What an EcoClaim Scan Reveals
We scanned a fictional e-commerce store and found 5 violations of the EU Green Claims Directive. This is what EU regulators will check starting September 2026.
GreenLeaf Organics
www.greenleaf-organics.eu · 12 pages scanned
Compliance Score
Estimated Penalty Exposure
€2M revenue in DE → up to in fines
Based on 3 critical violations. Germany fines up to €50k per violation. France up to €100k or 80% of ad spend.
AI Analysis Summary
This store makes several unsubstantiated environmental claims that violate the EU Empowering Consumers Directive (2024/825). Critical issues: carbon-neutral claims based solely on offsets, vague 'sustainable' language without certification, and a misleading sustainability badge with no recognized scheme. Estimated penalty exposure: up to 4% of annual turnover.
Flagged Claims
Flagged Claim
"Our entire collection is 100% sustainable and eco-friendly"
/collections/all
Why this is flagged
Generic environmental claims without verifiable proof
Making a generic environmental claim such as 'eco-friendly', 'green', or 'sustainable' without specific, verifiable evidence is prohibited under Directive 2024/825, Annex I point 2.
Made with GOTS-certified organic cotton (certificate #OC-12345) and FSC-certified recyclable packaging. Our supply chain is audited annually by SGS for environmental compliance.
Flagged Claim
"Carbon neutral since 2023 through our offset partnership with TreePlant Global"
/pages/about-us
Why this is flagged
Environmental claims based solely on carbon offsetting
Claiming carbon neutrality or climate neutrality based on emissions offsetting alone is explicitly prohibited under Directive 2024/825, Annex I point 4a. This was reinforced by the German BGH 'klimaneutral' ruling (June 2024).
We have reduced operational emissions by 40% since 2021 through renewable energy and supply chain optimization (verified by TÜV SÜD, report #ENV-2025-789). Our remaining emissions reduction roadmap targets 60% by 2027.
Flagged Claim
"Certified Sustainable" badge displayed on all product pages without specifying any certification body
/products/organic-face-cream
Why this is flagged
Sustainability labels not based on recognized certification
Displaying a sustainability label or trust mark that is not based on a recognized third-party certification scheme or established by public authorities is prohibited under Directive 2024/825, Annex I point 2a.
Remove the self-created badge. If certified, display the actual certification mark (e.g., EU Ecolabel licence #EU/456/789, valid until 2027) with a link to the certifying body's verification page.
Flagged Claim
"The greenest skincare brand in Europe"
/pages/about-us
Why this is flagged
Comparative environmental claims without clear basis
Making comparative environmental claims ('greenest', 'most sustainable', 'better for the planet than') without providing the comparison methodology, data sources, and scope is misleading under UCPD Articles 6-7 as amended by Directive 2024/825.
Our moisturizer uses 30% less water in production compared to the industry average (Euromonitor 2025 baseline). Independently verified by EcoVadis (score: 72/100, Silver medal).
Flagged Claim
"We will achieve zero waste by 2030"
/pages/sustainability
Why this is flagged
Future environmental performance without commitments
Making claims about future environmental performance without clear, objective, verifiable commitments and targets, and without an independent monitoring system, is prohibited under Directive 2024/825, Annex I point 4.
We aim to reduce packaging waste by 50% by 2028, tracked quarterly against our 2024 baseline (published in our annual sustainability report, audited by Deloitte). Current progress: 22% reduction as of Q1 2026.
Flagged Claim
"Packaged in 100% recyclable materials (FSC-C098765)"
/products/organic-face-cream
Why this is flagged
Specific, verifiable environmental claim
This claim references a specific, recognized certification (FSC) with a verifiable licence number. It makes a narrow, factual statement about packaging material rather than a broad environmental claim.
This claim is compliant. It is specific, verifiable, and backed by a recognized certification scheme.
Country Risk Assessment
Risk based on enforcement intensity, case law, and transposition status.
BGH klimaneutral ruling sets strict precedent. UWG amendments already in force since December 2025. Fines up to €50,000 per violation.
Loi Climat already bans 'carbon neutral' claims since January 2023. DGCCRF actively enforcing. Fines up to €100,000 or 80% of ad spend.
ACM guidelines on sustainability claims in effect. KLM 'Fly Responsibly' ruling (March 2024) sets precedent for misleading green marketing.
CNMC enforcement increasing. Iberdrola vs Repsol greenwashing case raised awareness. Transposition deadline met March 2026.
AGCM has issued fines (Armani €3.5M, Shein €1M). Enforcement growing but less aggressive than DE/FR. Full transposition pending.
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