Free guide

Green Claims That Still Sell

By Christine Johansen · Published October 2, 2026 · Updated October 3, 2026

If you sell to shoppers in the EU, words like "eco-friendly" and "sustainable" are now a legal risk. So is "carbon neutral" when it rests on offsets.

The EU's EmpCo rules took effect on September 27, 2026. There was no grace period, and they cover products you made before that date. Most of the fix is copy. The product is usually fine and the wording is the problem.

This guide covers what changed, which claims are in trouble, and how to rewrite them so they still sound like you. It ends with a 30-minute self-audit you can run on your own site.

Download the guide (PDF)

Six claims that are now a problem

The vague green word. Eco-friendly, green, sustainable, planet-friendly, conscious.
The whole-product halo. A claim that's true of one part but written about the whole product.
Carbon neutral by offset. Neutral, climate positive, or reduced impact because you bought offsets.
The homemade badge. An in-house badge, score, or tier that signals a greener product, with no independent checker.
The someday promise. Net zero by 2040, with no public, verified plan behind it.
The legal minimum dressed up. Selling something the law already requires of every product in your category.

Below is what each one looks like rewritten.

What to write instead

The examples below are made up, but you'll recognize the type. Swap in your own facts. The rewrite only works if every detail in it is true and you can prove it.

Before	After	What changed
Our most eco-friendly rain shell yet.	Shell fabric made from 100% recycled nylon. Water repellent with no PFAS added.	Two facts replace one feeling.
Sustainable merino base layers.	Merino certified to the Responsible Wool Standard.	The certificate does the talking.
Recycled fleece.	Body fabric made from 100% recycled polyester. Zips and trims aren't there yet.	Names the part. The honesty helps.
Carbon neutral shipping on every order.	Every order funds mangrove planting in Kenya. Shipping still has a footprint, and we publish ours.	Keeps the good deed. Drops the neutral claim.
Net zero by 2040.	We've cut our emissions 18% since 2022. Our plan and yearly progress are public and independently checked.	Progress you can show beats a promise you can't.
Plastic-free packaging, because we love the planet.	Ships in a mailer made from 100% recycled card. No plastic bag inside.	Says what the shopper will find when they open it.
The EcoTrail 30 pack.	The Trail 30 pack, made with 70% recycled ripstop.	The claim moves out of the name and into a fact.
A leaf icon labeled Planet Pick.	The certifier's own label, linked to the certificate.	A badge with someone independent behind it.

Four rules behind every rewrite

1. Name the part. Say which fabric, which component, which step.
2. Give the number. A percentage or a named standard beats any adjective.
3. Put the proof next to the claim. Same page, same label, same ad. A link or a QR code to the detail is fine as backup.
4. Keep your voice everywhere else. The law cares about the claim. The joke about soggy socks is all yours.

That last one matters most. The law cares about the claim, not the sentence beside it. Keep the brand writing that made someone want the jacket in the first place.

Questions brands are asking

Do the EU green claims rules apply to brands outside the EU?

Yes, if you market to EU consumers. Where your company is based doesn't get you out of it.

Do the rules cover products that are already on the shelf?

Yes. The rules have applied since September 27, 2026, with no transition period, and the European Commission has said they cover products already made and already on shelves.

Can we still say a product is carbon neutral?

Not when the claim rests on offsets. You can no longer call a product carbon neutral, climate positive, or reduced impact because you bought offsets. You can still talk about the projects you fund.

Is a word like eco-friendly or sustainable banned?

Generic environmental claims are banned unless the claim is spelled out clearly in the same place, or the product holds a top-tier ecolabel such as the EU Ecolabel. A link to a sustainability page elsewhere doesn't count.

Can we keep the badge or leaf icon our designer made?

It depends on what the icon says. If it tells shoppers a product is greener or better for the planet, it counts as a sustainability label, and labels now need a real certification scheme behind them, with an independent third party or a public authority doing the checking. In-house badges, scores, and tiers don't qualify. A leaf in your logo or as page decoration is a different matter. What counts is what a shopper would take the icon to mean.

Are brand and product names covered?

Yes. The Commission has confirmed that brand names and product names are covered. A name like EcoShell or Green Line makes a claim every time someone reads the label.

What are the fines?

They vary by country. For cross-border cases handled jointly by EU authorities, countries must be able to fine at least 4% of a brand's annual turnover in the countries involved.

Is this the same as the Green Claims Directive that stalled?

No. That was a separate proposal. EmpCo, formally Directive (EU) 2024/825, passed in 2024 and nothing about it has been paused.

Want a second pair of eyes?

If the self-audit turned up more than you expected, send me one page. I'll tell you which claims are at risk and how I'd rewrite them. No pitch, no pressure.

Send me a page

Sources

This page is general information for marketing teams. It isn't legal advice. For a ruling on a specific claim, talk to a lawyer who works in EU consumer law.