EU green claims: what is banned from 27 September 2026
Directive (EU) 2024/825 adds six new entries to the EU’s unfair-practices blacklist. Four of them ban claim shapes outright — no wording will save them. This page sets out all six, with a worked rewrite for each.
Last reviewed 2026-09-04 · ClaimProof, Harmony Future Holdings Limited, Dublin
What this page is
A plain-English reading of the green-claims changes in Directive (EU) 2024/825, the ‘Empowering Consumers for the Green Transition’ directive. It is free, and it is the same corpus our paid dossier is built from. It is not legal advice and not a clearance of any claim. Have anything marked banned or high risk reviewed by a qualified lawyer before you use it.
The date, and what actually changes
Member states had to transpose the directive by 27 March 2026 and must apply the measures from 27 September 2026. It amends the Unfair Commercial Practices Directive 2005/29/EC by inserting new entries into Annex I, and the Consumer Rights Directive 2011/83/EU.
Annex I is the part that matters
Annex I of the UCPD is the blacklist: practices prohibited in all circumstances. There is no balancing test, no ‘average consumer’ assessment and no defence that nobody was actually misled. Four of the six new rules land there. If your claim matches one of those shapes, the claim is the problem — not the way it is phrased.
The six shapes
| Shape | Example | Basis | Status |
|---|---|---|---|
| Generic environmental claim | “Eco-friendly”, “green”, “sustainable”, “natural” with nothing behind it | Annex I point 4a | Banned outright |
| Offsetting-based neutrality | “Carbon neutral” achieved by buying offsets | Annex I point 4c | Banned outright — wording cannot cure it |
| Whole product for a single aspect | “A sustainable kettle” when only the housing is recycled | Annex I point 4b | Banned outright |
| Uncertified sustainability label | A mark you designed in-house | Annex I point 2a | Banned outright |
| Legal requirement as a feature | “Now free from banned substances” | Annex I point 10a | High risk — assessed case by case |
| Unverified future pledge | “Net zero by 2040” with no published, verified plan | Art. 6(2)(d) | High risk — assessed case by case |
1. Generic environmental claims
Making a generic environmental claim for which the trader is not able to demonstrate recognised excellent environmental performance relevant to the claim is prohibited in all circumstances (UCPD Annex I point 4a).
The directive’s own recital gives the exemplar list. If one of these words is doing the work in your copy, and you cannot demonstrate recognised excellent environmental performance, the claim is on the blacklist:
The generic terms
environmentally friendly · environmentally correct · eco-friendly · eco · green · nature’s friend · natural · ecological · energy efficient · biodegradable · climate friendly · gentle on the environment · carbon friendly · climate neutral · carbon neutral · CO2 neutral · sustainable
The free checker on this site scans your wording against exactly this list.
2. Neutrality based on offsetting
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 greenhouse gas emissions is prohibited in all circumstances (Annex I point 4c).
This one cannot be reworded
Every other item on this page has a rewrite. This one does not. ‘Carbon neutral via offsets’ is banned as a claim shape, so softening the language, adding an asterisk or moving it to the small print does not help. The only fix is to stop making a neutrality claim and talk instead about reductions you actually achieved, with the baseline named.
3. Whole-product claims for a single aspect
Making an environmental claim about the entire product or the trader’s entire business when it actually concerns only a certain aspect of the product or a specific activity of the business is prohibited in all circumstances (Annex I point 4b).
This is the one that catches careful companies. The recycled housing is real, the certificate is real, and the claim still fails, because it was written about the kettle rather than about the housing.
4. Sustainability labels without a scheme behind them
Displaying a sustainability label that is not based on a certification scheme or not established by public authorities is prohibited in all circumstances (Annex I point 2a). A mark you designed in-house is prohibited however good the underlying work is.
5. Legal requirements presented as a distinctive feature
Presenting requirements imposed by law on all products in the product category as a distinctive feature of the trader’s offer is prohibited (Annex I point 10a). Meeting the law is not a selling point. If you genuinely exceed the requirement, the margin is the claimable part.
6. Future environmental performance claims
A claim about future environmental performance — ‘net zero by 2040’ — without clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan, with measurable and time-bound targets regularly verified by an independent third-party expert whose findings are made available to consumers, is a misleading commercial practice (UCPD Art. 6(2)(d)).
Not a blacklist entry
This one sits in Article 6, not Annex I, so it is assessed case by case rather than prohibited outright. We classify it as high risk rather than banned. We had this wrong in an earlier version of our own corpus and corrected it on an adversarial re-check — the distinction matters, because a per-se ban and a case-by-case assessment call for different responses.
