Reference
The vocabulary EU shops have leaned on for a decade, grouped by why it fails. Each entry carries the provision it falls under and a rewrite that says the same thing defensibly.
Every citation below points to the full directive. Fines and enforcement differ by country — see the country guides.
92 terms shown
Claims that assert overall environmental benefit without naming a measurable one. The single largest group, and the one point 4a of Annex I to the UCPD (Directive 2005/29/EC, as amended by Directive 2024/825) was written for.
A blanket friendliness claim tells the buyer nothing measurable. It is only allowed where you can demonstrate recognised excellent environmental performance covering the whole product, which in practice means an EU Ecolabel or an equivalent Type I scheme.
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Name the benefit and its proof: "Packaging is 90% post-consumer recycled board, FSC-C000000."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
“Green” is the textbook generic claim: no scope, no metric, no verification. It is also a colour and a common proper noun, so a match here is a prompt to look, not a conclusion — check whether the word is doing any environmental work in the sentence.
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Replace with the specific attribute you can evidence, e.g. "Dyed without heavy metals (ZDHC MRSL Level 3)."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Sustainability is a whole-lifecycle property. Used as an adjective for a product it asserts excellence across every impact category, which needs lifecycle evidence almost no seller holds.
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State the one impact you measured: "Uses 38% less water per unit than our 2022 process (verified by SGS, report ENV-2025-411)."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
"Natural" reads as an environmental and safety benefit but has no legal definition outside food and cosmetics standards. Natural origin also does not make a substance harmless.
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Quantify the composition: "92% plant-derived ingredients (ISO 16128 natural origin index 0.92)."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Same defect as "eco-friendly" in longer form. It claims net benefit to the environment as a whole while every physical product carries a footprint.
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Describe the reduction against a stated baseline: "Cuts packaging weight by 41% versus our previous carton."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
A planetary-scale benefit claim with no scope, no metric and no possible substantiation for an individual product.
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Swap in a verifiable fact about one lifecycle stage, with the certificate or test that backs it.
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Implies the product is beneficial, or at least neutral, for the planet overall. That is an aggregate claim requiring full lifecycle evidence.
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Name the stage and the number: "Shipped by rail from our EU warehouse — 76% lower transport emissions than air freight."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
In marketing "clean" borrows the authority of a standard that does not exist. It suggests both environmental and toxicological safety without defining either.
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List what is excluded and against which list: "Formulated without the 1,700 substances on the EU cosmetics Annex II."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
A vague virtue word used as a product tier name. Regulators have treated collection names like this as environmental claims subject to the same substantiation duty.
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If it names a collection, state the criterion for inclusion: "Every item in this line is at least 70% GRS-certified recycled fibre."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
"Responsibly made" or "responsible sourcing" asserts ethical and environmental diligence without naming the standard the diligence is measured against.
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Name the scheme and coverage: "98% of our cotton is sourced through Better Cotton (2025 volume)."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Toxicity is dose-dependent and substance-specific, so a blanket "non-toxic" is not demonstrable. It also implies competitors are toxic.
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Point to the classification: "Not classified as hazardous under CLP Regulation 1272/2008."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
The bare prefix, used on badges and product tiers, carries the same implied overall benefit as "eco-friendly" while being even less specific.
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Drop the prefix and show the licence: "EU Ecolabel, licence EU/030/123."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
A figurative benefit claim. Regulators read implied environmental claims the same way as explicit ones, and the figurative framing makes it harder, not easier, to substantiate.
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Replace with a factual statement about a measured impact.
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Presented as a quality mark, it asserts general environmental soundness. In several member states it is also treated as implying organic certification.
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Use the certified term you actually hold, e.g. "Certified organic under Regulation (EU) 2018/848."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Claims conformity with an unstated environmental norm. There is no such general norm, so the claim cannot be tested.
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Cite the actual standard you conform to and its scope.
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Suggests a positive or neutral climate effect for a product that still emits. Where the basis is offsetting it also breaches the offsetting ban.
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Give the footprint and the trend: "4.2 kg CO2e per unit (ISO 14067), down 19% since 2023."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
A softened generic claim. Softening the wording does not narrow the scope — it still asserts low overall impact.
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Name the impact you reduced and by how much, against a stated baseline.
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
An absolute negative claim about all environmental compartments. It cannot be demonstrated for a manufactured good.
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State the specific hazard classification result instead, e.g. "Not classified as hazardous to the aquatic environment."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Implies emissions are benign. Combines the generic-claim problem with an unquantified climate assertion.
