Open the artwork file a factory in Asia sends you for a new product and there is a good chance it already contains a green leaf, the word "Eco" or a line like "100% natural, environmentally friendly". Nobody asked for it. It is simply what the factory's designer puts on everything, because until now nobody in Europe pushed back.
From 27 September 2026 that changes. Directive (EU) 2024/825 adds a set of environmental claims to the EU blacklist of commercial practices that are unfair in all circumstances. A generic claim such as "eco-friendly", "green", "sustainable" or "biodegradable" is then prohibited unless you can show recognised excellent environmental performance behind it. A self-made sustainability badge is prohibited. "Climate neutral" based on offsetting is prohibited. And a claim about the whole product is prohibited when only the packaging is recycled (source: Directive (EU) 2024/825, Annex I points 2a, 4a, 4b and 4c).
This article explains what the law says, which words and images fall under it, where these claims come from when you import from Asia, what to do with stock that is already printed, and how to rewrite a listing so it survives an inspection. It is written for importers and online sellers of non-food consumer products, not for corporate sustainability teams.
1. The short answer
From 27 September 2026, every environmental claim you make on a product, its packaging, your listing or your website falls into one of three groups.
Specific and proven: allowed. "Bottle made from 85% recycled PET, certificate available on request" is a specific claim about one aspect, with the specification on the same medium. You need to be able to back it up, but it is not banned.
Generic and unproven: banned. "Eco-friendly water bottle" is a generic claim. It is only allowed if the product carries the EU Ecolabel, a nationally recognised EN ISO 14024 type I ecolabel, or has top environmental performance under other EU law. For a normal consumer product from Asia, that is almost never the case.
Structurally banned: three practices are prohibited regardless of evidence. A sustainability label without a third-party certification scheme or a public authority behind it. A "carbon neutral" or "climate positive" claim based on offsetting. A claim about the whole product or the whole business when it only applies to one part.
The practical consequence for most sellers is not that you have to stop talking about environmental features. It is that every generic word has to be replaced by a specific, measurable statement, and that statement needs a document behind it.
2. What the law actually says
Directive (EU) 2024/825, usually called the Empowering Consumers for the Green Transition Directive (ECGT or EmpCo), does not create a new standalone regime. It amends two existing consumer laws: the Unfair Commercial Practices Directive 2005/29/EC and the Consumer Rights Directive 2011/83/EU. Member states had to adopt it into national law by 27 March 2026 and must apply it from 27 September 2026 (source: Directive (EU) 2024/825, Article 4).
That matters for enforcement. The Unfair Commercial Practices Directive has an Annex I, often called the blacklist. Practices on that list are unfair in all circumstances. An authority does not have to prove that a consumer was actually misled; the practice itself is enough. The new directive adds twelve points to that list. Four of them are about environmental claims and one about presenting legal requirements as a selling point.
The four bans that matter for product sellers
Point 2a: "Displaying a sustainability label that is not based on a certification scheme or not established by public authorities." A certification scheme in this definition needs third-party verification, transparent conditions for joining, and independent monitoring. Your own "Green Choice" badge on a listing, or a leaf icon with the word "Certified" that nobody certified, is out.
Point 4a: "Making a generic environmental claim for which the trader is not able to demonstrate recognised excellent environmental performance relevant to the claim." This is the one that hits "eco-friendly", "green", "sustainable" and similar words.
Point 4b: "Making an environmental claim about the entire product or the trader's entire business when it concerns only a certain aspect of the product or a specific activity of the trader's business." The directive gives the example itself: a product marketed as "made with recycled material" when only the packaging is recycled (source: Directive (EU) 2024/825, recital 11).
Point 4c: "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." "Carbon neutral shipping" paid for with credits from a forest project on another continent is exactly this. You may still say that you invest in such projects, as long as you do not call the product neutral because of it.
The fifth one people overlook
Point 10a: "Presenting requirements imposed by law on all products within the relevant product category on the Union market as a distinctive feature of the trader's offer." Bisphenol A has been banned in baby bottles across the EU since 2011. A listing that sells a baby bottle as "BPA-free, safe for your child" as if that were a choice the brand made is, in our reading, presenting a legal minimum as a selling point. The same logic applies to "CE certified" as a bullet point on a toy: the CE marking is mandatory, so it is not a feature.
