The European Union has reached an important milestone in its effort to regulate environmental marketing claims. As of September 27, 2026, EU Member States are required to apply the national rules implementing Directive (EU) 2024/825 on Empowering Consumers for the Green Transition, introducing significantly stricter requirements around environmental claims, sustainability labels and other consumer-facing sustainability communications.

For companies selling products or services to consumers in the European Union, sustainability language can increasingly create consumer-protection compliance risk. Terms such as “green,” “eco-friendly” and “climate friendly,” as well as certain carbon-neutrality claims and sustainability labels, now face substantially tighter restrictions.

The rules primarily apply to business-to-consumer commercial practices, meaning companies should focus particularly on sustainability statements used in advertising, product marketing, websites, packaging and other communications intended to influence consumer purchasing decisions.

What Changed on September 27?

Directive (EU) 2024/825 was adopted in 2024 and amended two major pieces of EU consumer legislation: the Unfair Commercial Practices Directive and the Consumer Rights Directive. The Directive entered into force in March 2024. EU Member States were required to transpose it into national law by March 27, 2026, with those national measures applying from September 27, 2026.

The objective is to provide consumers with more reliable information about the environmental characteristics, durability and reparability of products and services while strengthening protections against greenwashing and misleading sustainability communications.

For businesses, the practical impact is significant. Companies selling to EU consumers should now review environmental claims appearing across product packaging, advertisements, websites, digital platforms and other customer-facing communications.

Generic Environmental Claims Face Much Greater Scrutiny

One of the most significant changes concerns broad environmental terminology. The Directive prohibits companies from making certain generic environmental claims where they cannot demonstrate recognised excellent environmental performance relevant to that claim.

Examples expressly identified in the Directive include terms such as:

• “Environmentally friendly”

• “Eco-friendly”

• “Green”

• “Climate friendly”

• “Carbon friendly”

• “Energy efficient”

• “Biodegradable”

• “Biobased”

Broader terminology such as “sustainable” or “responsible” may also create compliance concerns and cannot necessarily be justified solely by evidence of strong environmental performance. The rules do not prohibit all environmental communications. Instead, they push companies toward claims that are more specific, substantiated and appropriately qualified.

The Directive also prohibits presenting an environmental benefit relating to only one aspect of a product or business in a way that creates the impression that the entire product or business has that environmental characteristic. For ESG, legal and marketing teams, this means broad claims about a product being “green” or an organization being “environmentally friendly” require substantially closer scrutiny.

Carbon-Neutral Claims Based on Offsets Are Particularly Exposed

The rules also directly target certain climate claims based on carbon offsets. The Directive prohibits claims that a product, including a good or service, has a neutral, reduced or positive impact on greenhouse gas emissions where that conclusion is based on greenhouse gas offsetting.

The legislation specifically addresses claims such as “climate neutral,” “CO2 neutral,” “carbon positive,” “climate net zero” and “climate compensated” when they rely on offsetting to characterize the greenhouse gas impact of a product.

This distinction matters. The rules do not prohibit companies from communicating investments in carbon-credit projects or broader environmental initiatives. However, businesses cannot use offsets outside the product's value chain as the basis for presenting the product itself as having a neutral or reduced greenhouse gas impact.

Companies using offsets to support consumer-facing claims about particular products or services should therefore treat this as a priority review area. Company-level climate claims may also be regulated under the broader rules against misleading commercial practices, even though they are not automatically covered by this specific product-level prohibition.

Future Climate Commitments Need Stronger Substantiation

Forward-looking environmental claims are another important area of focus. Under the amended consumer-protection rules, claims relating to future environmental performance can be considered misleading on a case-by-case basis where they are not supported by clear, objective, publicly available and verifiable commitments.

The underlying commitments should be contained in a detailed and realistic implementation plan that includes measurable and time-bound targets and identifies the actions and resources necessary to achieve them where appropriate.

Progress toward those commitments must also be regularly verified by an independent third-party expert, with the findings made available to consumers. This could affect the way companies communicate objectives such as:

• Achieving net-zero emissions

• Transitioning to renewable energy

• Reducing product carbon footprints

• Improving environmental performance by a future date

Companies making these claims should ensure that public commitments align with the strategies, milestones, resources and evidence supporting them.

