Banned & Restricted Green Claims Under EU Law

Banned under EU Directive 2024/825 unless substantiated by recognised certification. Too vague to convey meaningful environmental information to consumers.

Generic environmental claim prohibited without clear, prominent specification on the same medium. Gives an unjustified impression of environmental virtue.

One of the most commonly flagged terms. Banned as a standalone claim because it implies overall environmental excellence without evidence.

Misleads consumers into assuming environmental benefit. "Natural" does not necessarily mean low-impact; arsenic and crude oil are also natural.

Explicitly listed in the Directive as a generic claim that cannot be used without recognised certification or specific, verifiable evidence.

Variant of "environmentally friendly" — equally vague and equally prohibited without substantiation under the ECGT Directive.

Another variant of a generic environmental claim. No product can credibly claim to be beneficial for the entire planet without qualification.

Ambiguous term that can imply environmental or health benefits without specifying either. Particularly problematic in beauty and food sectors.

Used widely in fashion (e.g. "Conscious Collection") but conveys no specific environmental information. Regulators consider it misleading.

Vague aspirational term. Does not communicate what environmental measures are actually in place.

Implies environmental or health safety without specifying which substances were excluded or what testing was performed.

Prefix commonly used as shorthand for environmental benefit ("eco-packaging", "eco-range"). Prohibited without specific substantiation.

Generic environmental claim listed under EMPCO-A1. Implies a positive relationship with nature without any measurable or verifiable environmental benefit.

Banned under EMPCO-A1 as a generic environmental claim. In some EU markets (e.g. Spain, France) the term is legally protected for certified organic products only.

Vague claim suggesting compliance with unspecified environmental standards. Prohibited without specific, verifiable evidence under Directive 2024/825.

Listed in EMPCO-A1 banned terms. Implies a positive climate impact without specifying emissions data or reduction measures.

Generic environmental claim that conveys no specific information. Prohibited under EMPCO-A1 without substantiation by recognised certification.

No product can credibly claim zero environmental harm across its full lifecycle. This is a prohibited generic claim under EMPCO-A1.

Vague carbon-related claim that implies climate benefit without specifying emissions data, reductions, or methodology.

Using the noun form as a marketing claim (e.g. "committed to sustainability") is equally vague and prohibited as the adjective form under EMPCO-A1.

Extremely broad claim implying net positive environmental impact. No single product can substantiate benefit to the entire planet.

Implies the consumer is making an environmentally superior decision without specifying what makes this choice better than alternatives.

When used to imply environmental benefit, "pure" is a generic claim under EMPCO-A1. Often confused with product composition claims but misleading in environmental context.

Listed in EMPCO-A1 banned terms. Implies net climate benefit without specifying whether this is achieved through reductions, removals, or offsets.

Vague reduction claim that lacks a baseline, timeframe, scope, and verification. Prohibited without specific substantiation under EMPCO-A1.

Comparative claim requiring a clear baseline, scope, methodology, and third-party verification. Without these, it is an unsubstantiated generic claim.

Explicitly banned under Article 1(4) of Directive 2024/825 when based on greenhouse gas emission offsets. Must reflect actual lifecycle impact.

Implies the product removes more carbon than it emits. Exceptionally difficult to substantiate and banned if based on offsets.

Synonym for carbon neutral — explicitly covered by the Directive's ban on offset-based neutrality claims.

Prohibited when used to suggest achieved neutrality via offsets. "Net zero" requires near-total value-chain decarbonisation per SBTi.

Offsets alone cannot form the basis of a carbon neutrality claim. The Directive prohibits claims based solely on purchased carbon credits.

Implies net benefit to the climate. Extremely hard to prove and falls under the prohibition on unsubstantiated environmental excellence claims.

Compensation through offsets is the exact practice targeted by the new rules. Cannot be used to imply neutrality.

Almost no product truly produces zero emissions across its full lifecycle. Misleading unless the claim covers all scopes and is independently verified.

Relative claim that requires a clear benchmark. Without specifying "lower than what" and by how much, it is considered unsubstantiated.

Variant spelling of carbon/CO2 neutrality claim. Explicitly listed in EMPCO-A2 banned terms. Prohibited when based on offsetting alone.

Listed in EMPCO-A2. Compensation through offsets alone cannot form the basis for an environmental neutrality claim under Directive 2024/825.

Synonym for carbon compensated, explicitly listed in EMPCO-A1 and EMPCO-A2. Banned when used to imply climate neutrality achieved through offsets.

Listed in EMPCO-A2 banned terms. Implies emissions have been balanced out, typically through offsets. Prohibited as a standalone neutrality claim.

Variant of carbon balanced, explicitly listed in EMPCO-A2. Cannot be used to imply net-zero climate impact without genuine emission reductions.

Explicitly listed in EMPCO-A2. Offsetting alone is not equivalent to genuine emission reduction. This claim creates a misleading impression of environmental neutrality.

Misleading unless the conditions and timeframe for biodegradation are specified. Many "biodegradable" products only degrade in industrial facilities.

