An environmental claim is not safer because it is vague. Under the new EU rules, vagueness is often the problem.
Consumer authorities from 27 countries assessed 344 online sustainability claims in the European Commission’s coordinated sweep. They found insufficient information to assess accuracy in 57.5 percent of cases and vague language in 37 percent. That was a screening exercise, not a court judgment on every claim, but it explains why the law now targets broad environmental language directly.
From 27 September 2026, national measures implementing Directive (EU) 2024/825 apply. The directive adds specific practices to the EU blacklist of commercial practices considered unfair in all circumstances. It changes what can be said on packaging, product pages, ads and brand communications aimed at consumers.
This is not a reason to say nothing. It is a reason to make narrower claims and keep evidence that matches every word.
“Green” is a conclusion, not evidence
The directive identifies generic environmental claims such as “environmentally friendly,” “eco-friendly,” “green,” “climate friendly,” “biodegradable” and “energy efficient.” A generic claim cannot be made without recognised excellent environmental performance relevant to that claim.
That qualification matters. A recognised performance for one property does not justify a conclusion about the whole product.
A lower-impact package does not make the product sustainable. Renewable electricity at one facility does not prove a climate-friendly business. Recycled fibres do not establish lower impact across manufacture, dyeing, transport, use and disposal.
The legal text gives a useful contrast. “Climate-friendly packaging” is generic. “100% of energy used to produce this packaging comes from renewable sources” is specific. The second is not automatically lawful. It still has to be accurate and supportable. It is simply a claim that can be tested.
A defensible environmental claim tells the reader what changed, where it changed and what evidence proves it.
The whole-product shortcut is prohibited
The directive also blacklists an environmental claim about an entire product or business when it concerns only one aspect or an unrepresentative activity.
This is the common packaging mistake. A recycled mailer receives a large green badge while the product, production and delivery footprint remain outside the statement. The visual hierarchy turns a packaging fact into a product conclusion.
Fix it by naming the boundary. “Mailer contains 80% post-consumer recycled plastic by weight.” “Outer box is recyclable in paper streams where local facilities accept coated board.” “This colourway uses fabric containing 60% recycled polyester.”
Each number still needs evidence. Each disposal instruction must reflect the actual material and infrastructure. The point is that the sentence stops exactly where the evidence stops.
Do not let icons, leaves, earth imagery or a green palette imply a broader claim than the copy states. The directive’s definition covers text, graphics and symbolic representation. Design is part of the claim, which is why it belongs inside the design system rather than in a late legal review.
Offsetting cannot make a product climate neutral
The directive prohibits claims based on greenhouse-gas offsetting that a product has a neutral, reduced or positive environmental impact in terms of emissions.
It lists examples including “climate neutral,” “CO2 neutral certified,” “carbon positive,” “climate net zero,” “climate compensated” and “reduced climate impact” where the proposition rests on offsets outside the product value chain.
You may communicate investment in environmental initiatives if the communication is accurate and not misleading. That is different from converting an offset purchase into a property of the product.
Separate the statements: the measured emissions associated with the product, the boundary and method used, reductions made inside the value chain, and any separate contribution to an external project. Do not subtract the fourth from the first and turn the answer into a badge.
Your own sustainability label needs an external basis
The new rules prohibit displaying a sustainability label that is not based on a certification scheme or established by public authorities.
An internal leaf icon with “responsible choice” underneath can function as a sustainability label even if the team calls it a navigation device. A collection name can do the same work. The test is the impression created for the consumer.
Before using a label, record who owns the scheme, who sets the requirements, whether requirements are public, who verifies compliance, how independence is protected, what the label covers, and how complaints are handled.
The EU Ecolabel framework is one example of a public scheme with product-group criteria. Its existence does not mean every product qualifies, or that another certification can borrow its authority.
Future promises need a real operating plan
Claims about future environmental performance need clear, objective, public and verifiable commitments set out in a detailed and realistic implementation plan. The directive also requires regular verification by an independent third-party expert whose findings are made available to consumers.
“Net zero by 2030” is therefore not merely a line of optimistic copy. It implies a baseline, defined scope, intermediate targets, resourcing, accountable owners and evidence of progress.
Before publishing a future claim, answer: what is the baseline year, which emissions are included, what actions produce the reduction, what milestones occur before the final date, who verifies progress, where can the public read the plan, and what happens if the plan changes.
If those answers do not exist, remove the promise.
Durability language also needs a defined comparison
“Made to last” sounds harmless. It is still a factual proposition about expected performance.
State the test instead: abrasion cycles achieved under a named method, wash conditions used, repair service period, spare-part availability, warranty duration and exclusions, comparison product and basis.
The Unfair Commercial Practices Directive already prohibited misleading actions and omissions before the 2024 amendment. The new directive adds more explicit blacklisted practices. It does not replace the need to assess the overall impression.
The separate Green Claims proposal is not enacted law
Do not merge two EU files.
Directive 2024/825 is adopted. Member States had to transpose it by 27 March 2026 and must apply the measures from 27 September 2026.
The separate proposed Green Claims Directive, procedure 2023/0085/COD, would add more detailed substantiation and verification rules for explicit environmental claims. It is not enacted. The European Parliament’s legislative tracker records that the Commission announced an intention to withdraw it in June 2025, the third trilogue was cancelled, and the proposal remained pending with negotiations at a standstill.
Build for the law that exists. Monitor the proposal, but do not present its draft mechanisms as current obligations.
Build a claim file before the product page
For every environmental statement, create a short claim record.
| Field | Required answer |
|---|---|
| Exact claim | The words and visual context |
| Subject | Product, component, packaging or business |
| Market | Where the claim appears |
| Evidence | Certificate, test, invoice, calculation or dataset |
| Boundary | Included and excluded stages |
| Date | Evidence period and review date |
| Owner | Person responsible for keeping it current |
| Qualification | Text that must appear with the claim |
Then read the ad, product page and package together. A careful footnote cannot repair a headline whose first impression is broader.
Consumer law is applied through national authorities and courts. Obtain qualified advice for the markets in which you sell.
How we handle this
Merch begins with the product, material, supplier and evidence boundary before environmental language enters the product page. We turn supplier statements into a claim register and reject conclusions the documents do not support.
Origin makes the hierarchy honest, so a material fact stays a material fact instead of becoming an identity halo. Scale keeps ad copy within the same boundary, because a compliant product page does not rescue an overbroad campaign claim.
If your evidence is incomplete, send us the exact proposed wording, target markets, supplier documents and certifications. The useful review happens before packaging is printed.
Sources
EUR-Lex, Directive (EU) 2024/825.
European Commission, sustainable consumption and implementation material.
European Commission, coordinated consumer-protection sweeps.
EUR-Lex, Unfair Commercial Practices Directive, consolidated.
EUR-Lex, Green Claims proposal 2023/0085/COD.
European Commission, EU Ecolabel.
Sources and legal status checked 30 July 2026. National implementation and product-specific advice must be checked before use.
