82 Banned Green Terms Under the EU ECGT Directive (2026)

The EU Empowering Consumers for the Green Transition Directive (2024/825) — known as the ECGT Directive — bans or restricts 82 distinct environmental marketing terms when used without specific, verifiable substantiation. The Directive was published on March 6, 2024, the transposition deadline passed on March 27, 2026, and full EU-wide application begins September 27, 2026. From that date, any of the 82 terms below appearing in a product description, homepage banner, packaging text, or marketing email exposes the trader to fines of up to 4% of in-country turnover — per member state, in parallel.

This is the complete reference. Most public lists circulating online cover the 12–28 most obvious entries ("eco-friendly," "green," "carbon neutral") and stop there. The actual scope of the Directive — once you map every prohibited claim type in Annex I, the Unfair Commercial Practices Directive amendments, and the November 2025 Commission Q&A — covers 82 terms across 8 legally distinct categories. Every term on the EcoClaim banned-words reference is tied to a specific Annex I point or UCPD article, with the legal reasoning and a compliant alternative.

How the 82-Term List Is Built

Article 6 of Directive 2005/29/EC, as amended by Directive 2024/825, makes any environmental claim a misleading commercial practice when it is generic, unsubstantiated on the same medium, based solely on offsets, or implies an environmental benefit not actually delivered. Annex I of the same Directive — the blacklist of practices considered unfair in all circumstances — adds 13 new points (4a, 4b, 2a, 2b, 4c, 23a, 23b, 23c, 23d, 23e, 23f, 23g, 23h) that prohibit specific claim types outright, regardless of context. The 82-term reference is the cross-product of those legal sources applied to the marketing language actually used by EU e-commerce stores. See the full categorized list on the Banned & Restricted Green Claims page.

The 82 Banned Terms by Category

1. Generic Environmental Claims (23 terms) — Annex I, point 2 + Article 6(2)

Generic claims convey an unjustified impression of environmental virtue without specifying what the benefit is or how it is verified. The Directive prohibits them outright when used without recognized excellent environmental performance certification displayed on the same medium. This is the largest and most-often-violated category.

• Eco-friendly — banned generic claim, no certification possible without specifying scope
• Green — explicitly cited in EU Parliament press release of January 2024 as a prohibited generic term
• Sustainable — most-flagged term in EcoClaim scans, banned as a standalone label
• Natural — misleads on environmental impact (arsenic and crude oil are also natural)
• Environmentally friendly — explicitly listed in Annex I of the consolidated Directive
• Earth-friendly — variant of "environmentally friendly," same prohibition applies
• Planet-friendly — no product can credibly claim planet-wide benefit
• Clean — ambiguous; particularly problematic in beauty and food sectors
• Conscious — implies ethical/environmental virtue without any substantiation
• Responsible — generic virtue claim without measurable benchmark
• Non-toxic — implies broad safety without testing data
• Eco — abbreviated generic claim, banned regardless of context
• Nature's friend — generic implication of environmental harmony
• Ecological — generic claim without scientific substantiation
• Environmentally correct — implies regulatory or moral compliance without proof
• Climate friendly — variant of carbon-neutrality implication, banned
• Gentle on the environment — vague qualitative claim
• Not harmful to the environment — negative claim, equally unsubstantiable
• Carbon friendly — variant of climate-neutrality language
• Sustainability — used as standalone product label, banned
• Good for the planet — categorical claim, banned
• Green choice — generic positioning, banned
• Pure — implies absence of harmful elements without specification

2. Carbon & Climate Claims (18 terms) — Annex I, point 4 + 4a

Annex I, point 4a — added by Directive 2024/825 — prohibits any environmental claim based on the offsetting of greenhouse gas emissions when applied to a product's overall environmental impact. Climate-neutrality and carbon-neutrality claims that rely on offset purchases (rather than verifiable in-value-chain emissions reductions) are banned in all circumstances. The October 2025 TotalEnergies ruling and the Apple 'carbon neutral' Apple Watch ban in Germany apply this rule directly.

