FAQGreen ClaimsEU

UCPD and Directive (EU) 2024/825 overlap How the Green Claims proposal adds detail

Directive (EU) 2024/825 amends the Unfair Commercial Practices Directive for recurring greenwashing practices. The Green Claims proposal would add detailed rules for voluntary explicit environmental claims and labels.

This FAQ separates the adopted amendments, which apply from 27 September 2026, from the unadopted Green Claims proposal.

Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
Overview

Directive (EU) 2024/825 is adopted and amends the Unfair Commercial Practices Directive () and Consumer Rights Directive. Member States had to transpose it by 27 March 2026 and must apply those measures from 27 September 2026. Its environmental-claim rules cover misleading claims, future environmental performance, sustainability labels, whole-product and whole-business overreach, and offset-based product climate claims. The separate Green Claims file remains an unadopted proposal for more detailed substantiation, communication, labelling-scheme, and verification rules.

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5 of 5 questions
Question 1

What did Directive (EU) 2024/825 change for environmental claims under the UCPD?

Directive (EU) 2024/825 adds environmental-claim definitions and specific practices to the . It defines an environmental claim broadly as a non-mandatory commercial message or representation that states or implies a positive, zero, lower, or improving environmental impact for a product, product category, brand, or trader.

From 27 September 2026, several practices become named controls. A is prohibited when the trader cannot demonstrate relevant to the claim. A is prohibited if it is not based on a qualifying certification scheme or established by a public authority. A future environmental performance claim may be misleading unless it has clear, objective, publicly available, verifiable commitments in a detailed and realistic implementation plan with measurable, time-bound targets, allocated resources, and regular independent third-party verification whose findings are available to consumers.

The legal tests are not all the same. The sustainability-label rule, unsupported generic-claim rule, whole-product or whole-business overreach rule, and offset-backed product greenhouse-gas rule are added to Annex I, so they are prohibited in all circumstances from the application date. Future environmental performance is added to Article 6(2), so authorities assess the claim and its plan case by case.

  • From 27 September 2026, generic terms such as eco-friendly, green, climate friendly, or biodegradable require relevant to the claim unless a clear and prominent specification on the same medium makes the message a specific claim.
  • From that date, a claim cannot cover the entire product or the trader's entire business when its basis concerns only one product aspect or one business activity.
  • From that date, a product greenhouse-gas claim cannot claim a neutral, reduced, or positive environmental impact based on offsetting.
  • A future environmental performance claim may be misleading if it lacks a public, measurable, resourced implementation plan and regular independent verification.
  • Sustainability labels require a qualifying certification scheme or establishment by a public authority.
Question 2

When do the Directive (EU) 2024/825 amendments apply?

Directive (EU) 2024/825 entered into force in 2024, but its transposition and application dates are later. Member States had to adopt and publish national measures by 27 March 2026 and must apply them from 27 September 2026.

Before relying on a national remedy or enforcement route, check the implementing law in the relevant Member State. The directive sets the EU deadline, while national legislation supplies the local text, authority, procedure, and sanctions.

  • 27 March 2026: deadline for Member States to adopt and publish implementing measures.
  • 27 September 2026: date from which Member States must apply those measures.
  • National check: confirm the implementing act and competent authority in every Member State where the claim is used.
Question 3

How does the Green Claims proposal add to those UCPD rules?

The Green Claims proposal would add specific rules for voluntary explicit environmental claims and environmental labelling schemes. The Commission proposal describes substantiation, communication, and verification rules that would complement the changes. The Council general approach also adds detail for explicit environmental claims and environmental labels.

The , as amended by Directive (EU) 2024/825, identifies unfair or misleading practices and adds specific prohibitions. If adopted in the form of the cited negotiating texts, the Green Claims proposal would require the trader generating a covered explicit environmental claim to document an assessment, communicate specified information, and complete the applicable verification before using the claim or label, subject to its scope and exceptions.

  • layer: unfair-practice rules and prohibitions for consumer-facing claims and labels.
  • Green Claims proposal layer: claim substantiation, communication requirements, environmental labelling scheme rules, and verification mechanics.
  • Overlap rule from the Council general approach: enforcement can still assess a commercial practice as unfair even where the claim has Green Claims documentation or a verifier assessment.
  • Legal status as of 25 July 2026: EUR-Lex still lists procedure 2023/0085(COD) as ongoing, and no final Green Claims directive is cited here.
Question 4

Which claims should be checked under both layers?

Check both layers when a voluntary business-to-consumer message is explicit and environmental. Examples include packaging recycled-content claims, bee-friendly or nature-positive claims, carbon compensated ride claims, claims to reduce CO2 by a future date, product-level climate neutrality claims, and labels or trust marks that imply environmental superiority.

Start with the and the Directive (EU) 2024/825 amendments that apply from 27 September 2026: is the claim generic, future-looking, broader than the evidence, offset-based at product level, or tied to a ? Then use the Green Claims proposal as planning material. If the claim would fall within its scope and no more specific Union rule governs it, identify the assessment, communication, labelling-scheme, and verification evidence the cited proposal text would require.

