EU Green Claims Directive
The complete guide for e-commerce businesses. Understand your obligations under EU Directive 2024/825, avoid penalties of up to 4% of annual turnover, and ensure your environmental claims comply before September 27, 2026.
4%
Max fine as % of annual turnover
53%
Of green claims found vague or misleading (EU Commission, 2020)
...
Days until enforcement begins
What Is the EU Green Claims Directive?
Directive 2024/825 and COM(2023)166
The EU's crackdown on greenwashing operates through two complementary pieces of legislation that every business making environmental claims to European consumers must understand.
Directive 2024/825 — Empowering Consumers for the Green Transition
Adopted in February 2024 and published in the Official Journal on March 6, 2024, this directive amends two existing consumer protection laws: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). It introduces specific prohibitions against misleading environmental claims and unsubstantiated sustainability labels. Member states must transpose it into national law by March 27, 2026, with enforcement beginning September 27, 2026.
The Green Claims Directive — COM(2023)166
Proposed by the European Commission in March 2023, this companion directive was designed to set detailed substantiation and verification requirements for environmental claims. It would have required businesses to back claims with scientific evidence and third-party verification. In June 2025, the Commission withdrew this proposal following political concerns about its scope, particularly its potential impact on micro-enterprises. However, the existing framework under Directive 2024/825 remains fully in force and provides substantial enforcement powers against greenwashing.
Timeline & Key Dates
From proposal to enforcement
March 2023
Commission proposals published
The European Commission published the proposal for the Green Claims Directive (COM(2023)166) alongside the Empowering Consumers proposal, both aimed at tackling greenwashing in the EU single market.
February 2024
Political agreement reached
The European Parliament and Council reached political agreement on the Empowering Consumers for the Green Transition Directive, finalizing the text after trilogue negotiations.
March 6, 2024
Directive 2024/825 enters into force
Published in the Official Journal of the European Union, the directive formally entered into force 20 days after publication, starting the transposition clock for member states.
June 2025
Green Claims Directive (COM(2023)166) withdrawn
The Commission withdrew the standalone Green Claims Directive proposal following political pressure over its scope. The Empowering Consumers Directive remains unaffected.
March 27, 2026
Member state transposition deadline
All 27 EU member states must transpose Directive 2024/825 into their national legislation by this date. Individual countries may introduce stricter measures.
September 27, 2026
Enforcement begins
National authorities begin enforcing the new rules. Businesses making non-compliant environmental claims face fines, product bans, and public naming.
Who Is Affected?
Scope of the directive
The directive applies to any business making environmental claims to consumers in the EU, regardless of where the business is headquartered. If you sell to EU consumers and make green claims, you are in scope.
E-commerce stores
Product descriptions, marketing pages, and ads with environmental claims
Brands & manufacturers
Packaging claims, sustainability pages, and product labels
Retailers & marketplaces
Third-party seller claims displayed on your platform
Service providers
Carbon-neutral shipping, eco-friendly services, and green subscriptions
Country-specific enforcement guides
Key Requirements
What the law demands of environmental claims
Under Directive 2024/825, environmental claims must meet strict criteria. Vague, unsubstantiated, or misleading claims are explicitly prohibited.
Specific, not vague
Claims must refer to a specific, clearly identified environmental benefit. Generic terms like "eco-friendly," "green," or "good for the planet" are prohibited unless substantiated with specific evidence.
Substantiated by evidence
Businesses must be able to demonstrate the truthfulness of their claims based on widely recognized scientific evidence, using accurate information and taking into account relevant international standards.
Not based solely on offsetting
Claims of overall reduced environmental impact based exclusively on carbon offsetting schemes are banned. You cannot claim a product is "carbon neutral" purely because you purchased carbon credits.
Sustainability labels must be verified
Any sustainability label used must be based on a certification scheme or established by public authorities. Self-made sustainability labels that are not based on a third-party certification scheme are prohibited.
Claims about future performance
Environmental claims about future performance must include clear, objective commitments with measurable targets and a detailed, accessible implementation plan with independent monitoring.
Clearly communicated
All claims must be presented in a way that is not misleading to average consumers, with supporting evidence easily accessible at the point of sale.
Penalties & Enforcement
The cost of non-compliance
The directive gives member states broad discretion in setting penalties, but establishes minimum enforcement standards. The consequences of non-compliance are designed to be dissuasive and proportionate.