Six worked rewrites
Telling a marketing owner their wording is banned is half the job. These show the move from a prohibited shape to a defensible one.
Generic environmental claim
Before: “Eco-friendly packaging”
After: “Carton made from 90% recycled fibre, FSC Recycled certified (licence FSC-C000000)”
The generic adjective is replaced by the measurable fact it was standing in for, plus the scheme that verifies it. The claim is now checkable, which is exactly what makes it survivable.
Offsetting-based neutrality
Before: “Carbon neutral delivery”
After: “We cut delivery emissions 28% per parcel against our 2023 baseline by moving to electric vans; the remaining emissions are not offset”
No rewrite makes an offsetting-based neutrality claim lawful, so the neutrality framing is dropped entirely. What remains is a measured reduction in your own operations, with the baseline named.
Whole product for a single aspect
Before: “A sustainable kettle”
After: “This kettle’s housing is 65% post-consumer recycled plastic”
The wording is narrowed to exactly the aspect the improvement covers. Never let the product claim what only the housing achieves.
Future performance pledge
Before: “Net zero by 2040”
After: “Net zero by 2040: our plan, interim 2030 target and the independent verifier’s latest findings are at [your-site]/climate-plan”
The pledge survives only with a detailed, realistic, publicly available plan carrying time-bound targets and independent verification the consumer can actually reach.
Legal requirement as a feature
Before: “Now free from banned substances”
After: “Independently tested to [STANDARD]: substance X at 0.001%, ten times below the legal limit”
Meeting the law is not a distinguishing feature. If you genuinely exceed the requirement, the margin is the claimable part — not the baseline everyone must meet.
In-house sustainability label
Before: “Our Green Leaf mark”
After: “Certified to [SCHEME NAME] by [CERTIFYING BODY], certificate [NUMBER], valid to [DATE]”
A label needs a certification scheme or a public authority behind it. A mark you designed yourself is prohibited however good the underlying work is.
Claims that survive still need evidence
Any environmental claim that survives the blacklist must still be accurate, specific and substantiated with evidence available at the time the claim is made. Keep it in a dated register: in practice the burden of proof sits with the trader.
Comparative claims, where it most often goes wrong
- Name what you are comparing against. ‘Better for the environment’ with no comparator is not a comparison, it is a generic claim.
- Compare like with like: same product category, same function, same unit of measure.
- Use the same method for both sides, and say what the method was.
- If the comparator is a previous version of your own product, say so explicitly — consumers otherwise read it as a market comparison.
- Keep the comparison current: it decays as the market or your own range changes.
- State the aspect compared, not the whole product, unless the whole product genuinely was assessed.
The eight ways the evidence file fails
- Evidence dated after the claim was first published. The claim was unsubstantiated on the day it shipped, and the file proves it.
- A certificate covering one site or one product line, used to support a claim made across the whole range.
- A life-cycle assessment whose boundary excludes the stage the claim implies — ‘carbon neutral product’ on a cradle-to-gate study.
- Comparisons against an unnamed competitor, an obsolete version of your own product, or a different category.
- A generic adjective left in place because ‘everyone says it’. From 27 September 2026 that is exactly the wording enforcement targets.
- A sustainability label designed in-house, with no scheme and no public authority behind it.
- Claims live on packaging printed 18 months ago that nobody has re-reviewed against the current evidence.
- No named owner, so when the certificate lapses nobody withdraws the claim.
A brief you can hand your marketing team
- Never use a bare green adjective. If you cannot replace it with a number and a source, do not publish it.
- Never claim neutrality achieved by offsetting. The shape is banned outright, whatever the wording around it.
- Never let the product claim what only one component achieves.
- Never display a sustainability mark that has no certification scheme behind it.
- Never present a legal minimum as a distinguishing feature.
- Always file the evidence BEFORE the claim goes live, dated.
- Always name an owner who withdraws the claim if the evidence lapses.
- Always re-check printed material before a reprint — a claim on packaging outlives the person who approved it.
Six questions to ask in your own review
- Who signed off the current wording, and on what date?
- Produce the evidence for the highest-risk claim in under five minutes.
- Is that evidence dated before the claim was first published?
- Which claims appear on packaging that is already printed?
- Who withdraws a claim when its evidence lapses, and how would they know?
- Has anyone checked the claims on the website against the ones on the pack?
Penalties
Penalties are set by member-state transposition of the UCPD regime. For widespread infringements the UCPD ceiling is at least 4% of the trader’s annual turnover in the member states concerned (UCPD Art. 13, as amended by Directive (EU) 2019/2161). Which band applies to a specific claim is a legal determination and we do not assert it.
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