Greenwashing and green claims: a guide to EU Directive 2024/825
Nama Studio information guide · updated as of September 2026
If you work in e-commerce, fashion, beauty, or retail more generally, there is one date worth marking in your calendar: September 27, 2026. This is the day Directive (EU) 2024/825 — also known as “Empowering Consumers for the Green Transition” — the new European regulation against greenwashing, enters into full effect.
The important thing to understand right away is that this does not only concern advertising. It can apply to the very name of the product, descriptions, badges, icons, site filters, claims on product pages, packaging, and social media communication.
A directive broader than it seems
Member States were required to transpose the directive by March 27, 2026; from the end of September, it becomes concretely applicable to businesses. Between the two dates, the scope of what is considered an “environmental claim” remains very broad: it includes text messages, images, symbols, labels, brand names, company names, and product names that suggest an environmental benefit.
1. Product naming comes under the lens
Names like “Eco T-shirt,” “Green Dress,” “Sustainable Bag,” “Eco Skin Care,” “Clean Beauty,” “Conscious Collection,” “Planet Friendly,” or “Earth Friendly” can become problematic if the environmental benefit they suggest cannot be demonstrated.
The point is not that the word is automatically prohibited: it is that the company must be able to prove what it is communicating, avoiding an overall impression that is more positive than the product actually is.
2. Generic claims change status
The regulation considers generic expressions like “eco-friendly,” “green,” “environmentally friendly,” “ecological,” “climate friendly,” “biodegradable,” or “bio-based” particularly problematic when it is not possible to demonstrate excellent environmental performance that is recognized as relevant to that claim.
The difference is substantial: in the latter case, a concrete and measurable attribute is declared, rather than providing a general judgment on the product.
3. A claim must refer exactly to what it says
This aspect is particularly important for e-commerce. It is not enough to write “Made with recycled materials” if only a marginal part of the product — or perhaps only the packaging — is made with recycled material. The regulation prohibits extending a benefit to the entire product that applies only to a specific component or aspect.
4–5. Icons and site filters count, too
It is not just words that are involved: a tree, a leaf, a planet, or a green symbol contribute to the overall impression the consumer receives, just as much as text. The same goes for navigation filters: a generic “Sustainability” filter that groups products for very different reasons risks being misleading, and the new regulatory framework pushes toward classification based on specific and verifiable characteristics (e.g., “Recycled materials,” “Organic cotton,” “FSC-certified packaging,” “Made in EU”).
6–7. The risk of absolute claims: “100%” and “carbon neutral”
Claims like “100% sustainable,” “100% eco,” or “100% recyclable” communicate a total result and for this reason are particularly risky: in 2026, EU authorities addressed cases related to claims such as “100% recycled plastic,” requiring immediate specification of any exclusions (e.g., the cap and label of a bottle).
One of the strongest changes concerns climate claims: “climate neutral,” “CO₂ neutral,” “carbon neutral,” “climate positive,” or “net zero” cannot be used to give the impression of zero or reduced climate impact simply because the company offsets emissions through external offsetting activities.
8. Certifications: a badge is not enough
It is no longer sufficient to create a logo on your own (e.g., “Eco Choice”) and affix it to the product — a point particularly relevant for marketplaces and e-commerce sites that create proprietary badges. Voluntary sustainability labels must be based on:
• an appropriate certification system or a public authority;
• minimum standards of transparency and credibility;
• verification by independent third parties;
• alignment with international, EU, or national standards.
Two directives not to be confused
A point that often causes confusion: Directive 2024/825 is not the same thing as the so-called Green Claims Directive, a separate provision intended to establish more detailed requirements on how companies must demonstrate, communicate, and verify their environmental claims.
|
Aspect |
2024/825 — Empowering Consumers |
Green Claims Directive |
|
Status |
Adopted and in force |
Withdrawn by the EU Commission (June 2025) |
|
Application |
09/27/2026 |
None — proposal withdrawn |
|
Focus |
Unfair commercial practices and greenwashing |
Preventive scientific proof of claims |
|
Product naming |
Yes |
Planned, now suspended |
|
Independent verification |
Depends on the claim/system |
Planned ex-ante — reason for withdrawal |
|
Update: in June 2025, the European Commission initiated the withdrawal of the Green Claims Directive, mainly due to the administrative burden posed by the ex-ante verification by independent third parties. Directive 2024/825, however, remains fully in force and applicable from September 27, 2026: this is what you need to act on now. |
What is at risk: the sanctions
For the most serious violations of the rules on unfair commercial practices — of which anti-greenwashing rules are a part — Member States must provide for fines of up to at least 4% of the trader's annual turnover, with the possibility for some countries to set even higher caps. The exact level and criteria applied (gravity, duration, any repeat offenses) depend on the competent national authority.