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Publish the number: "Product carbon footprint 2.8 kg CO2e, calculated to ISO 14067 and third-party verified."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Used as a product or badge label (“Sustainability score”, “Sustainability choice”) it is a generic claim and has to be substantiated. The word also has a legitimate use as the title of a real report or policy page — we cannot tell the two apart from the wording alone, so we flag it and leave the judgement to you. If this instance is a report title, mark it and move on.
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Keep the word for your reporting; on products use the measured attribute and its evidence.
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Asserts net positive planetary impact — the strongest form of generic claim and the least substantiable.
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Reframe as a comparison you can evidence, with method and source disclosed.
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
A steering label that tells the consumer this option is environmentally better without disclosing the criterion or the comparison set.
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If you rank options, publish the criteria and the data behind the ranking next to the badge.
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Implies both environmental cleanliness and absence of unwanted substances, with neither defined. Fine as a material descriptor ("pure wool"), not as a virtue claim.
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Restrict it to composition facts: "100% pure new wool."
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Recital 9 of Directive 2024/825 names "energy efficient" in its own list of generic environmental claims. Without an efficiency class, a measured figure or a named test standard on the same medium, it claims excellent performance the trader has to be able to demonstrate.
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"Energy class A under EU 2017/1369, 42 kWh/annum in the standard cycle."
“Regenerative” asserts that the activity leaves the environment better than it found it — a stronger claim than sustainability, and one with no agreed definition or certification scheme behind it in most sectors. It is one of the fastest-growing claims in fashion and food and among the least substantiated. We only flag it in the collocations where it is an environmental claim (regenerative agriculture, cotton, sourcing, economy). “Regenerative Energien” is German for renewable energy, “regenerative braking” is a brake and “regenerative medicine” is a field of research — none of those is a claim about this product.
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Name the practice and the measured outcome: “Soil organic carbon up 0.4 percentage points across 1,200 ha, measured 2021–2025 to ISO 17025 by [lab].”
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Asserting a net positive effect is the strongest form of generic environmental claim: it implies the activity does more good than harm overall, which almost no commercial operation can demonstrate across a full life cycle.
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Drop the net claim and state one measured effect with its boundary, or describe the initiative without claiming its net result.
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Harmony and respect are not measurable properties. The claim reads as an environmental benefit while committing to nothing a buyer or an authority could check. “Please respect nature and stay on the path” is an instruction to a visitor, not a claim about a product, so the bare verb is not flagged.
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Replace with the practice you can evidence: the standard you farm to, the certification, or the measured effect on a named indicator.
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Neutrality, compensation and reduction claims. Point 4c removes offsetting as a basis for any of them, which invalidates most of the wording in common use.
Claims a net beneficial climate effect. In practice it always rests on purchased credits, which point 4c rules out as a basis for any neutrality, reduction or positive-impact claim.
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Separate the two facts: report your measured emissions and reductions, then describe any credits purchased as a separate contribution, never as the product's footprint.
A reduction claim is only meaningful against a stated baseline, scope and period. Without them the buyer cannot tell what was reduced or from what.
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"CO2e per unit down 24% versus our 2022 baseline (scope 1-3, verified by TUV SUD)."
Same defect as any bare reduction claim: no baseline, no boundary, no verification.
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Give baseline year, calculation standard and who checked it.
Prohibited where it rests on offsetting, which is how virtually all such claims are built. The German Federal Court of Justice (BGH, I ZR 98/23) additionally requires the meaning of the term to be explained at the point of the claim.
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"We cut operational emissions 40% since 2021 and fund verified reforestation separately — the remaining 60% is not offset away."
An even stronger version of the neutrality claim, and equally dependent on credits. Point 4c covers neutral, reduced and positive impact claims based on offsetting.
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Describe removals you own and can measure, keeping them separate from the product footprint.
The most litigated term in this list. Beyond point 4c, German case law (BGH klimaneutral, 2024) held the term ambiguous and misleading unless the basis is explained in the advertisement itself.
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State reductions achieved and the roadmap for the rest, with the verification body named.
As a present-tense product claim it is an offsetting claim. As a target it is a future-performance claim needing verifiable commitments and independent monitoring.
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"Target: net zero across scopes 1 and 2 by 2035, interim milestone -50% by 2030, progress audited annually and published."
Offsetting itself is not illegal — presenting it as making the product neutral, reduced-impact or positive is. The claim must not be attached to the product's environmental performance.
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"Beyond our reduction plan, we also fund Gold Standard removal projects. This is additional to, not a substitute for, our own emissions cuts."