Sustainability Labels Are Also in Scope

The rules extend beyond written marketing claims. The Directive prohibits displaying a sustainability label that is not based on a certification scheme or established by a public authority. This can affect environmental badges, sustainability seals, icons, certifications and other visual signals that communicate environmental or social performance to consumers.

Companies using internally developed or proprietary sustainability labels should therefore review whether those labels meet the requirements of the Directive. This may be particularly relevant for multinational companies that have historically developed brand-specific environmental labels without using an independent certification framework.

Not Every Sustainability Disclosure Is Covered

One important distinction for ESG teams is that these rules are primarily focused on consumer-facing commercial practices, rather than corporate sustainability reporting generally. Mandatory corporate sustainability disclosures, including reporting prepared under frameworks such as the Corporate Sustainability Reporting Directive (CSRD), will typically sit outside this specific consumer-protection framework when they are directed principally toward investors or other corporate stakeholders.

However, that distinction can change when sustainability information is reused in marketing. For example, if a company takes an environmental claim from its sustainability report and uses it voluntarily in an advertisement, product page, promotional campaign or other consumer-facing communication, that use may fall within the anti-greenwashing rules. This makes coordination between ESG, sustainability, legal and marketing teams increasingly important.

Old Stock Is Not Automatically Exempt

Companies should also pay attention to products and packaging that were already in circulation before September 27. The European Commission has clarified that the new requirements can also apply to existing products and old stock from the application date.

There is no general grandfathering exemption simply because packaging or marketing materials were produced before September 27, 2026. However, EU consumer-protection authorities have indicated that enforcement can take a proportionate approach. Factors such as existing inventory, packaging cycles, supply-chain constraints and good-faith efforts to achieve compliance may be considered.

Companies may therefore need to consider measures such as relabeling, stickers, supplemental point-of-sale information or updated digital disclosures where existing packaging contains claims that no longer comply.

What Companies Should Do Now

With the September 27 application date now passed, companies selling products or services to EU consumers should move from preparation to active compliance. A practical first step is to conduct an inventory of environmental and sustainability claims across consumer-facing communications.

Companies should pay particular attention to:

• Broad terms such as “green,” “eco-friendly” or similar generic environmental language

• Carbon-neutral or climate-neutral claims involving offsets

• Claims that extend a limited environmental benefit to an entire product or organization

• Net-zero and other forward-looking environmental commitments

• Proprietary sustainability labels or badges

• Environmental statements that lack clear supporting evidence

• Existing packaging and old stock containing environmental claims

The review should extend beyond formal ESG reporting. Websites, product descriptions, advertisements, packaging, social media, marketing campaigns and other consumer-facing communications may all create exposure under the new framework.

For many organizations, environmental marketing can no longer be handled solely as a branding decision. ESG, sustainability, legal, compliance and marketing teams will increasingly need to coordinate on how environmental information is communicated externally.

Do Not Confuse These Rules With the Green Claims Directive

Directive (EU) 2024/825 is separate from the EU's proposed Green Claims Directive. The Empowering Consumers for the Green Transition Directive has been adopted, transposed into national law and its implementing measures now apply.

The separate Green Claims Directive was intended to establish additional rules governing the substantiation and communication of explicit environmental claims.

As of September 2026, however, that proposal remains formally pending, while its legislative future is uncertain. The European Commission announced in June 2025 that it intended to withdraw the proposal, and the planned third trilogue between EU institutions was subsequently cancelled.

Companies should therefore distinguish between the two initiatives. The Empowering Consumers for the Green Transition rules are now an active compliance requirement. The Green Claims Directive remains a separate legislative proposal whose future remains unresolved.

The Bigger Picture

The September 27 deadline marks an important shift in European greenwashing regulation. Environmental marketing claims are increasingly becoming regulated compliance issues rather than simply matters of brand positioning.

For businesses operating in the EU consumer market, the core question is becoming increasingly straightforward: Can the company demonstrate what it is claiming? Organizations should be able to connect public sustainability statements to specific, defensible evidence and avoid claims that exaggerate or oversimplify environmental performance.

For ESG teams, the immediate priority should be ensuring that what a company says externally about sustainability is consistent with what it can substantiate internally. As regulators continue to scrutinize environmental marketing, companies with clear processes for reviewing, documenting and approving sustainability communications will be better positioned to manage the EU's evolving anti-greenwashing framework.