If the Green Claims Directive is stalled, what rules do businesses actually need to follow?

Directive (EU) 2024/825 on Empowering Consumers for the Green Transition, which is separate from the Green Claims Directive and unaffected by its withdrawal. It entered into force on 26 March 2024, must be transposed into national law by 27 March 2026, and becomes applicable across the EU from 27 September 2026. It already bans generic unsubstantiated claims such as 'eco-friendly' or 'green', and bans claims that a product is 'carbon neutral' based solely on offsetting.

EU Green Claims Directive status update: what businesses need to know in 2026

EU Green Claims Directive: Status Update and What's Actually Binding in 2026

Q: What is the EU Green Claims Directive, and is it in force?

The Green Claims Directive was a 2023 European Commission proposal that would have required businesses to scientifically substantiate and independently verify environmental claims before making them. It is not in force. On 20 June 2025 the Commission announced its intention to withdraw the proposal after political opposition (notably from the EPP and several member states, including Italy, which withdrew its support three days later). Trilogue negotiations were cancelled, and as of October 2026 there is no active legislative process, though the Commission says the text has not been formally withdrawn.

Q: What are the penalties for unsubstantiated green claims in the EU?

There is no EU-wide penalty figure tied to the Green Claims Directive, since it was never adopted. Under the EU consumer-protection framework that Directive 2024/825 falls under, penalties for ordinary infringements are set by each member state's own transposing law. For serious cross-border 'widespread infringements', EU coordination rules allow fines of up to 4% of a trader's annual turnover (or EUR 2 million where turnover data is unavailable), but this ceiling comes from the 2019 Omnibus Directive's amendment to the Unfair Commercial Practices Directive, not from the Green Claims Directive.

Key point: The EU Green Claims Directive — the 2023 proposal that would have mandated full-lifecycle, third-party-verified substantiation for every environmental claim — has stalled. The European Commission announced its intention to withdraw it on 20 June 2025, trilogue negotiations were cancelled, and as of October 2026 there is no confirmed path to adoption. What is binding is Directive (EU) 2024/825, which member states must transpose by 27 March 2026 and which applies EU-wide from 27 September 2026. It already bans generic claims like "eco-friendly" without evidence and "carbon neutral" claims based solely on offsets. There is no single EU-wide penalty figure for this directive — penalties are set by each member state's national transposing law.

For years, companies have been free to slap "eco-friendly", "sustainable", or "carbon neutral" labels on products with minimal accountability. A European Commission study found that 53% of environmental claims in the EU were vague, misleading, or unsubstantiated. The Green Claims Directive was meant to fix that with a dedicated, strict regime — but that specific law has stalled. A separate, already-binding directive now carries most of the practical weight instead.

Whether you sell products in the EU, export to European markets, or simply want to stay ahead of global trends, understanding what is actually enforceable — as opposed to what was merely proposed — is essential. Here is where things really stand.

What the Green Claims Directive proposed — and what's actually required today

The original 2023 proposal would have required full scientific substantiation (using methodologies like PEF or ISO 14040/44 lifecycle assessment), mandatory independent third-party verification before a claim could be used, and full-lifecycle disclosure for every voluntary environmental claim. That proposal is stalled: the Commission announced on 20 June 2025 that it intended to withdraw it, after the European Parliament's EPP group and several member states objected to the compliance burden it would place on small businesses; Italy withdrew its support on 23 June 2025. As of October 2026, there is no active trilogue and no new timeline.

That does not mean environmental claims are unregulated. Businesses already have binding obligations under Directive (EU) 2024/825 ("Empowering Consumers for the Green Transition"), adopted 28 February 2024, which member states must transpose by 27 March 2026 and which becomes applicable from 27 September 2026. It amends the Unfair Commercial Practices Directive to blacklist:

Generic environmental claims without proof — terms like "eco-friendly", "green", or "sustainable" are banned unless the trader can demonstrate recognised, excellent environmental performance relevant to the claim
Carbon-neutral claims based solely on offsetting — claiming a neutral, reduced, or positive environmental impact purely because of purchased offset credits is banned outright
Whole-product claims based on one aspect — an environmental claim about an entire product or business, when it really concerns only one attribute, is prohibited
Unrecognised sustainability labels — labels not based on a certification scheme or established by a public authority are banned

The heavier machinery the Green Claims Directive would have added — mandatory PEF/ISO 14040 lifecycle assessment and mandatory independent verification before any claim is made — is not currently EU law. It may return in a future proposal, and some member states already go further on their own (see France, below), but there is no general EU-wide pre-verification mandate today.

Claims that are banned or restricted under current EU law

Claim type	Status as of October 2026	What to do instead
"Eco-friendly" / "Green"	Banned without substantiation under Directive 2024/825 (applicable 27 Sept 2026)	Specify: "30% lower CO2 than category average"
"Carbon neutral" (product)	Banned if based solely on offsets, under Directive 2024/825	Report actual footprint + reduction + residual offsets separately
"Sustainable"	Banned as an unsubstantiated generic claim (2024/825) — full-lifecycle PEF proof was a Green Claims Directive idea, not current EU law	Use specific metrics tied to recognised standards
"Natural"	Not specifically addressed EU-wide yet; still caught by general misleading-claims rules under the Unfair Commercial Practices Directive	"Made with 95% naturally-sourced ingredients"
"Climate positive"	Not specifically addressed EU-wide yet; treat as a generic claim requiring full substantiation to avoid misleading-claims liability	Show verified net negative emissions with transparent methodology
Unverified eco-labels	Banned under Directive 2024/825 — only labels based on certification schemes or established by public authorities are allowed	Use EU-recognised labels (EU Ecolabel, verified EPDs)

