Greenwashing: The EU Rules That Apply From 27 September 2026

Greenwashing stops being a reputational risk and becomes an unfair commercial practice across the European Union on 27 September 2026. That is the date from which Member States must apply Directive (EU) 2024/825 — the Empowering Consumers for the Green Transition Directive — which adds a list of sustainability-claim practices to the blacklist in Annex I of the Unfair Commercial Practices Directive, banned in all circumstances without any need to prove that a consumer was misled. Generic environmental claims, self-invented sustainability labels, carbon-neutral claims based on offsetting, and future-performance promises without a verified plan are all on it. There is no transition period. This guide explains what the Directive prohibits and from when, what it requires for the claims that remain permitted, what happened to the separate Green Claims Directive, and how a company builds the claims control that keeps its marketing on the right side of the line.

The greenwashing law and the date

Directive (EU) 2024/825 was adopted on 28 February 2024. It amends two existing directives — the Unfair Commercial Practices Directive 2005/29/EC and the Consumer Rights Directive 2011/83/EU — rather than creating a new regime, which is why it bites so hard: the practices it adds to Annex I of the UCPD are per se unfair, prohibited in every Member State, enforced by consumer authorities and actionable by competitors and consumer organizations. Member States had to transpose it by 27 March 2026 and must apply their measures from 27 September 2026. Claims that were acceptable the day before may be unlawful the day after; the Directive contains no grandfathering for existing packaging or campaigns.

The Green Claims Directive — a separate 2023 proposal that would have required ex-ante verification of explicit environmental claims by accredited bodies — is not this law. The Commission withdrew it in June 2025. Nothing in that withdrawal touches Directive 2024/825, which was already adopted and in force; the rules below are binding regardless.

What the greenwashing rules prohibit from 27 September 2026

The Directive adds the following to the Annex I blacklist of practices that are unfair in all circumstances.

Alongside the blacklist, the Directive tightens the general test. Environmental claims about future performance — “net zero by 2040”, “100% recyclable by 2030” — are misleading unless backed by clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan with measurable, time-bound targets, and regularly verified by an independent third-party expert whose findings are made available to consumers. Comparative environmental claims must state the method and the products compared. And “sustainability label” is defined broadly — any voluntary trust mark, quality mark or equivalent that sets a product, process or business apart on environmental or social characteristics.

What the rules require for claims that remain lawful

Who the greenwashing rules reach

Any trader making business-to-consumer claims in the EU, regardless of where it is established. The rules attach to the claim, not to the company’s reporting status: a company outside CSRD scope that sells to EU consumers is fully within them. Business-to-business claims are outside the UCPD but sit under national unfair-competition and advertising law, where the same evidence standard is increasingly applied — and a B2B claim that reaches a consumer through a customer’s marketing is the customer’s problem and then, contractually, yours. Enforcement is by national consumer authorities with penalties set nationally; the Directive also preserves the right of competitors and consumer bodies to bring actions, which is where much greenwashing enforcement has historically come from.

Building the greenwashing control

1. Inventory every claim. Packaging, website, advertising, product listings, sales decks, tender responses, investor materials. Most companies find several hundred, and most of the generic ones are on packaging with long print runs.
2. Classify each against the table. Banned outright; allowed with conditions; allowed. Generic terms and offset-based neutrality claims go in the first column and come off by 27 September.
3. Trace every remaining claim to evidence. A claim about emissions traces to the Scope 1, 2 and 3 inventory; a recycled-content claim to supplier certificates; a future target to the transition plan and its verification. If the evidence does not exist, the claim does not run. Our guide to Scope 1, 2 and 3 emissions covers the inventory most claims depend on.
4. Replace labels with certified ones or remove them. An internal badge is a banned practice; the EU Ecolabel, and certification schemes with third-party monitoring, are not.
5. Route claims through the ESG policy. The policy states the commitments and targets; marketing may claim what the policy commits to and the KPIs evidence, and nothing beyond it. Our guide to the ESG policy puts claims control in its review section.
6. Put a sign-off in the process. Legal or sustainability reviews every environmental or social claim before publication, against the classification and the evidence file. Record the approval.
7. Train marketing and sales. The people writing the copy need the banned-terms list and the reason for it.

Frequently asked questions

When do the EU greenwashing rules apply?
From 27 September 2026, under Directive (EU) 2024/825. Member States had to transpose it by 27 March 2026. There is no transition period for existing claims, packaging or campaigns.

Is ‘carbon neutral’ banned?
Where the claim rests on offsetting greenhouse gas emissions, yes — claims of neutral, reduced or positive environmental impact based on offsets are on the Annex I blacklist. A reduction claim evidenced by the company’s own value-chain emissions remains possible.

Can we still say ‘eco-friendly’?
Only if the product has recognized excellent environmental performance relevant to the claim, such as an EU Ecolabel. Generic environmental claims without that are prohibited in all circumstances.

What happened to the Green Claims Directive?
The Commission withdrew that separate proposal in June 2025. It would have added pre-approval of claims by accredited verifiers. Directive 2024/825 was already adopted and is unaffected.

Does this apply to non-EU companies?
Yes, to any trader making business-to-consumer claims in the EU market, regardless of where it is established. The rules attach to the claim.

Where this leaves you

Treat 27 September 2026 as a hard date: inventory every sustainability claim, remove the generic terms, the self-made labels and the offset-based neutrality claims, trace everything else to evidence held in the ESG policy and the emissions inventory, and put a documented sign-off between the claim and the customer. Greenwashing enforcement in the EU no longer needs to prove anyone was misled — only that the claim was made.

References

• Directive (EU) 2024/825 of 28 February 2024 — The Empowering Consumers for the Green Transition Directive: the Annex I additions and the transposition and application dates.
• Directive 2005/29/EC (Unfair Commercial Practices Directive) — The directive whose Annex I blacklist the new practices join.

More on ESG

• The EU greenwashing rules — you are here
• ESG reporting in 2026: what the EU simplification changed
• ESG policy: the six sections
• Scope 1, 2 and 3 emissions
• ESG KPIs: the twelve metrics boards ask for
• ESG vs CSR: four differences

The ESG policy templates and environmental policy that a claims-control process is anchored to, with the aspects and impacts registers and an ESG gap analysis tool, are in the ESG Toolkit, or start with the free templates.