What counts as a claim
The definition is wider than most sellers expect. An environmental claim is "any message or representation which is not mandatory under Union or national law, in any form, including text, pictorial, graphic or symbolic representation, such as labels, brand names, company names or product names" that states or implies a product has a positive or zero impact on the environment, is less damaging than others, or has improved over time (source: Directive (EU) 2024/825, Article 1, new Article 2 point (o) of Directive 2005/29/EC).
So a leaf icon is a claim. A brown kraft-look box with a green band is, in combination with wording, a claim. A product name like "EcoBrush" or "NatureClean" is a claim. The European Commission's FAQ on the directive, updated on 18 May 2026, sharpened exactly these points: brand and product names, and visual elements, count (source: European Commission, FAQ on Directive (EU) 2024/825, May 2026 update).
3. Generic versus specific: the test on the same medium
The line between banned and allowed runs through one definition. A generic environmental claim is one "where the specification of the claim is not provided in clear and prominent terms on the same medium" (source: Directive (EU) 2024/825, new Article 2 point (p)).
"Same medium" is the operative phrase. If the packaging says "eco-friendly" and the explanation is on a page of your website, the packaging claim is still generic. If the Amazon bullet says "green packaging" and the substantiation is in a downloadable PDF, the bullet is still generic. The specification has to sit next to the claim, on the box, in the bullet, in the ad.
The directive's own recitals give the cleanest illustration. "Climate-friendly packaging" is generic. "100% of energy used to produce this packaging comes from renewable sources" is specific (source: Directive (EU) 2024/825, recital 9). The second one is allowed because a consumer can see exactly what is being claimed and an inspector can ask for the energy contract.
The table below shows how that plays out for wording we see on products sourced in Asia.
| Wording on the product or listing today | Why it fails | What you can say instead, and what you need to have |
|---|---|---|
| "Eco-friendly bamboo toothbrush" | Generic claim, point 4a | "Handle made from bamboo; bristles are nylon and not compostable." No evidence needed for a factual description. |
| "100% biodegradable bags" | "Biodegradable" is listed as a generic claim in recital 9; also usually untrue outside industrial conditions | "Certified industrially compostable to EN 13432" with the certificate number, only if the material actually holds that certificate. |
| "Made with recycled material" on a product in a recycled box | Whole-product claim for a packaging feature, point 4b | "Box made from 90% recycled cardboard. Product: virgin polypropylene." Packaging has its own rules under the EU Packaging Regulation (PPWR). |
| "Carbon neutral delivery" | Offsetting claim, point 4c | "We contribute to project X per order" is allowed as a statement of what you do, without calling the delivery neutral. |
| Green leaf badge with "Eco Choice" designed in-house | Sustainability label without a certification scheme, point 2a | Remove it, or replace it with a label from a scheme that has independent verification, such as FSC for paper and wood, and only if you hold the chain-of-custody certificate. |
| "BPA-free baby bottle" as a headline feature | Legal requirement presented as a distinctive feature, point 10a | State the material: "Made from Tritan copolyester." |
Two words in that table deserve a warning. "Recyclable" is not on the generic list, but the Commission's FAQ treats it as a claim that must be true for the consumer in practice. If the material is technically recyclable but not collected in the country where you sell, the claim is misleading under the general rules that already applied before this directive. And "natural" is not on the list either, but combined with green imagery it can become a generic claim through the back door; the recitals say explicitly that words combined with colours or images can together form a generic claim (source: Directive (EU) 2024/825, recital 9).
4. Where the claims come from when you import from Asia
If you buy finished consumer products in China, Vietnam or India, the environmental claims on them were mostly not your idea. They arrive through three channels, and each needs a different fix.
Factory artwork. The packaging file the factory sends for approval usually comes from a template, the same file that has to carry the mandatory GPSR information for importers. Leaf icons, "Eco" in the corner, "100% natural" on the back. It is decoration to the designer. Under the new definition it is a claim, and since your name is on the box, it is your claim. The fix is to strip everything that is not a factual description at the artwork approval stage, before the print run, not after 10,000 boxes are on a pallet.
