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EU green claims rules: questions people actually ask

Straight answers on Directive (EU) 2024/825. Where something is a legal determination rather than a fact, we say so instead of guessing.

Last reviewed 2026-09-04 · ClaimProof, Harmony Future Holdings Limited, Dublin

Is “carbon neutral” banned outright?

If the neutrality rests on offsetting, yes — prohibited in all circumstances under Annex I point 4c, and no wording cures it. “Carbon neutral” also appears on the generic-terms list, so it carries the point 4a risk as well. If you have genuinely reduced emissions in your own operations, say that instead, with the baseline and the percentage named.

Can we keep saying “eco-friendly” if it is true?

Only if you can demonstrate recognised excellent environmental performance relevant to the claim. That is a high bar and it is on you to meet it. In practice the safer move is to replace the adjective with the fact it was standing in for: the material, the percentage, the certificate number.

Does this apply to business-to-business marketing?

The UCPD is consumer-protection law, so the blacklist entries bite on business-to-consumer commercial practices. B2B claims are governed by different rules — including misleading-advertising law and your own contracts — and a claim that reaches consumers through a reseller or a public website may well be in scope anyway. Whether a specific claim of yours is caught is a legal determination; we flag it rather than answer it.

What about packaging that is already printed?

The obligation attaches to the commercial practice, not to the print run, so existing stock is a real exposure rather than a grace period. This is one of the eight documented ways evidence files fail: claims live on packaging printed 18 months ago that nobody has re-reviewed. Inventory it now — the lead time on a reprint is the thing that hurts.

Is a self-designed eco label really banned?

Yes. Displaying a sustainability label not based on a certification scheme, or not established by public authorities, is prohibited in all circumstances (Annex I point 2a). The quality of the underlying work does not matter — what is missing is the scheme.

Can we still say “net zero by 2040”?

It is not on the blacklist, so it is assessed case by case rather than prohibited outright. It survives only with a detailed, realistic, publicly available implementation plan carrying measurable, time-bound targets, regularly verified by an independent third-party expert whose findings consumers can actually reach. Without that, treat it as high risk.

Our claim is true and we have the evidence. Are we fine?

Not automatically. The four Annex I entries are prohibitions on claim shapes — they apply in all circumstances, with no balancing test and no defence that the claim was accurate. A true statement in a banned shape is still a banned practice. Evidence is what you need after the shape is clear.

When exactly does it start?

Member states had to transpose by 27 March 2026 and must apply the measures from 27 September 2026. National transposition can vary in detail, so check your own member state’s implementing law.

What are the penalties?

Set by member-state transposition of the UCPD regime. For widespread infringements the UCPD ceiling is at least 4% of annual turnover in the member states concerned (Art. 13, as amended by 2019/2161). Which band applies to a specific claim is a legal determination and we do not assert it.

Does the free checker keep the claims I paste in?

No. The page has no analytics, sets no cookies and makes no network requests once loaded. The scan is JavaScript running on your device. You can disconnect from the network and it still works — which matters, because unreleased marketing copy is exactly the kind of thing you should not be pasting into someone else’s server.

Is the free checker the same as the paid dossier?

The classifier is the same logic. What the free checker cannot do is take your whole claim set at once, produce the dated evidence register, rank the remediation work, or give you the rewrite guidance tailored to each claim. That is what the €490 dossier is.

Is any of this legal advice?

No. This site is internal review documentation. It is not legal advice, it is not a clearance of any claim, and it does not guarantee compliance with Directive (EU) 2024/825 or its national transposition. The wording that finally ships is your own responsibility — have anything marked banned or high risk reviewed by a qualified lawyer first.

Every claim you make, classified and rewritten

The free checker handles one claim at a time. The dossier takes your whole claim set, classifies each one, supplies a defensible rewrite, and gives you the dated evidence register that shifts the burden of proof back off you.

Get the dossier — €490