Stricter scrutiny of environmental claims
For years, brands have used terms such as “green”, “eco-friendly” and “sustainable” with limited scrutiny. That is changing.
From 27 September 2026, Directive (EU) 2024/825 on empowering consumers for the green transition, commonly referred to as EmpCo, introduces stricter requirements for environmental claims made to consumers.
Organisations will need to communicate clearly and accurately and be able to substantiate the claims they make. The rules apply from that date, including to packaging and campaigns already in use.
Who is affected?
The new rules are relevant to any organisation whose products or services reach consumers in the EU, including B2B2C businesses selling through distributors, retailers or partners.
What changes in practice?
Terms such as “green”, “eco-friendly” and “sustainable” cannot be used without the required substantiation or a clear and prominent specification on the same medium.
The information supporting the claim must be relevant to what is being communicated. A claim about one part of a product should not create the impression that the entire product has the same environmental performance.
Sustainability labels must either be established by a public authority or based on a qualifying certification scheme.
Self-created labels may therefore need to be removed or replaced. Visual elements such as icons, colours and symbols should also be assessed when they could be interpreted as an environmental claim or sustainability label.
Product-level claims such as “carbon neutral” may be prohibited when they are based on greenhouse gas offsets outside the product’s value chain.
Organisations can still communicate about investments in environmental projects, provided that the information is accurate, transparent and not presented as an environmental benefit of the product itself.
Claims about future environmental performance require clear, objective and verifiable commitments.
These commitments must be supported by a detailed and realistic implementation plan, measurable targets and appropriate independent verification.
Why prepare early?
Environmental claims are rarely managed in one place. They may be spread across:
- Product packaging
- Websites and online shops
- Advertising campaigns
- Retail displays
- Product documentation
- Sales materials
- Partner and distributor communications
Reviewing claims, gathering evidence, adapting packaging and updating processes takes time.
The stakes are high. Non-compliance can lead to fines of up to 4% of annual turnover, litigation and reputational damage.
5 steps to green claims readiness
Create an inventory of the environmental claims, sustainability labels and relevant visual elements used across products and communication channels.
This provides a clear view of where claims appear and which teams are responsible for them.
Review existing claims to determine which are sufficiently specific and substantiated, which require additional evidence and which may need to be adapted or removed.
Claims can then be prioritised according to their legal, operational and reputational risk.
Identify the evidence required to support each claim.
Depending on the product and the nature of the claim, this may include:
- Product environmental footprint calculations
- Lifecycle data
- Documented methodologies
- Traceable sustainability metrics
- Independent validation
Define clear ownership, validation workflows and approval responsibilities.
Training helps marketing, sustainability, product and legal teams understand how the rules apply and what evidence is needed before a claim is published.
Environmental claims need to remain accurate as products, data and regulations evolve.
Regular reviews help organisations identify new risks, update evidence and maintain consistency across channels.
From compliance to credibility
The new rules do not prevent organisations from communicating about sustainability. They require organisations to communicate with greater precision and stronger evidence.
Brands that understand their claims and can substantiate them will be better placed to communicate with confidence. This supports compliance while helping customers distinguish credible environmental information from vague messaging.
What comes next
The application date of 27 September 2026 is approaching, but many organisations have an earlier practical deadline.
Reviewing product portfolios, gathering evidence, adapting artwork and introducing governance can take several months.
Preparing now gives your organisation time to identify its exposure, prioritise the most urgent changes and build a more reliable approach to environmental communication.
Assess your green claims
Not sure which claims would stand up to scrutiny?
A compliance scan provides a practical assessment of your environmental claims, labels and visual elements. It helps you understand where you stand, which gaps require attention and what to prioritise before the new rules apply.
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