Timeline: what's actually confirmed

Two separate tracks are easy to confuse. Here is each one, accurately:

March 2023 — Commission publishes the Green Claims Directive proposal
12 March 2024 / 17 June 2024 — Parliament and Council each adopt their own negotiating positions on the Green Claims Directive; trilogues begin in January 2025
20 June 2025 — Commission announces its intention to withdraw the Green Claims Directive proposal, citing the compliance burden on small businesses; Italy withdraws its support three days later. No provisional agreement was ever reached
October 2026 (today) — the Green Claims Directive remains stalled, with no active negotiation and no confirmed timeline
28 February 2024 — separately, Directive (EU) 2024/825 ("Empowering Consumers for the Green Transition") is adopted; it enters into force 26 March 2024
27 March 2026 — deadline for EU member states to transpose Directive 2024/825 into national law
27 September 2026 — Directive 2024/825 becomes applicable: generic unsubstantiated claims and offset-only "carbon neutral" claims become illegal EU-wide

In short: the law to prepare for is Directive 2024/825, not the Green Claims Directive. The Green Claims Directive's stricter substantiation and verification requirements may resurface in a future proposal, but as of October 2026 they are not binding anywhere in the EU.

How to prepare your business

Audit your current claims — review all product labels, marketing materials, website copy, and advertising for environmental claims. Flag anything that is vague, unsubstantiated, or based solely on offsets, ahead of Directive 2024/825's 27 September 2026 application date
Conduct lifecycle assessments — for your key products, commission an ISO 14040-compliant LCA or use the EU PEF methodology. This is not currently mandatory EU-wide, but it gives you the data to substantiate specific claims under 2024/825 and protects you if stricter rules return
Build a carbon accounting system — measure your actual emissions across Scope 1, 2, and 3 before claiming reductions
Replace vague claims with specific ones — "our aluminium cans contain 70% recycled content, reducing production emissions by 45% compared to virgin aluminium" is defensible. "Our packaging is eco-friendly" is exactly the kind of generic claim Directive 2024/825 bans
Consider engaging a verification body — independent verification is not currently an EU-wide legal requirement outside specific national rules, but it builds the evidence trail regulators and consumer groups will expect, and positions you well if the Green Claims Directive (or a successor) is eventually revived

Impact on carbon neutrality claims

This is the biggest practical impact for many companies, and it comes from Directive 2024/825 — not the stalled Green Claims Directive. From 27 September 2026, claiming a product is "carbon neutral" based solely on purchased carbon offsets is banned, unless you:

Disclose the actual carbon footprint of the product
Show a credible reduction trajectory (not just offsetting)
Clearly separate actual reductions from offset contributions
Use only high-quality, verified offset credits

In practice, most "carbon neutral" labels as currently used will become illegal in the EU from 27 September 2026. Companies that have genuinely reduced emissions and transparently disclose the remainder offset will be able to make more nuanced claims — just not the blanket "carbon neutral" label based on offsets alone.

How Digital Product Passports fit in

Separately from the Green Claims Directive's uncertain fate, the EU Digital Product Passport (DPP) is moving ahead on its own track and will make it far easier for businesses to produce the evidence that Directive 2024/825 (and any future green-claims rules) demand. As DPPs roll out across textiles, batteries, electronics, construction products and furniture between 2027 and 2030, brands will increasingly be able to substantiate specific claims by publishing structured product data via the EU DPP Registry. A QR-coded passport with an audited carbon footprint, recycled-content share and supplier traceability is exactly the kind of specific, verifiable evidence that substantiation rules demand — whether under 2024/825 today or under a revived Green Claims Directive in the future.

For a complete picture of the three EU DPP frameworks (ESPR, Battery Regulation, Construction Products Regulation), the priority categories and the rollout timeline through 2030, see our complete guide to the EU Digital Product Passport.

Beyond the EU: global trend

The EU's Green Claims Directive may have stalled, but the broader regulatory direction — including the EU's own Directive 2024/825 — is still moving. Similar scrutiny is emerging worldwide:

UK — the Competition and Markets Authority (CMA) Green Claims Code is already enforced under existing consumer protection law
France — the Loi Climat has restricted "carbon neutral" product claims in advertising since January 2023: the term is banned unless the advertiser publishes a full greenhouse-gas assessment, its avoid/reduce/offset methodology, and its compensation details
US — the FTC is updating its Green Guides, with stricter rules possible but not yet finalised
Australia — the ACCC has taken enforcement action against greenwashing since 2023

Frequently asked questions

What is the EU Green Claims Directive, and is it in force?

It was a 2023 Commission proposal requiring businesses to scientifically substantiate and independently verify environmental claims. It is not in force: the Commission announced its intention to withdraw it on 20 June 2025 after political opposition, and as of October 2026 there is no active legislative process.

If it's stalled, what rules actually apply?

Directive (EU) 2024/825, which is unaffected by the Green Claims Directive's collapse. Member states must transpose it by 27 March 2026, and it applies EU-wide from 27 September 2026 — already banning generic claims like "eco-friendly" and offset-only "carbon neutral" claims.

What are the penalties for unsubstantiated claims?

There is no EU-wide penalty figure from the Green Claims Directive, since it was never adopted. Penalties are set primarily by each member state's own transposing law. For serious cross-border "widespread infringements", EU rules allow fines up to 4% of annual turnover (or EUR 2 million where turnover is unknown) — but that ceiling comes from the 2019 Omnibus Directive's UCPD amendment, not from the Green Claims Directive.