4%
Maximum fine as percentage of annual turnover in affected member states
€3.5M+
Fixed fines possible where turnover data unavailable (varies by member state)
Fines of up to 4% of annual turnover in the affected member state(s)
Confiscation of revenue gained through misleading claims
Temporary or permanent bans on placing products on the market
Public naming of non-compliant businesses
Exclusion from public procurement tenders
Cross-border enforcement via the Consumer Protection Cooperation (CPC) Network
CPC Network: Cross-border enforcement
The Consumer Protection Cooperation (CPC) Network enables coordinated enforcement across all EU member states. National consumer protection authorities can share information, conduct joint investigations, and take coordinated action against businesses making misleading environmental claims. This means a greenwashing violation identified in one country can trigger enforcement across the entire single market.
Don't wait for a fine.
EcoClaim estimates your penalty exposure based on your actual claims and shows you exactly what to fix.
Check your risk free →Banned Practices
Specific prohibitions added to the Unfair Commercial Practices Directive
Directive 2024/825 adds a range of specific environmental claim practices to the existing EU blacklist of unfair commercial practices. These are banned outright, with no defense possible.
Generic environmental claims without proof
Example: "Eco-friendly," "green," "sustainable," "climate-friendly" used without specific, verifiable evidence
Unsubstantiated overall environmental impact claims
Example: Claiming a product has a positive or neutral environmental impact overall when this cannot be demonstrated
Carbon-neutral claims based solely on offsetting
Example: "Carbon neutral" or "climate positive" when achieved only through purchasing carbon credits
Self-certified sustainability labels
Example: Displaying a green trust mark or eco-label that was not established by an independent third-party certification scheme or public authority
Misleading durability claims
Example: Implying a product lasts longer than it does, or hiding information about features that limit durability (e.g., "designed to last" without evidence)
False claims about reparability
Example: Suggesting a product can be repaired when it cannot, or concealing information about repair limitations
How to Comply
Practical steps for e-commerce businesses
Compliance requires a systematic approach. Here is a practical framework for e-commerce businesses preparing for the September 2026 enforcement date.
Audit all environmental claims
Conduct a full inventory of every environmental claim across your website, product descriptions, packaging, marketing materials, and advertising. This includes claims on product pages, category pages, homepage banners, email campaigns, and social media.
Gather substantiating evidence
For each claim identified, collect scientific evidence, test results, certifications, or lifecycle analyses that support it. If no evidence exists, the claim must be removed or revised.
Replace vague language with specific claims
Convert generic claims into specific, measurable statements. Instead of "eco-friendly packaging," specify "packaging made from 80% post-consumer recycled cardboard, FSC-certified." Every claim should be testable.
Verify sustainability labels
Ensure all sustainability labels, trust marks, and eco-badges are from accredited third-party certification schemes or public authorities. Remove any self-certified labels.
Review carbon offsetting claims
If you use carbon offsetting, ensure it is not the sole basis for your environmental claims. Separate genuine emission reduction efforts from offset-based claims. Avoid "carbon neutral" unless you have evidence beyond offsets.
Implement ongoing monitoring
Compliance is not a one-time exercise. Set up processes to review new product listings, marketing copy, and third-party seller claims on an ongoing basis. Automated tools can dramatically reduce this burden.
Implementation varies by country. Different member states may introduce additional requirements or stricter penalties. Check our country-specific compliance guides for detailed guidance on individual EU markets.
EcoClaim automates this entire process.
Our AI scans your pages, flags non-compliant claims, and generates compliant alternatives — in under 60 seconds.
Scan your store free →How EcoClaim Helps
Automated compliance for e-commerce
EcoClaim automates the most time-consuming parts of green claims compliance, so you can focus on running your business while staying on the right side of EU law.
Automated store scanning
EcoClaim crawls your entire online store, identifying every environmental claim across product pages, descriptions, and marketing copy.
AI-powered risk analysis
Each claim is analyzed against the requirements of Directive 2024/825 and flagged by risk level: non-compliant, needs review, or compliant.
Compliant alternatives
For every flagged claim, EcoClaim suggests specific, regulation-compliant language that preserves your marketing message while meeting legal requirements.
Ongoing monitoring
Continuous monitoring catches new claims added by your team or third-party sellers before they become compliance risks. Get alerts when issues are detected.
Directive 2024/825 does not operate in isolation. Several other EU regulations interact with green claims requirements, creating a comprehensive framework that businesses must navigate together.
Right to Repair Directive (EU 2024/1799)
In forceIn force since July 2024, this directive gives consumers the right to have products repaired rather than replaced. It directly intersects with green claims because businesses can no longer market products as "durable" or "long-lasting" while making repair difficult or impossible. Manufacturers must provide spare parts and repair information for a reasonable period. Misleading repairability claims are already covered by EMPCO-A5 of Directive 2024/825.