Catalogue copy. Supplier product descriptions on sourcing platforms are written to sell, and "eco-friendly" is the most common adjective in them. Sellers copy that text into Amazon bullets, Etsy descriptions and Shopify product pages, often word for word. Every one of those listings is a commercial communication in the EU and every generic claim in it is covered.
Material buzzwords. Bamboo, cork, wheat straw, "plant-based" plastic and PLA sell on an environmental promise, but the promise is rarely proven. A bamboo product with a melamine resin binder is not compostable. A PLA straw is only compostable in an industrial facility and only if certified. If you sell these materials, the claim has to be reduced to what the test report says, and if there is no test report, to what the material is.
What to ask a supplier for is not a promise but a document: a recycled content certificate, an EN 13432 compostability certificate with the certificate number, an FSC chain-of-custody number, or a lab report. A factory that cannot produce the document cannot back the claim, and in that case the claim comes off the artwork.
The artwork approval is also the moment to check the mandatory information on the same file. The Labelling check GPSR takes the packaging artwork and reviews traceability details, warnings, manufacturer details and the EU Responsible Person block. You are opening the file anyway; do both in one round instead of two print runs.
5. Old stock and containers already on the water
There is no transition period. The directive applies to all commercial communications from 27 September 2026, including products manufactured, ordered or shipped before that date (source: European Commission FAQ on Directive (EU) 2024/825). A container of packaged goods that left Shenzhen in August with "eco-friendly" printed on every box is covered the day it lands.
Regulators know this creates a real problem for slow-moving stock. The Dutch Authority for Consumers and Markets (ACM) published a note on old stock stating that companies are expected to work towards full compliance in good time, and that in specific cases with genuine transition problems, enforcement may take into account that a company can show it holds genuinely old stock and is making verifiable efforts to comply as fast as possible (source: ACM, Toelichting op de toepassing van de EU-richtlijn duurzaamheidsclaims bij oude voorraden). That is a statement about enforcement priorities, not an exemption. The ACM also points out that the directive adds to rules that already existed, so a claim that was already misleading in 2025 is not protected by being old.
In practice you have four options for printed stock, in order of cost.
- Remove the claim online. It costs nothing and covers the listing immediately.
- Add a corrective sticker over the claim on the box.
- Add corrective information at the point of sale, for example an insert or a note on the product page explaining the claim.
- Reprint.
For most importers the first two are enough for the current batch, with the artwork fixed for the next order.
6. Who enforces this, and where it hits you first
The Unfair Commercial Practices Directive is enforced nationally. In the Netherlands that is the ACM, which has been publishing its Leidraad Duurzaamheidsclaims since 2021, with an update in June 2023, and which has now been designated as the supervisor for the new rules (source: ACM, Leidraad Duurzaamheidsclaims; Ondernemersplein, Duurzaamheidsclaims moeten duidelijk en controleerbaar zijn). The Dutch implementing act, the Implementatiewet richtlijn betere duurzaamheidsinformatie voor consumenten (36.873), passed both chambers without debate and was published on 24 June 2026 (source: Eerste Kamer, dossier 36.873). Germany, France and the other member states have their own authorities, and a Dutch seller shipping to German consumers falls under German enforcement for those sales.
For online sellers the first pressure point will probably not be an inspector. It will be the marketplace. Amazon, Bol and Etsy have their own exposure under consumer law for what appears on their platforms. Expect listing policies on environmental wording to tighten, and expect competitors to report each other's "eco-friendly" bullets, because a report is free and a suppressed listing is a competitive advantage.
7. The Green Claims Directive is not this law
A lot of the confusion around this topic comes from a second proposal with a similar name. The Green Claims Directive, proposed in March 2023, would have required prior verification of explicit environmental claims by an accredited verifier before they could be used. In June 2025 the European Commission announced its intention to withdraw that proposal after opposition from the largest group in the European Parliament, and trilogue negotiations were paused; as far as public sources show, the file has not moved since (source: Latham & Watkins, June 2025; Carbon Gap policy tracker).