Must specify whether home-compostable or industrially compostable. Misleading if local composting infrastructure does not exist for the consumer.

Prohibited when the product is not actually recyclable in practice for a significant proportion of consumers. Must reflect real-world recycling infrastructure.

Requires specification of the percentage of recycled content and whether it is pre-consumer or post-consumer recycled material.

In food and cosmetics, regulated by specific EU organic regulations. In other sectors, it can be misleading without recognised certification.

Does not automatically mean environmentally superior. Must specify the percentage of bio-based content and its source.

Can only be used if the product and its packaging contain absolutely no plastic, including coatings, linings, and adhesives.

Scientifically inaccurate — all matter is made of chemicals. Misleads consumers about product safety or environmental impact.

Vague material claim. Does not specify which materials, what percentage, or whether extraction was environmentally responsible.

Future claims are banned without a detailed, publicly accessible implementation plan with measurable, time-bound targets reviewed by an independent body.

Requires independently verified interim milestones and a credible plan. Vague progress claims without data are prohibited.

Commitments without binding action plans are considered greenwashing. The Directive requires concrete, time-bound, independently monitored targets.

Aspirational language without measurable progress is non-compliant. Must show what specific actions are being taken and their results.

Without a clear definition of "zero waste", measurable milestones, and third-party monitoring, this is a prohibited unsubstantiated future claim.

Implies progress without requiring proof. Must include a concrete plan with milestones, timelines, and independent verification.

The Directive prohibits sustainability labels that are not based on official certification schemes or established by public authorities. Self-created logos mislead consumers.

Trust marks and quality seals that lack third-party verification are explicitly targeted by the Directive as misleading commercial practices.

Self-created scoring systems (e.g. a brand's proprietary "eco-score") are prohibited unless they meet the Directive's requirements for transparency, third-party oversight, and comparability.

Visual elements implying environmental certification (green ticks, leaf badges, globe icons) are considered implicit environmental claims and must be substantiated.

Self-approval creates a false impression of independent assessment. The Directive requires that certification involves genuine third-party evaluation.

Comparative environmental claims must be based on equivalent methodology, comparable scope, and up-to-date data. Vague comparisons are prohibited.

Must specify what is being compared, using what methodology, and covering which environmental aspects. Otherwise it is a prohibited generic claim.

Extremely broad comparative claim. Requires full lifecycle comparison and clear disclosure of scope, data sources, and methodology.

Combines a banned generic term with a comparative structure. Double non-compliance: unsubstantiated base claim plus unsubstantiated comparison.

Superlative environmental claims require comprehensive evidence covering all competitors in the same product category and methodology disclosure.

Implies superiority over all competitors. Must be verifiable through third-party benchmarks or standardised assessments.

Banned under EMPCO-A6 when the product is still functional. Inducing premature replacement through false end-of-support claims is a prohibited commercial practice under Directive 2024/825.

Prompting consumers to replace consumables (cartridges, filters, batteries) before technically necessary is prohibited under EMPCO-A6. Often triggered when significant capacity remains.

Falsely claiming accessories are incompatible when they still function is banned under EMPCO-A6. This includes software-driven incompatibility designed to push new purchases.

Prohibited when the update deliberately reduces functionality of older hardware to push upgrades. Genuine security updates are exempt but must be communicated transparently.

Marketing that implies the current product is outdated when still functional falls under EMPCO-A6 restrictions on inducing premature replacement.

Declaring a functional product as end-of-life to drive replacement is a banned practice under EMPCO-A6. Only genuine technical obsolescence (safety risks, no security patches) justifies such claims.

Timer-based replacement prompts that do not reflect actual filter condition are banned under EMPCO-A6. Consumers must not be pushed to replace consumables prematurely.

Banned under EMPCO-A7 when BPA is already prohibited by EU regulation in that product category (e.g. baby bottles, food contact materials). Presenting legal compliance as a distinctive feature misleads consumers.

CE marking is legally mandatory for products sold in the EU. Presenting it as a quality differentiator or special feature is prohibited under EMPCO-A7.

A minimum 2-year guarantee is legally required for all consumer goods in the EU under Directive 1999/44/EC (now updated by Directive 2019/771). Marketing it as a special benefit is prohibited under EMPCO-A7.

Animal testing for cosmetics has been banned in the EU since 2013 under Regulation 1223/2009. Claiming this as a distinctive feature for cosmetics is prohibited under EMPCO-A7.

REACH compliance is legally mandatory for all chemicals and products sold in the EU. Using it as a marketing differentiator is banned under EMPCO-A7.

RoHS compliance is mandatory for electrical and electronic equipment in the EU. Presenting it as a special feature is misleading under EMPCO-A7.

CLP (Classification, Labelling and Packaging) compliance is a legal obligation, not a product feature. Marketing mandatory hazard labelling as a safety benefit violates EMPCO-A7.

Several phthalates are already banned in toys and childcare articles under EU REACH Annex XVII. Claiming their absence as a feature in regulated categories is prohibited under EMPCO-A7.