Product Compliance Resources provided by ProductIP


Do you like being "greenwashed"

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.


Greenwashing misleads consumers into thinking that a product or brand is environmentally friendly or “Green”, when in fact it is not. Some products come with false promises, misleading information, or claims. Consumers are unable to compare products fairly and cannot make good sustainable choices.

Directive (EU) 2024/825

The European Commission wants to put a stop to this and has therefore amended the Directives concerning unfair business-to-consumer commercial practices (2005/29/EC) and consumer rights (2011/83/EU) with ‘anti-greenwashing’  Directive (EU) 2024/825.
From 27 September 2026, before using a green claim or logo that is currently not covered by other EU rules, a trader must collect all evidence to substantiate their claims. In addition, an independent verifier must check if the evidence is adequate, and it meets all the requirements of the directive.
This new directive will help consumers make better-informed choices and thus stimulate the demand for more sustainable and durable goods. It prohibits misleading consumers about a product’s environmental or social characteristics, as well as its circularity aspects, such as durability, repairability, or recyclability.

Prohibited misleading commercial practices

  • Design a product with a limited lifespan, so-called planned obsolescence.
  • Withhold information that a software update will have negative impact on the functioning of a product.
  • Claim that a software update is a security update while update relates only to features for improved functionality.
  • Sell products that are expected to last longer than they actually do.
  • Indicate that the product can be repaired if repair is not possible.
  • Inducing a consumer to replace consumables of a product earlier than necessary, such as printer ink cartridges.
  • Advertising benefits that are irrelevant and not directly related to any environmental claim or sustainability label of the product or business.
  • Marketing that a product is free of a specific chemical when that substance is already banned.

Environmental claims

An environmental claim is a voluntary claim that states or implies that a product, brand or trader has a positive or zero impact on the environment or is less damaging to the environment than competing products. They may appear as audiovisual media, text, images, graphics or symbols but also as labels, brand names, company names or product names. It has to be clear if an environmental claim relates to the entire product or the trader’s entire business or only to a specific part. 

From 2026, environmental claims may only be made when it has been verified by an independent third party. Some examples of correct green claims could be:

  • “Packaging made of 30% recycled plastic”
  • “Company’s environmental footprint reduced by 20% since 2015”
  • “CO2 emissions linked to this product halved as compared to 2020.

Sustainability labels

As most sustainability labels of products, processes or businesses are voluntary, there are currently around 230 sustainability labels and 100 green energy labels in the EU. By making it mandatory for a sustainability label, trust mark, or quality mark to be based on a certification scheme, their transparency and credibility are demonstrated and guaranteed.

Some trusted schemes are:

  • The voluntary EU Ecolabel is the official European eco-label for non-food products and services. It is supported by all EU member states, Norway, Liechtenstein and Iceland. Products with this logo have a guaranteed low environmental impact because they are checked for compliance with the EU Ecolabel criteria by independent competent bodies. The EU Ecolabel scheme is based on Regulation (EC) 66/2010 and the standard for Type I environmental labelling, ISO 14024.
  • The voluntary EU Eco-management and audit scheme (EMAS) is developed for companies to evaluate, report, and improve their environmental performance, save energy, and optimise resource usage. An accredited third party, certifies the company management system according to Regulation (EC) 1221/2009.
  • The Nordic Ecolabel or Nordic swan is the official sustainability ecolabel for products from the Nordic countries (Denmark, Finland, Iceland, Norway and Sweden). The certification scheme considers the entire life cycle, from raw materials and production to use, recycling and disposal.
  • The Dutch environmental quality label Milieukeur of SMK for sustainable non-food products, such as concrete products, fire extinguishers or car cleaning products. Milieukeur aims for a healthy balance between the various sustainability themes, so that its criteria relate to the whole life cycle of the product or service.

More credible ecolabels can be found on the Global Ecolabelling Network (GEN)

How serious is Brussel?

European Parliament Committee on the Internal Market and Consumer Protection (IMCO) adopted the new directive unanimously. Of the 705 elected members of the plenary, 628 voted, of which 593 in favour.

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