92 grüne Aussagen, die im September 2026 aufhören zu funktionieren

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.

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “nachhaltig”

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “natürlich”

"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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “umweltfreundlich”

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “erdfreundlich”

A planetary-scale benefit claim with no scope, no metric and no possible substantiation for an individual product.

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.

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.

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.

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “schadstofffrei”

Toxicity is dose-dependent and substance-specific, so a blanket "non-toxic" is not demonstrable. It also implies competitors are toxic.

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “naturfreundlich”

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “ökologisch”

Presented as a quality mark, it asserts general environmental soundness. In several member states it is also treated as implying organic certification.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “umweltgerecht”

Claims conformity with an unstated environmental norm. There is no such general norm, so the claim cannot be tested.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “klimafreundlich”

Suggests a positive or neutral climate effect for a product that still emits. Where the basis is offsetting it also breaches the offsetting ban.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “umweltschonend”

A softened generic claim. Softening the wording does not narrow the scope — it still asserts low overall impact.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “umweltunbedenklich”

An absolute negative claim about all environmental compartments. It cannot be demonstrated for a manufactured good.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “CO2-freundlich”

Implies emissions are benign. Combines the generic-claim problem with an unquantified climate assertion.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “Nachhaltigkeit”

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.

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.

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.

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.

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim without demonstrated recognised excellent environmental performance)

Auf Deutsch: “regenerative Landwirtschaft”, “regeneratives Wirtschaftssystem”, “regenerative Baumwolle”

“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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “positive Auswirkungen auf die Umwelt”, “positiv Auswirkungen auf die Umwelt”

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “im Einklang mit der Natur”

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

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.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

Auf Deutsch: “CO2-reduziert”

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.

UCPD Article 6(1)(b) and Article 2(p) as amended by Directive 2024/825 (environmental characteristics are a main characteristic; a claim is generic — and so caught by Annex I point 4a — where the specification is not given in clear and prominent terms on the same medium)

Same defect as any bare reduction claim: no baseline, no boundary, no verification.

UCPD Article 6(1)(b) and Article 2(p) as amended by Directive 2024/825 (environmental characteristics are a main characteristic; a claim is generic — and so caught by Annex I point 4a — where the specification is not given in clear and prominent terms on the same medium)

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.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

Auf Deutsch: “CO2-negativ”

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.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

Auf Deutsch: “klimaneutral”

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.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

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.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

Auf Deutsch: “CO2-Kompensation”

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.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead). Recital 12 states that the prohibition "should not prevent companies from advertising their investments in environmental initiatives, including carbon credit projects, as long as they provide such information in a way that is not misleading" — the offsetting itself is lawful; what point 4c prohibits is deriving a NEUTRALITY claim from it

Auf Deutsch: “klimapositiv”

Claims the product improves the climate. Offsetting cannot support it, and no other basis is normally available.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

Auf Deutsch: “CO2-kompensiert”

Compensation is offsetting under another name; the prohibition follows the substance of the claim, not the wording.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

Auf Deutsch: “emissionsfrei”

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.

UCPD Article 6(1)(b) as amended by Directive 2024/825; Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825, where the claim rests on offsetting

Auf Deutsch: “emissionsarm”

"Low" is implicitly comparative and therefore needs a disclosed benchmark. Low compared to what, measured how?

UCPD Article 6 as amended (unsubstantiated comparative claim)

Auf Deutsch: “CO2-neutral”

Identical in substance to "climate neutral" and caught by the same prohibition and case law.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

Offsetting framed as compensation. Point 4c applies to the claim's effect on the consumer, regardless of the label used.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

Auf Deutsch: “klimakompensiert”

Same prohibition. Nordic regulators have been particularly active against this phrasing.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

Auf Deutsch: “CO2-ausgeglichen”

"Balanced" implies emissions have been cancelled out — a neutrality claim built on credits.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

Auf Deutsch: “klimaausgeglichen”

As above: a neutrality claim in softer wording, with the same legal treatment.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead)

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.

Directive 2005/29/EC, Annex I point 4c, inserted by Directive 2024/825 (claiming, BASED ON OFFSETTING, that a product has a neutral, reduced or positive impact on the environment; a neutrality claim not resting on offsetting falls under point 4a and Article 6(1)(b) instead). Recital 12 states that the prohibition "should not prevent companies from advertising their investments in environmental initiatives, including carbon credit projects, as long as they provide such information in a way that is not misleading" — the offsetting itself is lawful; what point 4c prohibits is deriving a NEUTRALITY claim from it

Auf Deutsch: “Klimaschutz”

“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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “biologisch abbaubar”

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim without demonstrated recognised excellent environmental performance)

Auf Deutsch: “kompostierbar”

Industrial and home composting are different capabilities, and most consumers have access only to the latter. Unqualified, the claim misdirects disposal behaviour.

UCPD Article 6(1)(b) and Article 2(p) as amended by Directive 2024/825 (environmental characteristics are a main characteristic; a claim is generic — and so caught by Annex I point 4a — where the specification is not given in clear and prominent terms on the same medium)

Auf Deutsch: “recycelbar”

Technically recyclable is not the same as actually collected. If no separate collection stream exists in the markets you sell to, the claim misleads.