Claims the product improves the climate. Offsetting cannot support it, and no other basis is normally available.
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Report the measured footprint and reductions; describe any climate funding separately.
Compensation is offsetting under another name; the prohibition follows the substance of the claim, not the wording.
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Keep compensation out of any statement about the product's impact.
Absolute and almost always false for a physical product across its lifecycle. It is defensible only for a narrowly defined stage that genuinely emits nothing, and the stage must be named.
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"Zero tailpipe emissions" or "our Tallinn plant runs on 100% contracted renewable electricity" — with the boundary stated.
"Low" is implicitly comparative and therefore needs a disclosed benchmark. Low compared to what, measured how?
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"1.9 kg CO2e per unit versus the 4.4 kg category average (Ecoinvent 3.10 dataset)."
UCPD Article 6 as amended (unsubstantiated comparative claim)
Identical in substance to "climate neutral" and caught by the same prohibition and case law.
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Report gross emissions and the reduction trajectory instead.
Offsetting framed as compensation. Point 4c applies to the claim's effect on the consumer, regardless of the label used.
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Describe compensation as corporate funding, separate from product claims.
Same prohibition. Nordic regulators have been particularly active against this phrasing.
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State measured reductions; do not net credits against the product footprint.
"Balanced" implies emissions have been cancelled out — a neutrality claim built on credits.
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Publish the unbalanced number and what you are doing to lower it.
As above: a neutrality claim in softer wording, with the same legal treatment.
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Report the footprint and the reduction plan.
Stating the offsetting is permitted; using it to imply the product or company has no climate impact is not. The risk is in the surrounding claim, so check what sits next to this sentence.
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Keep the sentence, remove any neutrality conclusion drawn from it, and state your gross emissions nearby.
“Climate protection” names a benefit without a quantity, a boundary or a baseline. Recital 9 lists exactly this family of wording as generic environmental claims.
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Give the figure and its scope: “Scope 1–2 emissions down 31% versus 2019, verified by [auditor].”
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Recyclable, compostable, bio-based, plastic-free. Usually true of one component and stated as if true of the product.
Everything degrades eventually. Without the conditions, the timeframe and the test method the word promises disappearance that does not happen in a landfill or the sea.
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"Biodegrades by 90% within 180 days in industrial composting, tested to EN 13432."
Industrial and home composting are different capabilities, and most consumers have access only to the latter. Unqualified, the claim misdirects disposal behaviour.
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"Home compostable, certified to NF T51-800 (TUV OK compost HOME, licence 000000)."
Technically recyclable is not the same as actually collected. If no separate collection stream exists in the markets you sell to, the claim misleads.
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"Recyclable in kerbside paper collection across the EU. The pump is PP — separate before disposal."
The trap is scope: "recycled packaging" on a product with a virgin plastic bottle and a recycled outer sleeve is a partial benefit presented as a whole-product one.
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Give share and component: "Bottle contains 55% post-consumer recycled PET; cap is virgin PP."
For food, feed and agricultural products the term is legally reserved for certified operators. Outside that scope it is an unsubstantiated quality claim.
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"Certified organic, EE-ECO-001, 96% of agricultural ingredients" — or drop the word if you hold no certification.
Bio-based says where the carbon came from, not that the product is compostable, recyclable or lower impact — yet consumers read all three into it.
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"72% bio-based carbon content, measured to EN 16785-1. Not compostable."
Frequently false at component level: adhesives, liners, coatings and labels usually contain polymers. It also implies an overall environmental benefit that a heavier alternative may not deliver.
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"Carton and inner tray are plastic-free; the seal film is not."
Scientifically impossible — all matter is chemical. It plays on chemophobia and cannot be substantiated in any form.
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Name the substance group you excluded and the list you used, e.g. "No parabens, no SLS/SLES."
Natural origin implies low impact, which does not follow — conventional cotton and leather are natural and impact-intensive. Scope is usually unstated too.
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"Outer shell: 100% linen. Lining: 65% recycled polyester." Let the composition speak.
"Renewable" says the input regrows, not that the product is better. Without the share, the source and the certification it carries the weight of an environmental benefit it has not demonstrated — and for energy it needs a supplier-specific figure, not a national grid average.
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"68% of the fibre is FSC-certified viscose from renewable wood pulp; the remainder is conventional polyester."
A resource claim that is only meaningful against a stated baseline and a measured figure. "Saves water" compared to what, by how much, under which use pattern? Without that it is an unsubstantiated environmental claim about a main characteristic.
