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In short: Since 27 September 2026, EU directive 2024/825, known as EmpCo (Empowering Consumers for the Green Transition), applies across the EU. Generic claims such as “eco-friendly”, carbon neutrality based on offsetting, self-made eco labels and presenting legal requirements as a benefit are now risky or banned. What remains allowed is specific, evidenced and explained right next to the claim. UK businesses selling to EU consumers have to follow it too.

Does your website say “eco”, do your ads promise a lower environmental impact or does your packaging carry green seals? Then it is time to review your copy. And it is not only businesses that actively market sustainability. A product name, a category in your online shop or a claim that presents a legal obligation as a competitive edge can also cause problems.

The rules come from Directive (EU) 2024/825, which every member state has written into its consumer protection law. Germany, for example, amended its Act against Unfair Competition (UWG). The aim is to curb greenwashing, meaning misleading environmental claims. The new bans cover communication with consumers: websites, online shops, ads, social media and packaging.

Some practices are now banned in all circumstances. For others, the context and the impression the claim gives the consumer decide. The examples below are illustrative. Every alternative wording must be true, accurate and backed by evidence.

1. “Eco-friendly”, “green” or “kind to nature”

Generic environmental claims are among the biggest changes. Terms like “eco-friendly”, “green”, “nature friendly”, “biodegradable” or “energy efficient” suggest exceptional qualities but rarely explain what they are.

Such generic claims are banned unless the business can show recognised excellent environmental performance, for example through the EU Ecolabel, an officially recognised ISO 14024 type I eco label or relevant EU rules. If the specific environmental benefit is explained clearly and prominently in the same medium, the claim no longer counts as generic under this ban.

Risky: “Eco-friendly packaging.”

Better:

  • “The packaging is made of 70% recycled plastic.”
  • “100% of the energy used to make this packaging comes from renewable sources.”

The explanation has to sit right next to the claim, not on another page. If a short ad has no room for it, it is safer to drop the generic slogan.

2. “Carbon neutral” or “CO₂ neutral”

Claims about the climate impact of products and services are now stricter too. Calling a product “carbon neutral”, “climate positive” or “offset” on the basis of carbon offsetting is banned in all circumstances.

A typical example is a flight marketed as carbon neutral because the airline funds tree planting. Offsetting outside the product’s value chain is not the same as actually reducing emissions.

Risky: “This product is CO₂ neutral thanks to offsetting.”

Better:

  • “We have cut CO₂ emissions in production by 28% compared with 2023.”
  • “We support reforestation project X. This support does not change our product’s carbon footprint.”

Emission reduction claims need a clear scope, method and baseline. You can still talk about climate projects you support, as long as you do not imply that they remove the product’s climate impact. Claims about a whole company being carbon neutral fall outside this product specific ban, but still must not mislead.

3. Self-made eco labels and green seals

A green leaf, a globe or a seal reading “Eco Choice” looks like proof of environmental credentials. But what if the business designed it itself? Sustainability labels are now only allowed if they were set up by a public authority or are based on a certification scheme that meets the directive’s requirements: transparent rules, independent verification and monitoring of compliance.

Risky: your own “Green Product Certified” seal without independent certification.

Better:

  • use a legitimately obtained label such as the EU Ecolabel,
  • replace the seal with a specific fact: “The packaging contains 80% recycled plastic.”,
  • name your shop category “Products with recycled packaging” instead of a vague “Eco picks”.

Check your own product badges and icons too. Depending on the overall impression, a graphic symbol can work like a sustainability label.

4. “Eco product” when only the packaging is better

Even true information can mislead if it applies to only part of a product but the ad presents it as a feature of the whole. The directive therefore bans environmental claims about an entire product or business when they really concern only one part or one activity.

Think of a cosmetics brand that uses recycled plastic for its bottles. If it calls the entire product line eco-friendly, it creates a broader impression than it can support.

Risky: “Our product is made from recycled material”, when only the packaging is.

Better:

  • “The bottle body is made of 100% recycled plastic. This does not apply to the cap and label.”
  • “Our Manchester site runs on electricity from renewable sources.”

For every claim, ask: are we talking about the whole product, the packaging, one ingredient, one site or the whole company?

5. “We will be carbon neutral by 2030”

The rules cover future promises as well as the present. Statements like “Carbon neutral by 2030” or “Net zero by 2040” can no longer be just an ambitious slogan. They must be backed by clear, objective, publicly available and verifiable commitments set out in a realistic implementation plan with measurable targets, deadlines and resources. An independent expert must regularly check progress, and the findings must be available to consumers.

Risky: “We will be a 100% green company by 2030”, with no concrete plan.

Better: publish a realistic plan, arrange independent verification and link to the details next to the claim. If there is no plan yet, talk about the steps you have already taken.

