EU Green Claims Directive: What Changes in September 2026

If your product packaging says "eco-friendly," "climate neutral," or "green," you have until September 27, 2026 to either prove it or remove it. That's not a suggestion. It's EU law.

Directive (EU) 2024/825 (the Empowering Consumers for the Green Transition Directive, or ECGT) was adopted in February 2024 and takes effect across all 27 EU member states later this year. It amends the EU's Unfair Commercial Practices rules to ban vague environmental claims and carbon-offset-based product labels.

This article covers exactly what's changing, which claims are banned, and how Digital Product Passports fit into the picture.

What is the ECGT Directive?

The ECGT isn't a standalone green claims law. It amends two existing directives that every EU trader already has to follow:

• The Unfair Commercial Practices Directive (2005/29/EC) - the EU's main law against misleading marketing
• The Consumer Rights Directive (2011/83/EU) - covering pre-purchase information requirements

The ECGT adds new entries to the UCPD's "blacklist" of practices that are banned in all circumstances. Before this amendment, the blacklist covered things like fake limited offers and hidden advertorials. Now it covers greenwashing too.

Which green claims are banned?

The directive targets three categories of claims. Understanding the distinction matters because the rules are different for each.

1. Generic environmental claims

These terms are banned unless you can demonstrate "recognised excellent environmental performance" or provide specific, verifiable qualifications on the same medium (e.g., on the same label):

• "Eco-friendly" / "environmentally friendly"
• "Green"
• "Nature's friend" / "ecological"
• "Climate friendly" / "carbon friendly"
• "Energy efficient" (without rating data)
• "Biodegradable" / "biobased" (without specifics)

2. Carbon offset claims on products

This is the strictest ban. You cannot claim a product has neutral, reduced, or positive greenhouse gas impact based on carbon offsets. Period. No amount of certification saves these claims:

• "Climate neutral"
• "CO2 neutral certified"
• "Carbon positive"
• "Climate net zero"
• "Climate compensated"
• "Reduced climate impact" (if based on offsets)

You can still invest in carbon credit projects and talk about those investments. What you can't do is put "climate neutral" on a product label because you bought offsets. The EU's position is clear: offsets don't change the product's actual emissions.

3. Unverified sustainability labels

Displaying a sustainability label that isn't based on a third-party certification scheme or established by public authorities is now a blacklisted practice. Self-created "green badges" and internal eco-scores without independent verification are out.

What about the separate Green Claims Directive?

You may have read about a "Green Claims Directive" that would require pre-market verification of all environmental claims. That was a separate proposal (COM(2023) 166) that went through trilogue negotiations but was effectively withdrawn by the Commission in June 2025.

The ECGT Directive (2024/825) is fully adopted and unaffected by that withdrawal. The difference matters:

Penalties: what enforcement looks like

The ECGT is enforced through existing consumer protection law, which already has real teeth. Under the Omnibus Directive (2019/2161), cross-border infringements carry fines of at least 4% of annual turnover or at least EUR 2 million where turnover data isn't available.

And enforcement isn't hypothetical. EU authorities have already been acting on greenwashing, even before the ECGT takes effect:

• H&M (Netherlands, 2023) - agreed to remove "Conscious" and "Conscious Choice" labels from garments and donate EUR 500,000 after the Dutch consumer authority found the terms unsubstantiated
• Shein (Italy, 2025) - fined EUR 1 million for "vague, generic, and misleading" recycling and circularity claims
• Apple (Germany, 2025) - ordered to stop marketing Apple Watch as "first CO2-neutral product" because the forestry offsets backing the claim expire in 2029

Once the ECGT blacklist provisions apply in September 2026, these enforcement actions get easier. Consumer protection authorities won't need to prove claims are misleading on a case-by-case basis. If a claim matches a blacklisted category, it's automatically unfair.

How Digital Product Passports connect to green claims

Here's where DPPs become relevant beyond compliance checkboxes. If you need to substantiate an environmental claim under the ECGT, you need verifiable product data to back it up. That's exactly what a Digital Product Passport provides.

Consider a real scenario:

• Your product label says "Made with 70% recycled polyester." Under the ECGT, that's a specific, substantiable claim.
• Your DPP page shows the material composition breakdown, the supplier certificate for recycled content, and the testing methodology.
• A consumer, retailer, or enforcement authority scans the QR code and verifies the claim in seconds.

The DPP doesn't just satisfy the ESPR requirements. It becomes your evidence trail for every environmental claim on the packaging. One scan, full transparency.

Timeline: what to do before September 2026

A practical packaging audit checklist

Go through your product packaging and marketing materials. For each environmental claim, ask these three questions:

1. Is the claim specific or generic? "Made with 80% organic cotton" is specific. "Eco-friendly" is generic. Generic claims need to go or be replaced with specifics.
2. Is the claim based on carbon offsets? If the word "neutral," "compensated," or "net zero" appears on the product (and it's based on purchasing offsets), remove it. No exceptions.
3. Can you prove it? If challenged, do you have data, certificates, or test results that verify the claim? If not, you need to either get that evidence or drop the claim.

The bottom line

September 2026 isn't a cliff. Brands that replace vague claims with specific, data-backed statements will actually strengthen their marketing. "Climate neutral" (banned) becomes "carbon footprint: 2.4 kg CO2e per unit - scan for lifecycle data" (verifiable, trustworthy, and legal).

The shift rewards brands that have their product data in order. If you're already building DPPs for ESPR compliance, you're most of the way there.