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"6 litres per minute at 3 bar, against the 9 l/min class average (EN 200)."
A circularity claim says the product re-enters a materials loop. Without a take-back route the buyer can actually use, and a stated recycled or recovered share, it describes an intention rather than a property of the thing being sold. “Circular design”, “circular saw” and “a circular rug” describe a shape, not a materials loop, so those are not flagged.
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State the loop that exists today: “Take-back in 14 EU countries; returned units are shredded and 62% of the mass re-enters our own production.”
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
“Saves resources” names no resource and no quantity. Which resource, measured against what alternative, and by how much are all left to the reader. “Saves resources” about disk space or battery life is not an environmental claim, so we require the natural-resource sense.
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Name the resource and the number: “Uses 1.8 litres less water per unit than our 2023 process.”
Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)
Targets and pledges. Allowed only with clear, public, verifiable commitments and independent monitoring behind them.
A dated promise of an undefined end state. Article 6(2)(d) requires clear, objective, publicly available and verifiable commitments plus an independent monitoring system — a slogan supplies none of these.
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"By 2030, 100% of our cotton will be GOTS or Better Cotton certified. Milestone: 60% by 2027, audited annually by Control Union and published."
UCPD Article 6(2)(d) as inserted by Directive 2024/825 (future environmental performance)
"On track" asserts verified progress against a plan. Without a published trajectory, interim targets and independent monitoring, there is nothing to be on track against.
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"2030 target -50% scope 1-2 versus 2021. Currently at -23% (2025, assured by DNV)."
UCPD Article 6(2)(d) as inserted by Directive 2024/825 (future environmental performance)
Commitment language creates the impression of a binding plan. It is only permitted where the commitment is specific, public, verifiable and monitored.
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Turn the commitment into a target with a number, a date, a baseline and a named auditor.
UCPD Article 6(2)(d) as inserted by Directive 2024/825 (future environmental performance)
Aspiration without a milestone. It conveys progress while committing to nothing measurable.
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Replace with the next concrete milestone and its date, or remove the sentence.
UCPD Article 6(2)(d) as inserted by Directive 2024/825 (future environmental performance)
"Aiming" is doing the same work as "committed" while sounding softer. The substantiation duty is identical.
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"90% diversion from landfill at our own sites by 2028; currently 71% (2025 waste report)."
UCPD Article 6(2)(d) as inserted by Directive 2024/825 (future environmental performance)
Describes a direction of travel with no start point, end point or verification.
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State where you are now and where you will be by when: "58% of sites on contracted renewable electricity today, 100% by 2029."
UCPD Article 6(2)(d) as inserted by Directive 2024/825 (future environmental performance)
Badges, seals, scores and ticks that look like certification but have no scheme behind them. Blacklisted outright — no misleadingness test applies.
Displaying a sustainability label that is not based on a third-party certification scheme, and not established by a public authority, is on the blacklist — no misleadingness test needed.
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Show only certification marks you actually hold, with licence number and a link to the issuer's register.
Seals and badges carry the visual authority of certification. If nothing independent stands behind the graphic, it is a prohibited label.
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Remove the graphic, or replace it with the real certifier's mark and licence reference.
A self-calculated score is a sustainability label under the Directive. Self-issued rating systems are exactly what point 2a targets.
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Use an external rating (EU Ecolabel, EPD, EcoVadis) or publish the full methodology and make clear it is your own, non-certified assessment.
Purely visual environmental signalling — leaves, green ticks, earth icons — is read by consumers as certification. Implied claims fall under the same rules as written ones.
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Keep decoration decorative: no leaf or tick next to a product unless it is a real certifier's mark.
Self-approval dressed as endorsement. The Directive requires the scheme behind a label to be independent or public.
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Cite an external body's approval, or say plainly that the assessment is your own.
Greener, better, best. A comparison needs a disclosed metric, comparator and method, or it is not assessable.
A comparison is only fair if the buyer can see what was compared, on which impacts, using which data. "Greener" discloses none of it.
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"32% lower cradle-to-gate CO2e than the category average, both calculated to EN 15804 (Ecoinvent 3.10)."
Combines the generic-claim problem with an undisclosed benchmark — vague on both the metric and the comparison set.
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Name one impact, one baseline, one method, one source.
Aggregate superiority across all environmental impacts. Even a full LCA rarely supports it, because trade-offs between impact categories are normal.
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Compare a single measured impact and disclose the trade-offs you found.
Comparative form of a term that is already too vague in its base form.
