EU rules on environmental claims for products

Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC

Update

The European Union (EU) has set rules to prevent environmental or social claims on products that are unsubstantiated or could mislead consumers. It has identified several categories of claims that are not permitted. By eliminating unfair claims, the EU aims to help consumers take better-informed decisions about products that will support the transition to a more sustainable and circular economy.

Impacted Products

All packaged products

What is changing?

To protect European consumers from misleading and unsubstantiated claims about the environmental or social characteristics of products (e.g. durability, recyclability), the EU has prohibited the following types of claims.

Unevidenced and generic claims

Claims that by purchasing a product, consumers are contributing to a sustainable economy are not permitted unless they are supported by clear, objective, and publicly available evidence.

These claims must be verified by a third party that is experienced in environmental issues and can monitor the supplier’s progress towards achieving the objectives communicated on the product’s packaging.

Generic environmental claims that cannot be demonstrated are not allowed, such as “environmentally friendly”, “eco-friendly”, “green”, “climate friendly”, “carbon friendly”, “energy efficient”, “biodegradable”, or “biobased”.

The same applies to claims about a product’s neutral, reduced, or positive impact on the environment in terms of greenhouse gas emissions, including “climate neutral”, “carbon positive”, “climate net zero”, “climate compensated”. These are only permitted if they are based on a lifecycle impact of the product.

Product-unrelated claims

Claims highlighting benefits that are irrelevant and unrelated to the product are not allowed, for example claiming that bottled water is gluten-free, or that paper sheets are plastic-free.

Unjustified product comparison

Comparative claims regarding a product’s environmental or social characteristics, or its circularity attributes (such as durability, reparability, or recyclability), are only permitted if they are supported by information about the method of comparison, the products compared, and their suppliers; and if the measures to update this information are shared.

Use of unregulated sustainability labels

Sustainability labels that are not based on a certification scheme, or that have not been established by public authorities, are not allowed. Presentation of the energy value and the amounts of nutrients in products is allowed, provided that EU nutritional information requirements are met (Regulation 1169/2011, Art. 35).

Extending environmental claims to the entire product

Environmental claims must accurately reflect the scope of the benefit being communicated. Claims that imply an environmental benefit applies to the entire product when it relates only to a specific component are not permitted. For example, a product cannot be marketed as “made with recycled material” if, in fact, only the packaging but not the product itself is made of recycled material.

Claiming something that is required by law

It is not allowed to present legal requirements as if they are a benefit specific to a product. For example, a bottle cannot be advertised as not including a specific chemical substance if that substance is forbidden in food packaging.

This rule also applies to mandatory sustainability requirements set by the Packaging and Packaging Waste Regulation 2025/40 (PPWR), Art. 14. Claims relating to packaging properties are only allowed if they:

• improve on the minimum requirements of the PPWR (compliance must be demonstrated in the technical documentation, PPWR Annex VII); and
• specify whether they relate to the packaging unit, part of the packaging unit, or all packaging placed on the market by the operator.

Why?

The EU aims to protect consumers from misleading claims. If environmental claims are not carefully regulated, consumers will not be able to make informed choices in favour of products that could boost the transition towards a more sustainable and circular economy.

Timeline

Directive 2024/825 was adopted on 28 February 2024 and Member States had until 27 March 2026 to transpose it into their national legislation.

The Directive applies from 27 September 2026.

Recommended Actions

In June 2026, a “Common understanding” was published regarding the management of “old stock” – products or packaging that display non-compliant environmental claims or sustainability labels because they were manufactured, ordered, distributed, or placed on retailers’ shelves before the new rules apply on 27 September 2026. The national competent authorities of the Consumer Protection Cooperation (CPC) Network prepared this guidance to support a coherent approach to old stock products.

Background

These rules were introduced in the context of the European Green Deal, the EU’s ambition to transition towards a green society. The rules were proposed in 2020 with the New Consumer Agenda and the Circular Economy Action Plan to promote a more sustainable, resource-efficient, and circular economy.

Directive 2024/825 amends Directive 2005/29/EC on unfair business-to-consumer commercial practices in the internal market.

Resources

Sources