None of that affects the rules in this article. Directive (EU) 2024/825 was adopted in February 2024, is already in national law, and applies from 27 September 2026 regardless of what happens to the second proposal. If you read somewhere that "the EU green claims law was withdrawn", that refers to the verification proposal, not to the ban on generic claims.
8. What to do before 27 September
Work through this in the order below. Most of it is a day's work for a catalogue of a few hundred SKUs.
- Export every listing title, bullet and description you have live in the EU and search for the generic words: eco, green, sustainable, environmentally friendly, natural, biodegradable, compostable, climate, carbon, planet, earth. Also search for "certified" and "free".
- For each hit, decide: delete, or make specific. Specific means a measurable statement about one aspect, with the specification in the same bullet or on the same panel.
- For every specific claim you keep, put the supporting document in a folder with the SKU number: certificate, test report, supplier declaration with the material composition. If there is no document, the claim goes.
- Open the current packaging artwork for every active SKU and check icons, colours and product names, not only text. Remove self-made badges. Keep only labels from schemes with third-party verification, and only if you hold the certificate.
- For stock already printed, decide per SKU between removing the claim online, a corrective sticker, or an insert. Note the decision, because it is the "verifiable effort" the ACM refers to.
- Add a line to your supplier artwork approval process: no environmental wording or symbols without a document. This is the only step that stops the problem from coming back with the next order.
- If you sell "climate neutral" anything based on credits, change the wording now. That ban has no evidence route around it.
If the question is broader than one product, for example because the same supplier artwork runs across a whole range, schedule a call and send a few listings beforehand. It is quicker to look at real wording than to talk in general terms.
9. Conclusion
From 27 September 2026, three things are true for every consumer product sold in the EU. A generic environmental word without recognised excellent environmental performance behind it is banned outright. A self-made sustainability badge and an offsetting-based neutrality claim are banned regardless of evidence. And every specific claim you keep needs a document you can hand to an inspector.
For importers the work is mostly upstream. The claims come in through factory artwork and supplier copy, so that is where they have to be stopped, at artwork approval and before a listing is copied from a catalogue. Fix the current listings, sticker or delete for the current stock, and put a one-line rule in the approval process so the next container arrives clean.
Not sure which of your products carry a claim you cannot prove? Send us a few listings and packaging files through the contact page and we will tell you which ones would fail and why.
Sources
- Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition. Article 1 (new Article 2 points (o) to (w) of Directive 2005/29/EC; new Article 6(2)(d) and (e); Annex I points 2a, 4a, 4b, 4c, 10a and 23d to 23j), Article 4 (transposition by 27 March 2026, application from 27 September 2026), recitals 9 and 11. OJ L, 6 March 2024.
- Directive 2005/29/EC concerning unfair business-to-consumer commercial practices (Unfair Commercial Practices Directive), Annex I.
- European Commission, Frequently asked questions on Directive (EU) 2024/825 (Empowering consumers for the green transition), first version November 2025, updated 18 May 2026.
- Autoriteit Consument & Markt, Leidraad Duurzaamheidsclaims, updated version of 13 June 2023.
- Autoriteit Consument & Markt, Toelichting op de toepassing van de EU-richtlijn duurzaamheidsclaims bij oude voorraden, 2026.
- Eerste Kamer der Staten-Generaal, Implementatiewet richtlijn betere duurzaamheidsinformatie voor consumenten (36.873): submitted 18 December 2025, adopted by the Tweede Kamer on 23 April 2026 and by the Eerste Kamer on 26 May 2026, published 24 June 2026.
- Ondernemersplein (Rijksoverheid), Duurzaamheidsclaims moeten duidelijk en controleerbaar zijn, effective 27 September 2026.
- Regulation (EC) No 66/2010 on the EU Ecolabel; EN ISO 14024 (type I environmental labelling); EN 13432 (requirements for packaging recoverable through composting and biodegradation).
- Latham & Watkins, European Commission announces intention to withdraw EU Green Claims Directive proposal, June 2025; Carbon Gap, Green Claims Directive policy tracker.
