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Green claim / Empowering Consumers Directive (greenwashing)

An environmental claim is any non-mandatory message or representation stating or implying that a product, brand or trader has a positive or zero environmental impact, is less damaging than others or has improved over time; Directive (EU) 2024/825 requires Member States to prohibit generic and unsubstantiated versions of such claims; the national rules transposing it apply from 27 September 2026.

Reviewed 22 September 2026 by Conphora compliance team · Not legal advice.

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In more detail

Directive (EU) 2024/825 amends the Unfair Commercial Practices Directive 2005/29/EC and the Consumer Rights Directive 2011/83/EU to protect consumers against greenwashing and early obsolescence. It inserts a definition of an environmental claim: any message or representation which is not mandatory under Union or national law, in any form, in the context of a commercial communication, which states or implies that a product, product category, brand or trader has a positive or zero impact on the environment, is less damaging than others or has improved its impact over time. A generic environmental claim is one made in written or oral form that is not on a sustainability label and whose specification is not provided in clear and prominent terms on the same medium. A sustainability label is any voluntary trust mark or quality mark promoting a product, process or business by reference to its environmental or social characteristics.

The directive adds practices to the blacklist in Annex I of Directive 2005/29/EC, which are prohibited in all circumstances: displaying a sustainability label that is not based on a certification scheme or established by public authorities; making a generic environmental claim for which the trader cannot demonstrate recognised excellent environmental performance; making a claim about the entire product or business when it concerns only one aspect; claiming, on the basis of offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive climate impact; and presenting legal requirements as a distinctive feature of the offer.

Member States had to adopt the transposing measures by 27 March 2026 and apply them from 27 September 2026 (Article 4). The obligations bind traders through that national law — in Denmark through the Marketing Practices Act — not through the directive itself. For a manufacturer or retailer, every environmental statement on packaging, websites and marketplaces must therefore be specific and substantiated, and any label must be backed by a certification scheme or public authority.

Sources

  1. Directive (EU) 2024/825 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32024L0825
Cite this page
Conphora (2026). Green claim / Empowering Consumers Directive (greenwashing). Retrieved 13 October 2026 from https://www.conphora.com/research/glossary/green-claim/
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