The EU's new rules on "eco-friendly" claims: a label-run checklist

If your packaging, product detail pages, or ad copy use words like "eco-friendly," "green," or "biodegradable" anywhere in the EU market, there's a compliance deadline worth putting on your calendar. Directive (EU) 2024/825 — formally the directive "amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information" — rewrites what counts as an acceptable environmental claim across the EU. Here's what it actually changes and what to do about it.

What the directive bans

Directive 2024/825 inserts a new point into Annex I of the EU's Unfair Commercial Practices Directive (2005/29/EC) — the list of practices considered unfair "in all circumstances." The new entry bans:

"Making a generic environmental claim for which the trader is not able to demonstrate recognised excellent environmental performance relevant to the claim."

In plain terms: broad, feel-good environmental language is no longer acceptable on its own. If you can't back a claim with recognized proof — an EU Ecolabel or an equivalent standard of "excellent environmental performance" — the claim itself becomes a prohibited practice, not just weak marketing copy.

What counts as "generic"

The directive also adds a definition of generic environmental claim: any environmental claim, written, spoken, or in audiovisual form, that isn't carried on a recognized sustainability label and where the substantiating detail isn't given "in clear and prominent terms on the same medium" as the claim. That second part matters as much as the first — a claim on a product label that points to substantiation buried on a website, in a footnote, or behind a QR code doesn't clear the bar. The specifics need to sit next to the claim itself.

Commonly used terms most exposed under this standard: "eco-friendly," "green," "climate friendly," "climate neutral," and "biodegradable" made without qualification — precisely the kind of shorthand that shows up on cosmetics packaging when a formula happens to be recyclable, plant-derived, or low-waste in one specific respect but the label speaks in absolutes.

Why this lands harder on cosmetics than most categories

Cosmetics copy leans on this shorthand more than most consumer goods categories — "clean," "green," "natural," "planet-friendly" have become default vocabulary for anything with a recyclable cap, a plant-derived surfactant, or a shorter ingredient list. Under the new standard, none of that is disqualifying on its own — the problem is only when the claim is made without recognized proof sitting next to it. A refill pouch, a biodegradable formula, or a reef-safe filter can still be marketed accurately; the label just needs to point to the actual standard the claim rests on rather than leaning on the adjective alone.

The timeline

Per Directive (EU) 2024/825, Article 4(1), EU Member States must adopt and publish their national transposing measures by 27 March 2026, and those national measures must apply from 27 September 2026. That second date is the one that matters for a label audit — it's when enforcement under the transposed national laws actually starts biting in each Member State.

Your pre-deadline checklist

1. Inventory every environmental claim across packaging, PDPs, ads, and social captions sold into the EU — not just the hero claim on the front of pack, ingredient callouts and footer copy count too.

2. For each claim, ask: can I point to a recognized standard? An EU Ecolabel or comparable certification supports a claim; an internal sustainability initiative, on its own, generally doesn't.

3. Move substantiation next to the claim, not to a separate page or a linked PDF. If the detail can't fit on the same medium as the claim, the claim needs to be narrowed until it can.

4. Flag the shorthand terms — "eco-friendly," "green," "climate neutral," "biodegradable," "clean," "planet-friendly" — for review anywhere they appear unqualified, including copy an agency or influencer wrote on your behalf. The claim doesn't have to be false to be in scope; it just has to be generic and unproven.

5. Check packaging you've already printed, not just what's in design review — a claim printed on stock sitting in a warehouse is still the claim you're making once national enforcement starts.

6. Set your internal audit deadline ahead of 27 September 2026, so any copy changes clear legal, design, and print lead times before national enforcement starts.

Tamats' compliance agent already screens marketing and label copy against this exact rule — and the rest of its EU, US, and Korean claims corpus — and links every flag back to the regulation behind it. tamats.org