EU environmental claims
Six priorities before the new rules apply
Over the last few years, many businesses have invested heavily in more sustainable products and packaging. The next challenge is making sure those improvements are communicated in a way that complies with the law.
From 27 September 2026, the EU's Empowering Consumers for the Green Transition Directive will begin to apply. Its aim is simple: reduce greenwashing by preventing businesses from making environmental claims that are too broad, poorly supported or likely to mislead consumers.
The changes don't just affect product labels. They apply to websites, online marketplaces, social media, advertising and, in some cases, even product names, logos and imagery.
Whilst not all EU member states have yet transposed the Directive into local law, the new rules will apply in some key member states, and companies are advised to ensure timely compliance.
1. Prohibited practices
The Directive introduces several practices that will simply no longer be allowed.
These include:
Displaying a sustainability label that is not based on an appropriate certification scheme or established by a public authority.
Making broad environmental claims without recognised evidence of outstanding environmental performance.
Presenting a benefit relating to one part of a product or business as though it applies more widely.
Claiming that a product is carbon or climate neutral where this relies on carbon offsetting.
Promoting compliance with a legal requirement as though it is a special feature of the product.
These are important because they become automatically prohibited. An enforcement authority does not need to show that the claim influenced a purchasing decision before taking action.
2. Review your generic environmental claims
Many of the environmental claims that have become common over recent years could now become much harder to justify.
Words such as environmentally friendly, eco-friendly, green, climate friendly, biodegradable and biobased are all highlighted by the legislation as examples of generic environmental claims.
For most businesses, the answer will not be trying to prove that the entire product has exceptional environmental performance. Instead, it is likely to mean replacing broad statements with much more specific claims that can be supported by evidence.
For example, saying a product is simply "biodegradable" may not be appropriate. Explaining that "95% of the formula is biodegradable according to OECD 301 testing" gives consumers a much clearer understanding of what is actually being claimed and is more likely to be interpreted as not misleading by authorities.
Often companies rely on qualifications for claims, and one point that is easy to overlook is where that explanation appears.
If a claim needs qualifying, the qualification should appear alongside the claim itself otherwise there is a risk to mislead the consumer. Businesses should not expect a website or separate technical document to correct a message that is potentially misleading on the front of the pack.
Just because a claim is technically accurate does not necessarily mean consumers will understand it in the way the business intended.
3. Look beyond the wording
Many businesses naturally focus on reviewing claim wording. However, the overall presentation matters just as much.
Product names, logos, green colour schemes, leaves, water imagery and other design elements may all contribute to an environmental message when viewed together.
The same principle applies to the scope of a claim.
Looking at artwork and wording together will often identify issues that would be missed if claims were reviewed in isolation.
4. Consider the subject of the claim
Imagine a bottle made with recycled plastic but a virgin plastic cap. A claim stating "made with recycled material" could easily leave consumers believing the entire pack contains recycled material. A much clearer claim would explain exactly which component contains recycled content.
By isolating and clearly defining the specific component or aspect to which an environmental claim applies, businesses can avoid creating misleading impressions and ensure their messaging remains transparent, accurate and compliant with the Directive’s focus on consumer clarity.
5. Check your sustainability labels
Many businesses use logos, badges or certification marks to communicate their sustainability credentials.
From September 2026, those labels will need much closer scrutiny.
Private sustainability labels will only be permitted if they are based on a certification scheme that meets the requirements set out in the Directive, including publicly available criteria and independent third-party monitoring.
Businesses should not assume that because a label is widely recognised it automatically complies with the new rules. This is also a good opportunity to review any in-house logos or "approved", "verified" or "certified" style graphics that may have evolved over time.
On the other hand, not every graphic is a sustainability label. A simple illustration explaining how to refill a bottle, for example, is unlikely to fall within these rules because it is simply providing practical instructions.
6. Don't overlook carbon and packaging claims
Product claims such as "carbon neutral", "climate neutral" or "climate compensated" will be prohibited where they rely on carbon offsetting outside the product's value chain.
Packaging claims also deserve careful attention. Businesses should think carefully about what claims such as "recyclable" or "made with recycled material" are actually communicating to consumers. If the evidence only supports part of the packaging, or if real-world recycling does not reflect the impression created by the claim, changes may be needed.
These claims should also be reviewed alongside the Packaging and Packaging Waste Regulation, which introduces its own requirements for environmental claims relating to packaging. In this regard, claims of mere legislative compliance should not be used.
Start your review now
With only a short time before the new rules apply, now is the right time to start a structured review.
We recommend beginning by:
identifying every environmental claim and sustainability label used across packaging, websites, advertising and social media
prioritising broad environmental claims, climate claims and sustainability labels for review
reviewing artwork as well as wording to make sure the overall impression is accurate
identifying products that may need artwork updates
checking that every claim is supported by evidence that matches exactly what is being communicated
The European Commission has published helpful Questions and Answers to support implementation, but some areas will only become clearer as enforcement develops (after the date of application). That means businesses should not wait for every uncertainty to disappear before taking action.
The new rules are intended to stop greenwashing, not prevent companies from talking about genuine environmental improvements. Businesses that can explain exactly what a claim means, support it with appropriate evidence and avoid overstating the benefit are already well on the way to compliance.
How Bloom can help ?
Navigating the transition to the new ECGT requirements does not have to compromise your brand’s authentic narrative. At Bloom Regulatory, we specialise in helping businesses balance rigorous compliance with clear, compelling consumer messaging.
Whether you need to audit your digital footprint, assess high-risk packaging artwork, or establish clear legal boundaries for sustainability claims, we provide the technical expertise and actionable guidance to help you make informed commercial decisions. If you are ready to ensure your claims are as robust as your environmental commitments, we are here to support your journey toward compliant, transparent communication.
Amanda Isom