The end of greenwashing?

It’s called by many names: EmpCo, ECGT, the Green Transition Directive… Since 27 September 2026, Directive (EU) 2024/825 has set out to ban vague green claims, “climate neutral” product claims that rely on buying carbon credits, and self-made sustainability labels in EU consumer marketing. So, which practices are now banned? What are the new conditions for net-zero and other future claims? What does it mean for sustainability managers, communication managers and CFOs?

The directive reaches beyond marketing. For carbon management, it shifts the focus from offsetting to reduction: carbon credits can no longer support a product claim of neutral, reduced or positive climate impact. Such claims must rest on the product’s own emissions, and any climate target used in marketing needs a verified plan behind it. For supply chain management, many claims depend on data held by suppliers, such as recycled content, material origin or the emissions of purchased goods. Companies will need reliable supplier data and certifications to prove what they say, so suppliers will feel the new rules too, even though the directive itself only covers business-to-consumer communication.

Avoid greenwashing – and greenhushing

Despite its good intentions, the directive has drawn criticism for making it harder for companies to describe what they do well. Some companies have even responded by going quiet and removing environmental information altogether, a trend known as greenhushing. But remember: the directive does not ask you to stop talking about your progress. It asks you to be specific and to back up what you say. “Eco-friendly bottle” is out. “Bottle made of 75% recycled PET” is in, as long as the data shows it. Companies with reliable data on their emissions, materials and suppliers can still tell a strong sustainability story, and it will be more credible than before. What changes is not what you are allowed to say, but what you need to be able to prove.

What the directive is

The directive, adopted on 28 February 2024, amends the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive. Member States had to transpose it by 27 March 2026 and apply it from 27 September 2026. It covers all business-to-consumer communication: packaging, product and brand names, websites, ads, social media and in-store material.

An environmental claim is any voluntary message, including images, symbols and names, suggesting a product, brand or company is good, better or improving for the environment. A claim is generic when its specification is not given clearly on the same medium. A sustainability label is any voluntary trust mark on environmental or social grounds.

What is now banned in all circumstances

Twelve practices join the UCPD blacklist, meaning they are unfair without any proof that consumers were misled. The key ones for green marketing:

• Generic claims without recognised excellent environmental performance (e.g. EU Ecolabel). Examples: “eco-friendly”, “green”, “climate friendly”, “biodegradable”. Broader terms such as “sustainable” or “responsible” generally cannot rest on an ecolabel alone, because they also imply social characteristics and are difficult for a company to prove.
• Product climate claims based on offsetting. You can’t say a product is climate neutral, low-carbon or climate positive if the claim relies on carbon credits rather than on cutting the product’s own emissions. Examples: “climate neutral”, “CO₂ compensated”, “carbon positive”
• Sustainability labels not based on a certification scheme or set up by a public authority. Example: in-house “green leaf” logos and badges.
• Whole-product or whole-company claims when only one part qualifies. Example: “made with recycled material” when only the packaging is.
• Presenting legal requirements as a distinctive feature. Example: “free from X” when X is banned EU-wide.
• Early-obsolescence practices. Examples: false durability or repairability claims, hidden effects of software updates.

A claim is not generic if it is specified clearly on the same medium: “100% renewable energy used to produce this packaging” is allowed if true. Companies may still report factually on investments in climate projects, as long as they do not imply the product itself is neutral.

Net-zero targets and other future claims

Future claims such as “net zero by 2040” remain allowed, but only with a published, detailed and realistic implementation plan with time-bound milestones, allocated resources and regular checks by an independent expert whose findings are made public. Advertising irrelevant benefits and non-transparent green comparison tools are also caught.

Information duties and enforcement

Traders must also show a harmonised notice on the two-year legal guarantee, a harmonised label for producers’ durability guarantees over two years (Implementing Regulation (EU) 2025/1960), software-update periods, repair information and greener delivery options.

Transposition is uneven: on 28 May 2026 the Commission sent formal notices to 20 Member States, including France, the Netherlands and Sweden. Where national law is late, regulators can still apply existing unfair-practices rules read in line with the directive. For widespread cross-border breaches, national law must allow maximum fines of at least 4% of the trader’s annual turnover in the Member States concerned.  

What it means for your role

• Sustainability manager: You own the evidence behind every claim and the verified transition plan behind every climate target.
• Communication manager: Generic words, green imagery and own labels go; claims must be specific and explained on the same medium, including reused CSRD content.
• CFO: Future claims need funded plans; carbon-credit spend no longer buys a “neutral” product claim; fines and relabelling costs are a real exposure.
• Sustainability reporting manager: Figures and targets in your sustainability report become consumer claims as soon as marketing reuses them, so the two must match. The transition plan you disclose should be the same plan that backs any net-zero claim.
• Auditor: The directive adds no new statutory audit duty, but net-zero and other future claims need regular checks by an independent third-party expert. Expect to be asked to take on that role, and to see clients compare consumer claims with the sustainability data you assure.

What you need to do now

1. Inventory all consumer-facing claims, including names, imagery and social media  
2. Remove blacklisted claims now: “climate neutral” claims that rely on carbon credits, own labels, unqualified “green” or “sustainable”. Fix digital channels first, then phase out packaging.
3. Rewrite the rest as specific, scoped facts, e.g. “bottle made of 75% recycled PET” instead of “eco-friendly bottle”.
4. Keep only credible labels: EU Ecolabel, EMAS, other public labels or independently certified schemes.
5. Check every public climate target for a published, funded, milestone-based plan with independent verification; pull it from marketing until it qualifies (sustainability and CFO).
6. Set a joint approval gate: no claim goes out without sign-off from sustainability, communication and legal, with finance for target-based claims. Ask of every claim: is it specific, true for what it covers, provable today, and based on the product’s own emissions rather than purchased carbon credits?

The new rules are now in full force and cover all consumer-facing communication still in use, including material published before they took effect. How they are enforced will continue to develop as Member States complete transposition. 

If you want to know more about what the directive means for your claims, labels and climate targets, contact Position Green’s advisors. We can help you connect your carbon management and supply chain management to your communication, so that the emissions and supplier data behind each claim hold up, and build the evidence your claims need.