The European Commission has published a Questions and Answers document on Directive (EU) 2024/825, which introduces stricter rules on environmental claims and sustainability labels. The new requirements will apply from 27 September 2026 and will affect companies that communicate the environmental characteristics of their products or business activities to consumers.
Companies should review environmental information presented:
- on product packaging and labels;
- on websites and online stores;
- in advertising and promotional materials;
- in product and brand names;
- through logos, seals and other sustainability labels.
Particular caution is required when using generic claims such as “environmentally friendly”, “green”, “eco-friendly”, “nature-friendly”, “climate-friendly” or “biodegradable” if they are not clearly specified and supported by the required evidence.
Any qualification of an environmental claim must be presented clearly and prominently on the same medium. If a claim appears on the packaging, its essential explanation should not be available only on a website. More specific and verifiable statements, such as information about recycled content or a demonstrable reduction in energy consumption, are generally more appropriate.
Companies should also pay attention to visual presentation. Green leaves, trees, water drops, images of nature and green colour schemes may, depending on the context, be perceived as implicit environmental claims or sustainability labels.
Proprietary environmental seals and sustainability labels may only be displayed if they have been established by a public authority or are based on a certification scheme that meets the applicable requirements. A logo of a business partner or another organisation should therefore not be presented as certification of a product’s environmental characteristics unless it genuinely performs that function.
Companies must also ensure that compliance with a legal requirement is not presented as a distinctive environmental benefit of their product or business. Fulfilling extended producer responsibility obligations or working with a producer responsibility organisation does not in itself constitute environmental certification of a product or its packaging.
The new rules will also apply to existing products and so-called old stock. Companies should therefore review packaging that has already been manufactured, ordered, distributed or placed on shop shelves. The European Commission identifies possible practical solutions such as covering a non-compliant claim with a sticker or providing additional explanatory information at the point of sale.
The European Commission’s document does not constitute a legally binding interpretation. However, it provides important guidance on how the new rules are expected to be applied.
Recommendation for companies: review your packaging, websites, online stores, advertising and environmental labels before 27 September 2026.
European Commission Questions and Answers on Directive (EU) 2024/825