Where to start: a self-assessment checklist
Before September 27, 2026, a good starting point is to review the following catalog and communication elements with your team:
• Product title and description
• Metafields and collections
• Badges (“Eco”, “Green”, “Sustainable”, etc.)
• Site icons and filters
• Menu and navigation
• Claims on the homepage and PDPs
• Packaging claims
• Newsletter and social ads
• Stated certifications
• CO₂ / carbon neutral claims
A useful method for finding your way is to build a simple map for each claim in use: claim → necessary evidence → recommended wording → wording to avoid.
A parallel obligation: the legal guarantee and the GARAN label
In addition to environmental claims, Directive 2024/825 also introduces two consumer information obligations that have nothing to do with greenwashing, but rather concern the legal guarantee of conformity and, in some cases, the commercial guarantee of durability. It is worth distinguishing them clearly, because one is mandatory for everyone and the other is just an optional plus.
The EU legal guarantee notice: mandatory for all
From September 27, 2026, anyone selling goods to consumers in the EU must display the European Commission’s harmonized notice, which reminds consumers of the 2-year minimum legal guarantee of conformity. This applies to all e-commerce businesses, with no exceptions based on company size.
Where it must be displayed:
• before the consumer places the order, ideally at checkout, near the purchase button;
• alternatively, on the product page, catalog, header, or homepage as a permanent link;
• recommended, although not mandatory, in the order confirmation email as well;
• must always be in color online, with a clickable and readable QR code.
What is not sufficient:
• including it only in the Terms and Conditions;
• a PDF hidden in the footer;
• paraphrased text instead of the official graphic;
• a version redesigned or altered by the company.
The GARAN label: a plus, not a mandatory requirement for all
If you do not offer any commercial durability guarantee, the GARAN label is not needed. But if you do offer one, and it meets three conditions, it becomes mandatory for that product: it must be free of charge, with no extra cost; it must cover the entire product; and it must have a duration of more than 2 years.
Fixed, non-modifiable elements: the “GARAN” wording, the checkmark and calendar icon, the legal guarantee reminder, and the QR code linking to the terms.
Elements customizable by the manufacturer: the duration in years, the trademark or brand, and the model ID. It must be positioned on the product page, near the model details, and can also be in a format that expands upon clicking. If printed, the required minimum size is 95 × 100 mm.
To-do: legal guarantee and GARAN
By September 27, 2026, a good starting point is to verify that:
• the legal guarantee notice is already visible before checkout;
• the graphic used is the official one, downloaded from the Commission’s website and not modified;
• it is positioned near the purchase button, or as a permanent link on the homepage or PDP;
• the QR code is functional and clickable on all pages;
• a decision has been made regarding any potential extra commercial guarantee;
• if so, the three conditions have been verified (free of charge, covers entire product, duration > 2 years);
• the GARAN label, if applicable, is activated with the correct customizable fields;
• the minimum size is respected if printed (95 × 100 mm);
• the flow has been tested on mobile and desktop.
In summary
• Starting September 27, 2026, the directive becomes effectively applicable: it covers naming, claims, icons, filters, and packaging, not just advertising.
• Every environmental claim must be made specific, measurable, and verifiable; it should never be a general judgment about the product.
• A badge or label only makes sense if it is supported by a recognized certification system or public authority.
• The most serious violations can lead to penalties of at least 4% of annual turnover.
• The EU legal guarantee notice is mandatory for everyone from September 27, 2026; the GARAN label, conversely, is contingent upon a voluntary commercial choice.
This article is for informational purposes only and does not constitute legal advice.
Sources
European Commission: Zalando commits to provide clearer information for consumer following EU action (IP/24/948, February 2024)
EU Retail Platform: Directive (EU) 2024/825, Empowering Consumer Green Transition
Latham & Watkins: European Commission Announces Intention to Withdraw EU Green Claims Directive Proposal
CMS Law: Protect your consumers or pay the price: mega fines for breaches of consumer protection laws