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State the measured difference and the comparator explicitly.
A superiority claim requiring evidence about the entire class — including competitor data you probably cannot access.
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"Top quartile in our sector on EcoVadis (score 72/100, 2025 assessment)."
Leadership claims need a defined field, a defined metric and a ranking that someone else produced.
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Cite the external ranking, its date and your position in it.
A reduction claim is a comparison. Without the baseline it is measured against, the scope it covers and the size of the reduction, the buyer cannot tell whether it means 2% or 60%.
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“38% lower cradle-to-gate CO2e than our 2022 process, both calculated to EN 15804 (Ecoinvent 3.10).”
Messaging that pushes replacement of a working product. New to the blacklist in 2024 and widely overlooked.
Withdrawing support is a commercial decision. Presenting it as a technical necessity pushes replacement of a working product, which the amended blacklist now treats as an unfair practice in itself.
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"Security updates for this model end on 1 March 2027. It will keep working; new features will not be added."
Inducing the consumer to replace or replenish a consumable earlier than technically necessary is blacklisted. Vague performance wording is the usual vehicle.
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Tie the prompt to a measured threshold: "Replace when flow drops below 1.5 l/min, typically after 6 months."
Where a product is designed to limit functionality with parts from another supplier, that must be disclosed up front. Announcing it only at the moment of use is the prohibited pattern.
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Disclose the restriction on the product page before purchase, and say what it affects.
Presenting an update as necessary when it merely enhances functionality is blacklisted. So is omitting that an update will degrade performance.
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Separate the two: "Security update (recommended)" and "Feature update (optional) — adds X, may increase battery use."
Generic upgrade nudges aimed at owners of functioning products edge into the durability-misrepresentation territory the amendment targets, especially alongside end-of-support messaging.
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Sell the new model on what it adds, without implying the old one has stopped being fit for use.
An "end of life" notice on a device that still functions asserts a durability limit that may not be real. Where the limit was designed in, the communication itself is prohibited.
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State what specifically ends — support, warranty, spare-part availability — and give the date.
Timer-based replacement prompts that ignore actual use induce earlier replacement than necessary. This is exactly the practice point 23i names.
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Base the prompt on measured use, and state the measurement: "1,000 litres filtered — replacement recommended."
Advertising compliance as a benefit. BPA-free, CE certified, two-year warranty — things every competitor must also do.
BPA has been banned in food contact materials in the EU since Regulation (EU) 2024/3190. Advertising its absence as a benefit presents compliance as a distinguishing feature.
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Drop the badge. If the material matters to buyers, describe it: "Tritan copolyester body."
CE marking is mandatory for the product categories that require it, and it is a manufacturer's declaration, not a certification. Marketing it as a quality feature is doubly misleading.
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Leave the CE mark where the law requires it and keep it out of your selling points.
Two years is the statutory conformity guarantee under Directive (EU) 2019/771 across the EU. Presenting it as your offer suggests a benefit the buyer already has by law.
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Advertise only the part that goes beyond it: "We cover this product for four years, two more than the law requires."
Animal testing of cosmetics and their ingredients has been prohibited in the EU since 2013 under Regulation 1223/2009. For cosmetics sold in the EU this is compliance, not a differentiator.
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Only claim it where it genuinely goes beyond the ban, e.g. a Leaping Bunny certification covering your whole supply chain, and name the scheme.
Meeting REACH is not a feature — it is the baseline every seller in the EU already has to clear. Presenting it as a benefit is what point 10a of Annex I now forbids.
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Remove it from the feature list; if a specific SVHC is absent and buyers care, name that substance.
RoHS applies to electrical and electronic equipment across the EU, so every competitor on the shelf is in the same position. Advertising it as an advantage is the practice point 10a lists.
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Keep the declaration in the technical documentation, not in the marketing copy.
Hazard labelling under Regulation 1272/2008 is required for classified substances and mixtures. Advertising it implies a voluntary safety step.
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Remove from selling points; the label itself already communicates what it must.
The main phthalates are restricted or authorisation-only under REACH Annex XVII and XIV, so for most consumer goods absence is the legal baseline.
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Claim it only where the substance would otherwise be lawful in your product category, and say which phthalates you mean.
No term matches that search. Try a shorter word, or clear the category filter.
Not being on this list is not permission. These are 92 terms we match by word; a claim that says the same thing in its own words is not here, and the scanner reads context that a word list cannot.
Check your own sentence insteadThe scanner looks for every one of them, in context, and tells you which ones are actually a problem.