  • Generic phrase test: is the claim specific on the same medium, or is it a broad term such as green, eco-friendly, sustainable, or biodegradable?
  • Future-performance test: does the claim have a detailed, realistic implementation plan with measurable and time-bound targets?
  • Scope test: does the public message match the actual product, life-cycle stage, business activity, or environmental characteristic being evidenced?
  • Label test: is the trust mark based on a public-authority scheme or a certification scheme with objective third-party monitoring?
  • Green Claims proposal test: is there science-based substantiation, communication of relevant claim information, and independent verification where the proposal would require it?
Question 5

How should teams treat labels, offsets, and future claims?

Prepare affected claims for the Directive (EU) 2024/825 application date of 27 September 2026. Review generic environmental language, sustainability labels, offset-based product climate claims, whole-product or whole-business wording, and future environmental performance claims against the adopted text and the relevant national implementing law.

Do not present Green Claims proposal details as settled law. As internal planning, a claim file can identify the claim, environmental characteristic, product or trader boundary, data and method, relevant trade-offs, communication text, and any verifier or labelling-scheme step that the cited negotiating text would require.

Use a two-stage decision. First apply the current and the national implementing law for Directive (EU) 2024/825 in the consumer's Member State, including the Annex I rules from 27 September 2026. Then, only for proposal planning, test whether the voluntary explicit claim or label would enter Green Claims scope, whether another Union act supplies specific rules, and which substantiation, communication, or verification route the cited negotiating text describes.

  • For generic claims, either make the claim specific and prominent on the same medium or document relevant to the broad term.
  • For labels, verify the public-authority or certification-scheme basis, including objective third-party monitoring and public terms.
  • For future claims, maintain the plan, targets, resources, verification findings, and consumer-facing availability of the commitments.
  • For offsets and carbon credits, separate the company's or product's own emissions reductions from credits, removals, or contributions outside the value chain.
  • For Green Claims proposal planning, keep substantiation and communication evidence reviewable before the claim goes live, but label each proposal-based control and do not assign a final legal deadline.
  • Reassess when the claim, qualification, label criteria, certification or monitoring status, product or business boundary, target plan, verifier findings, market, national implementing law, or Green Claims procedure status changes.
Recommended next step

Review environmental claims before publication

Use Sorena to separate adopted UCPD controls from proposal-based Green Claims evidence requirements before a claim, label, or campaign goes live.

Primary sources

References and citations

eur-lex.europa.eu5 citations
Referenced sections
  • Adopted EU directive amending the UCPD and Consumer Rights Directive; supports the FAQ's statements about generic environmental claims, future environmental performance claims, sustainability labels, offset-based product claims, and amended UCPD definitions.
  • Adopted directive amending the UCPD with definitions for environmental claims, generic environmental claims, sustainability labels, certification schemes, recognised excellent environmental performance, and named prohibited greenwashing practices.
  • Article 4 sets the 27 March 2026 transposition deadline and the 27 September 2026 application date.
Show 2 more
  • Adopted UCPD amendments covering generic environmental claims, future environmental performance claims, sustainability labels, whole-product or whole-business overreach, and offset-based product climate claims.
  • Adopted directive supporting immediate review of generic environmental claims, sustainability labels, future-performance claims, and offset-based product greenhouse-gas claims.
"Making a generic environmental claim for which the trader is not able to demonstrate recognised excellent environmental performance"
More quoted passages
"They shall apply those measures from 27 September 2026."
"without clear, objective, publicly available and verifiable commitments"
"Displaying a sustainability label that is not based on a certification scheme"
data.consilium.europa.eu3 citations
Referenced sections
  • Council general approach supporting the FAQ's discussion of how the Green Claims text would complement Directive (EU) 2024/825 and add verification, substantiation, and environmental-label detail.
  • Council text stating that the Green Claims Directive aims to complement Directive (EU) 2024/825 and apply detailed rules to explicit environmental claims, environmental labelling schemes, and labels.
  • Council general approach supporting proposal-stage treatment of Green Claims details on explicit claims, environmental labels, carbon-credit-related climate claims, substantiation, and verification.
"This Directive should complement the requirements set out in that Directive"
More quoted passages
"Explicit environmental claims should be substantiated by the trader generating them."
eur-lex.europa.eu2 citations
Referenced sections
  • Commission proposal supporting the FAQ's proposal-stage statements about Green Claims as the lex specialis layer for substantiation and communication of voluntary environmental claims.
  • Commission proposal explaining the Green Claims file as lex specialis for substantiation and communication of voluntary environmental claims, complementing UCPD changes.
"This proposal provides more specific rules (lex specialis) and complements the proposed changes"
ec.europa.eu2 citations
Referenced sections
  • Commission Q&A supporting the FAQ's examples of covered voluntary green claims and the proposal's ex-ante substantiation and verification framing.
  • Commission Q&A describing the proposal's coverage of voluntary explicit green claims, life-cycle approach, environmental labelling schemes, ex-ante verification, and examples such as recycled-content, bee-friendly, carbon-compensated, and future CO2 reduction claims.
"must be substantiated and this substantiation be verified ex-ante"
eur-lex.europa.eu
Referenced sections
  • Official procedure record identifying the Green Claims file as an ongoing ordinary legislative procedure rather than an adopted directive.
"Ongoing"
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