: environmental claims should be reliable, comparable and verifiable. 

A practical preparation plan for businesses 

Companies can begin with the following steps. 

1. Create an inventory of environmental communications

Identify environmental statements, labels and symbols used across packaging, websites, advertisements, catalogues, online stores and social media. 

Include claims about both products and the business as a whole. 

2. Identify the intended audience

Determine whether each communication is directed at consumers, business customers, investors or another audience. 

A claim taken from a corporate report may enter the scope of consumer protection rules when it is reused in consumer advertising. 

3. Classify each claim

Separate: 

• generic environmental claims; 

• specific and measurable claims; 

• comparative claims; 

• climate and carbon claims; 

• future commitments; 

• sustainability labels; 

• claims required by law. 

This helps determine the type of evidence and review needed. 

4. Check the scope of every statement

Confirm whether the claim applies to: 

• the entire product; 

• one component; 

• the packaging; 

• one production site; 

• a specific process; 

• the whole company. 

A limited benefit should not be presented as if it applied to the entire product or business. 

5. Review the supporting evidence

Check whether the evidence is: 

• relevant to the exact claim; 

• based on an appropriate method; 

• current and complete; 

• traceable to reliable data; 

• applicable to the relevant product and market; 

• sufficiently clear to withstand independent review. 

6. Review sustainability labels

Determine who owns each label, what criteria it represents, how compliance is assessed and whether the scheme includes appropriate independent verification. 

7. Assign responsibility

Marketing, sustainability, product, quality and legal teams should not review environmental claims separately. 

Establish a clear approval process identifying who prepares the claim, who checks the evidence and who authorises publication. 

8. Keep records

Maintain the evidence, calculations, reports, certificates and approvals supporting each active environmental claim. 

Claims should also be reviewed when a product, supplier, material, process or calculation method changes.

How independent verification can help 

Independent verification can provide greater confidence in the data, methodologies and evidence behind an environmental statement. 

Depending on the claim, this may include assessment of: 

• organisational greenhouse gas emissions; 

• product carbon footprints; 

• life-cycle assessments; 

• environmental product declarations; 

• renewable or recycled content information; 

• sustainability data and reporting; 

• progress against defined environmental targets. 

Independent verification does not automatically make every marketing statement legally compliant, and there is no single certificate that approves all environmental claims. Legal responsibility for a claim remains with the business communicating it. 

However, appropriate independent assessment can help identify gaps, improve the reliability of supporting information and reduce the risk of communicating claims that cannot be adequately demonstrated. 

Not sure whether the evidence behind your environmental claims is sufficient? 

Contact BM Certification to discuss which independent verification or assessment approach may be appropriate for your data, product, claim or environmental objective.

Official sources 

• Directive (EU) 2024/825 – EUR-Lex 

• European Commission Q&A on empowering consumers for the green transition 

• European Commission: Green Claims