• Carbon positive — implies net positive climate effect, almost never substantiable
• CO2 reduced — must be quantified, baselined, and verified by recognized methodology
• Reduced carbon footprint — same substantiation requirement as CO2 reduced
• Carbon neutral — banned when based on offsets (Annex I, 4a), restricted otherwise
• Carbon negative — claim of net-negative impact, requires extraordinary evidence
• Climate neutral — same offset-based prohibition as carbon neutral
• Net zero — ambiguous between corporate and product claims, restricted
• Carbon offset — cannot be used as a green credential for product marketing
• Climate positive — implies net positive climate effect, almost never substantiable
• CO2 compensated — same offset-based prohibition
• Zero emissions — only allowed for actual zero-direct-emissions products (e.g. EV at point of use, with disclosure)
• Low carbon — must be quantified and benchmarked, not used standalone
• CO2 neutral — same prohibition as carbon neutral / climate neutral
• Carbon compensated — offset-based, banned
• Climate compensated — offset-based, banned
• Carbon balanced — implies net-zero through unspecified mechanism, banned
• Climate balanced — same prohibition
• We offset our emissions — explicitly banned as a green-credential claim under Annex I, point 4a

3. Material & Composition Claims (9 terms) — Article 6 substantiation rules

Material and composition claims are not banned outright but are heavily restricted under the substantiation requirements of Article 6. They must specify the percentage, the certification body, and the lifecycle stage to which the claim applies. A product is not "recyclable" if recycling infrastructure is not available in the consumer's region; it is not "organic" unless it carries the EU organic logo with full certification reference.

• Biodegradable — must specify conditions, timeframe, and end-of-life percentage (EN 13432 or equivalent)
• Compostable — must specify industrial vs home composting and certification body
• Recyclable — banned without local recycling-infrastructure verification (Annex I, 4b)
• Recycled — must specify exact percentage and reference standard (e.g. GRS, RCS)
• Organic — restricted to EU-Ecolabel or EU organic logo certified products
• Bio-based — must specify percentage of bio-based content per ISO 16620
• Plastic-free — must specify scope (packaging, product, both) and verification method
• Chemical-free — categorically misleading; everything is made of chemicals, banned as worded
• Made from natural materials — vague; must specify material, origin, and verifiable share

4. Future Performance Claims (6 terms) — Annex I, point 4

Annex I, point 4 (as amended) bans environmental claims about future performance unless the claim is supported by a clear, time-bound, verifiable implementation plan with regular independent monitoring. Generic future-aspiration language is banned regardless of corporate intent.

• Will be sustainable by [year] — banned without published, monitored roadmap
• On track to net zero — banned without verified third-party progress audit
• Committed to [environmental goal] — banned as standalone claim, must include the plan
• Working towards [environmental goal] — same prohibition
• Aiming for zero waste — banned without quantified, time-bound waste reduction plan
• Transitioning to [renewable energy / circular model] — must include published transition plan

5. Self-Created Labels & Certifications (5 terms) — Annex I, point 2a

Annex I, point 2a — also added by Directive 2024/825 — prohibits the display of a sustainability label that is not based on a certification scheme or established by public authorities. Self-created badges, brand-internal trust marks, and visual cues that imply third-party verification are banned across all consumer-facing surfaces.

• Self-awarded eco-label — banned outright; only third-party certifications qualify
• Unverified trust mark — banned regardless of design
• Own sustainability score — internal scoring presented as authority is banned
• Green checkmark / leaf icon — visual cues implying certification are banned
• Approved by [own brand] — circular endorsement, banned

6. Comparative Claims (6 terms) — Article 6 + Annex I, point 2b

Comparative environmental claims ("greener," "more sustainable," "better for the planet") are restricted unless the comparison is based on equivalent products, identical methodology, and a transparent reference baseline. Annex I, point 2b prohibits comparative claims that cannot specify the comparator and the methodology on the same medium.

