Key points

• Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive, amends the Unfair Commercial Practices Directive and the Consumer Rights Directive. Member states were required to transpose it by March 2026, and its rules apply from 27 September 2026.
• The directive bans generic environmental claims such as eco-friendly or green unless the trader can demonstrate recognized excellent environmental performance.
• Claims that a product has a neutral, reduced or positive climate impact because the producer offsets emissions are prohibited.
• Sustainability labels must be based on a certification scheme or established by public authorities, and aggregate scores that blend different impacts are restricted.
• The separate Green Claims Directive, which would add pre-approval style substantiation rules, has stalled, so the existing consumer law framework is the one retailers must work to now.

What the directive does

The directive does not create a new regulator or a new substantiation regime. It adds specific items to the list of misleading commercial practices and to the information that must be provided at the point of sale, which gives enforcers clear, rule-based grounds to act. Because it operates through national transposition laws, the detail varies by member state, and retailers selling across the European Union need a country-by-country view.

The practical effect is that several claims common on packaging, product pages and advertising become hard to defend. Enforcement is through national consumer authorities and courts, and the directive's penalties follow the Omnibus approach, which allows fines linked to turnover for widespread infringements.

Generic claims

Terms such as environmentally friendly, eco, green, nature's friend, climate friendly and biodegradable are treated as generic environmental claims when the trader cannot show recognized excellent environmental performance. The recitals point to recognized schemes such as the EU Ecolabel. If a claim is not specific, it can be saved only by a clear statement, on the same medium and close to the claim, of what the specific performance is. A tagline on the front of a pack with an explanation on a website is unlikely to be enough.

Retailers should review private label ranges first, because they control both the product and the wording, and then supplier-provided claims, where the retailer is still the party presenting the claim to consumers.

Offsetting and climate neutrality

The directive prohibits claims, based on greenhouse gas emissions offsetting, that a product has a neutral, reduced or positive impact on emissions. This is aimed at statements such as carbon neutral delivery or climate positive. Traders can still talk about the facts of an offsetting program and about reductions in their own value chain, but they cannot make the product-level claim. Claims about the company's corporate climate commitments are governed by a different provision on future environmental performance, which requires a detailed, realistic implementation plan with measurable targets and independent expert verification.

Companies that built marketing around offset-based claims should plan the transition now. Withdrawing a claim from packaging takes time, and the end of a sell-off period is rarely generous.

Sustainability labels and scores

Sustainability labels that are not based on a certification scheme or established by a public authority are banned. A retailer's own badge, for example a leaf icon on products that meet an internal standard, is at risk unless it is built on an independent certification scheme meeting the directive's conditions. Certification schemes must be open to all traders on transparent, objective terms, and must include independent third-party monitoring. The directive also targets claims about the entire product when the claim relates only to one aspect, and statements that a product has a particular impact when that is not accurate.

Teams should list every logo, icon and score used in the stores and online, identify who created it and what verifies it, and decide whether it can be retained, rebuilt on a recognized scheme or dropped.

How to prepare

Start with an inventory of environmental claims across owned channels, packaging, marketing, supplier portals and customer service scripts. Then rank by risk: generic claims and offsetting claims first, labels second, forward-looking commitments third.

Establish an approval process. Marketing teams need a short form that asks what the claim says, what supports it, whether it is specific, and whether the scope matches the product. Records matter because the burden of showing substantiation will fall on the trader in an enforcement action.

Check supplier contracts for warranties on claims, cooperation on evidence and the right to withdraw claims at short notice. Update training for category managers and agencies. And track the transposition laws in the markets that matter most, since national authorities will interpret the directive first in their own guidance.

Corvane Ryle's Consumer Protection team and our Brussels office advise retailers and consumer brands on green claims across the European Union and the United Kingdom, where a separate regime under the Digital Markets, Competition and Consumers Act applies.