Unlike the outright bans above, future claims are assessed case by case.

6. “Gluten free” on mineral water or “we comply with the law”

This point also affects businesses that never mention the environment. The rules also target irrelevant benefits. The European Commission gives examples such as mineral water labelled “gluten free” or ordinary paper marketed as “plastic free”. These are assessed case by case because they can suggest a product is better than others when there is no real difference. A separate outright ban covers presenting legal requirements that apply to all products in a category on the EU market as your own advantage.

Risky: “Our product contains no substance X”, when substance X is banned in every product of that kind.

Better: communicate a genuine difference, such as a proven higher protein content than comparable products, or a specific feature that goes beyond the law, such as a documented level of a substance 50% below the legal limit.

The rule is simple: do not turn obligations or the obvious into a selling point.

7. “Eco”, “Green” or “Natural” in names and on packaging

An important clarification from the Commission concerns product, brand and company names. Even a registered trade mark can be an environmental claim if it gives the average consumer the impression of an environmental benefit. That does not mean every company with “Green” in its name is automatically in breach.

Check product lines such as “Eco Line”, categories such as “Green products”, slogans, domains and green leaves or droplets on packaging. With a name like “EcoClean”, explaining that the bottle is made from recycled plastic may not be enough, because customers may link the eco claim to the cleaning product itself. Precise names such as “Products with recycled packaging” and a check of the overall impression are safer. Green colours or a leaf are not banned as such, but combined with other elements they can mislead. Separate rules apply to “organic” and “bio” on food that meets EU organic farming standards.

New duties for online shops: guarantee notices

The directive also brings a change unrelated to green claims. Since 27 September 2026, traders selling consumer goods in the EU must clearly display a harmonised EU notice about the legal guarantee of conformity, reminding consumers of their statutory protection of at least two years. Online, it can be shown as a general notice on the website. Its content and design are set by Implementing Regulation (EU) 2025/1960. There is also a new harmonised label for a free commercial durability guarantee of more than two years, which traders must display when the manufacturer offers one and provides the information. The European Commission has published official templates and guidance.

Old stock is not automatically exempt. What are the penalties?

The rules also apply to marketing for products and packaging made before 27 September 2026. Consumer protection authorities in the EU’s CPC network have agreed a common approach to older stock and may take into account traders’ reasonable efforts, stock volumes and options to correct claims, for example by updating online descriptions, adjusting marketing materials or adding information at the point of sale. Old packaging, however, is not an automatic exemption.

Penalties depend on the member state. In Germany, breaches are mainly pursued through warning letters and injunctions from competitors and consumer associations, and fines of up to 4% of annual turnover are possible for widespread infringements in coordinated EU actions.

What about the UK?

The UK is not bound by the EmpCo directive. Its rules point in the same direction, though. Since 6 April 2025, the Digital Markets, Competition and Consumers Act lets the Competition and Markets Authority fine businesses up to 10% of global turnover for misleading practices, including greenwashing, and the CMA’s Green Claims Code sets out what it expects. If you sell to consumers in the EU, the EmpCo rules apply to that marketing as well.

6 steps to check your website and ads

  1. Review every channel: website, product descriptions, categories, ads, social media, newsletters, catalogues and packaging.
  2. Search for risky terms: eco, green, sustainable, carbon neutral, recyclable or biodegradable.
  3. Define the scope of each claim: the whole product, one part, the production process or the whole company?
  4. Check the evidence: measurements, methodology, certificates or other proof.
  5. Fix vague wording: use specific facts and explain them right next to the claim. If you cannot back it up, do not use it.
  6. Set up approval for new copy: including content from manufacturers, agencies, freelancers and other suppliers.

Larger online shops benefit from a simple register of claims, where they are used, the evidence behind them and who is responsible.

None of this means businesses should stop talking about sustainability. It changes how they do it. A generic slogan can no longer replace specific, verifiable information. Before publishing, ask three questions: what exactly are we claiming, what will the customer understand by it, and do we have evidence for that impression?

When we write content for websites, blogs and ads, accuracy matters as much as SEO, readability and conversions. If you want to make sure your ads, website and social media copy reflect the new rules, get in touch. Find out more about our content marketing work.

This article is for information only and is not legal advice. It is based on Directive (EU) 2024/825, the European Commission’s questions and answers, which are not a legally binding interpretation, and on publicly available guidance on national implementation. Status: November 2026.

Read also: Marketing trends 2027, Healthcare advertising rules for clinics

Sources: Directive (EU) 2024/825, activeMind.legal: EmpCo guide (German), KPMG: the UK’s new consumer enforcement regime, Ashurst: greenwashing in the spotlight