• Greener than [competitor / category] — banned without published methodology and like-for-like comparison
• More sustainable — vague comparator, banned
• Better for the planet — categorical claim without baseline, banned
• Eco-friendlier — comparative variant of generic claim, doubly banned
• Best in class — banned without independent benchmarking and class definition
• Industry-leading sustainability — banned without third-party industry-wide assessment

7. Planned Obsolescence Triggers (7 terms) — Annex I, points 23d–23g

Directive 2024/825 added new Annex I points (23d, 23e, 23f, 23g) banning practices that induce premature replacement of products. Marketing language that pressures consumers to discard a still-functional product — even when the marketing presents replacement as "the eco-conscious choice" — is banned outright. This category is frequently missed by competitor lists because it sits at the intersection of consumer law and environmental law.

• Upgrade now — your model is no longer supported — banned when used to push replacement of functional goods
• Replace now for best results — banned when the existing product is not functionally compromised
• Your accessory is incompatible — banned when interoperability was not previously disclosed
• Software update required — banned when the update artificially restricts existing functionality
• Time to upgrade — banned in marketing for products with no defined end-of-life
• End of life — replace your product — banned without independent end-of-life determination
• Your filter needs replacing — banned without clear performance threshold and disclosure

8. Legal Requirements Sold as Features (8 terms) — Article 7 misleading omission

Presenting a legal requirement as a special feature of a product is a misleading commercial practice under Article 7 of the consolidated UCPD. "BPA-free" cannot be advertised as a virtue if BPA is already restricted in the product category; "CE certified" is a baseline requirement, not a feature. This category catches a large share of greenwashing on cosmetics, electronics, and toys.

• BPA-free — restricted when BPA is already prohibited in the product category (e.g. baby bottles)
• CE certified — banned as a marketing feature; CE marking is mandatory, not optional
• 2-year warranty — restricted; the EU statutory minimum is two years, not a brand benefit
• No animal testing — restricted in cosmetics where animal testing is already prohibited under EU Regulation 1223/2009
• REACH compliant — banned as a feature; REACH compliance is legally required
• RoHS compliant — banned as a feature; RoHS is mandatory for electronics in the EU
• CLP labelled — banned as a feature; CLP labelling is required for hazardous substances
• Phthalate-free — restricted when the relevant phthalates are already banned (REACH Annex XVII)

How to Use This List

The 82-term list is most useful as a self-audit reference. For each term that appears anywhere on your store — product page, collection title, homepage banner, theme default text, email template — choose one of three responses: (1) remove the term entirely, (2) qualify it with same-medium evidence and certification, or (3) replace it with a quantified alternative. The Banned & Restricted Green Claims page shows the exact compliant rewrite for each term.

1. Start with site-wide claims — homepage banners, theme defaults, footer text, category headers — because these multiply across thousands of impressions
2. Audit product descriptions next, paying special attention to copy imported from suppliers via CSV or apps like DSers and Spocket
3. Check marketing email flows — the Directive covers all consumer-facing surfaces, including Klaviyo and Shopify Email automation
4. Review packaging copy described online — the digital description of physical packaging is also in scope
5. Re-scan after every product launch and supplier import to catch newly introduced violations

Why Other Lists Stop at 28

Public lists circulating online — including the lists published by competitor scanners — typically cover the 28 most obvious entries: the headline generic terms ("eco-friendly," "green," "sustainable") and the most-litigated carbon terms ("carbon neutral," "climate neutral," "net zero"). Those 28 terms are real, but they are a fraction of the actual prohibition surface. The remaining 54 terms — future-performance language, self-created labels, comparative claims, planned-obsolescence triggers, and legal-as-feature claims — are equally enforceable, and several of the highest-profile 2025 enforcement actions (FlixBus, TotalEnergies, the AGCM fashion investigations) hit categories that no 28-term list covers. The full 82-term reference is maintained on the EcoClaim banned-words page.

Frequently Asked Questions