Ecodesign for Sustainable Products Regulation (ESPR)
Phased 2025–2030The ESPR extends ecodesign requirements beyond energy-related products to nearly all physical goods sold in the EU. Its most significant feature for e-commerce is the Digital Product Passport (DPP), which will require products to carry a machine-readable data carrier linking to standardised sustainability information. This includes materials, carbon footprint, repairability score, and recycled content. DPPs will make it far harder to make unsubstantiated green claims, as verified data will be readily accessible. Phased implementation runs from 2025 to 2030 depending on product category.
Corporate Sustainability Reporting Directive (CSRD)
Phased from 2024The CSRD requires companies to report on their environmental impact using European Sustainability Reporting Standards (ESRS). While primarily a corporate reporting obligation, CSRD data creates a factual baseline against which product-level green claims can be verified. If a company's CSRD report shows increasing emissions while its marketing claims "climate-friendly" products, this inconsistency can be used as evidence of greenwashing. Phased in from 2024 for large public-interest entities, extending to smaller companies by 2026.
EU AI Act (EU 2024/1689) — Article 50
From August 2026Article 50 of the AI Act introduces transparency requirements for AI-generated content, including marketing materials. From August 2026, businesses using AI to generate or modify marketing copy — including environmental claims — must disclose that the content was AI-generated. This is particularly relevant for e-commerce businesses using AI tools to write product descriptions, as AI-generated green claims carry the same legal liability as human-written ones, with the additional requirement of AI transparency labelling.
Key Case Law
The German Federal Court of Justice (BGH) ruled that "klimaneutral" (climate neutral) claims are misleading if they do not clearly explain directly in the advertisement itself whether neutrality is achieved through actual emission reductions, compensation/offsets, or a combination. The explanation must not be hidden behind QR codes, footnotes, or external links. This landmark ruling established that offsetting alone is not equivalent to genuine emission reduction and set the standard for carbon-neutral claims across Germany.
The District Court of Amsterdam (ECLI:NL:RBAMS:2024:1512) found that 15 of 19 KLM green advertising claims were misleading. The court established a critical principle: even if individual statements contain some truth, the overall impression of a page matters. Claims that paint an "overly rosy picture" of environmental impact are misleading, even when technically partially accurate. This ruling applies the ACM's five-point test: claims must be truthful, substantiated, fair, concrete, and complete.
Frequently Asked Questions
Does the Green Claims Directive apply to non-EU businesses?
Yes. Directive 2024/825 applies to any business making environmental claims directed at EU consumers, regardless of where the business is incorporated. If you sell products or services to customers in the EU and make green claims in your marketing, you must comply.
Can I still say my product is "sustainable"?
Generic terms like "sustainable," "eco-friendly," or "green" can only be used if you can substantiate them with specific, verifiable evidence. A blanket "sustainable product" claim without explanation of what makes it sustainable is likely to be considered misleading under the new rules. Instead, make specific claims: "Made from 90% recycled materials" is far stronger than "sustainable."
Is "carbon neutral" still allowed?
Claims of carbon neutrality or reduced environmental impact that are based exclusively on carbon offsetting are banned. You can still reference offset programs, but they cannot be the sole basis for an environmental claim. You must demonstrate genuine emission reductions within your own operations first.
What happens if I don't comply by September 2026?
You face potential fines of up to 4% of your annual turnover in the affected member state(s), along with product bans, public naming, exclusion from public tenders, and confiscation of revenue gained through misleading claims. National enforcement authorities can also pursue cross-border action through the CPC Network.
Does the withdrawal of the Green Claims Directive (COM(2023)166) mean I don't need to worry?
No. The withdrawal of the standalone Green Claims Directive proposal in June 2025 does not affect Directive 2024/825 (Empowering Consumers for the Green Transition), which is already adopted, transposed, and will be enforced from September 27, 2026. The anti-greenwashing consumer protection framework remains fully in force.
How many claims does the average e-commerce store have?
This varies significantly by industry and store size, but most online stores have environmental claims embedded across product descriptions, category pages, about pages, and marketing banners. It is common for stores with 100+ products to have hundreds of individual claims that need review. EcoClaim's automated scanning can identify all of them in minutes rather than the weeks manual review would require.
Are your green claims compliant?
Scan your online store for free and get an instant compliance report. Identify risky claims before enforcement begins on September 27, 2026.
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