UCPD Article 6(1)(b) and Article 2(p) as amended by Directive 2024/825 (environmental characteristics are a main characteristic; a claim is generic — and so caught by Annex I point 4a — where the specification is not given in clear and prominent terms on the same medium)

Auf Deutsch: “recycelt”

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.

Directive 2005/29/EC, Annex I point 4b, inserted by Directive 2024/825 (whole-product claim about a partial benefit)

For food, feed and agricultural products the term is legally reserved for certified operators. Outside that scope it is an unsubstantiated quality claim.

Regulation (EU) 2018/848 (organic production and labelling)

Auf Deutsch: “biobasiert”

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim without demonstrated recognised excellent environmental performance)

Auf Deutsch: “plastikfrei”

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.

UCPD Article 6(1)(b) and Article 2(p) as amended by Directive 2024/825 (environmental characteristics are a main characteristic; a claim is generic — and so caught by Annex I point 4a — where the specification is not given in clear and prominent terms on the same medium)

Auf Deutsch: “chemiefrei”

Scientifically impossible — all matter is chemical. It plays on chemophobia and cannot be substantiated in any form.

UCPD Article 6(1)(b) and Article 2(p) as amended by Directive 2024/825 (environmental characteristics are a main characteristic; a claim is generic — and so caught by Annex I point 4a — where the specification is not given in clear and prominent terms on the same medium)

Natural origin implies low impact, which does not follow — conventional cotton and leather are natural and impact-intensive. Scope is usually unstated too.

UCPD Article 6(1)(b) and Article 2(p) as amended by Directive 2024/825 (environmental characteristics are a main characteristic; a claim is generic — and so caught by Annex I point 4a — where the specification is not given in clear and prominent terms on the same medium)

Auf Deutsch: “erneuerbare Rohstoffe”

"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.

UCPD Article 6(1)(b) and Article 2(p) as amended by Directive 2024/825 (environmental characteristics are a main characteristic; a claim is generic — and so caught by Annex I point 4a — where the specification is not given in clear and prominent terms on the same medium)

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.

UCPD Article 6(1)(b) and Article 2(p) as amended by Directive 2024/825 (environmental characteristics are a main characteristic; a claim is generic — and so caught by Annex I point 4a — where the specification is not given in clear and prominent terms on the same medium)

Auf Deutsch: “Kreislaufwirtschaft”

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

Auf Deutsch: “Ressourcen schonen”, “Ressourcen zu schonen”

“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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim)

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.

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.

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.

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.

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.

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.

UCPD Article 6(2)(d) as inserted by Directive 2024/825 (future environmental performance)

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.

Directive 2005/29/EC, Annex I point 2a, inserted by Directive 2024/825 (sustainability label not based on a certification scheme, or not established by public authorities)

Seals and badges carry the visual authority of certification. If nothing independent stands behind the graphic, it is a prohibited label.

Directive 2005/29/EC, Annex I point 2a, inserted by Directive 2024/825 (sustainability label not based on a certification scheme, or not established by public authorities)

Auf Deutsch: “Nachhaltigkeitsbewertung”

A self-calculated score is a sustainability label under the Directive. Self-issued rating systems are exactly what point 2a targets.

Directive 2005/29/EC, Annex I point 2a, inserted by Directive 2024/825 (sustainability label not based on a certification scheme, or not established by public authorities)

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.

Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825 (generic environmental claim). Recital 9 states that a claim "combined with implicit claims such as colours or images" can be a generic environmental claim. Point 2a is NOT the basis unless the mark is a label: Article 2(q) defines a sustainability label as a "trust mark, quality mark or equivalent", which a decorative leaf is not

Self-approval dressed as endorsement. The Directive requires the scheme behind a label to be independent or public.

Directive 2005/29/EC, Annex I point 2a, inserted by Directive 2024/825 (sustainability label not based on a certification scheme, or not established by public authorities)

Auf Deutsch: “grüner als”

A comparison is only fair if the buyer can see what was compared, on which impacts, using which data. "Greener" discloses none of it.

UCPD Article 6(1) as amended by Directive 2024/825 (a comparative environmental claim is misleading where it cannot be substantiated); Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825, where the comparison is generic. Article 7(7) is NOT the basis — it governs traders who PROVIDE a comparison service, not traders comparing their own goods

Auf Deutsch: “nachhaltiger”

Combines the generic-claim problem with an undisclosed benchmark — vague on both the metric and the comparison set.

UCPD Article 6(1) as amended by Directive 2024/825 (a comparative environmental claim is misleading where it cannot be substantiated); Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825, where the comparison is generic. Article 7(7) is NOT the basis — it governs traders who PROVIDE a comparison service, not traders comparing their own goods

Aggregate superiority across all environmental impacts. Even a full LCA rarely supports it, because trade-offs between impact categories are normal.

UCPD Article 6(1) as amended by Directive 2024/825 (a comparative environmental claim is misleading where it cannot be substantiated); Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825, where the comparison is generic. Article 7(7) is NOT the basis — it governs traders who PROVIDE a comparison service, not traders comparing their own goods

Auf Deutsch: “umweltfreundlicher”

Comparative form of a term that is already too vague in its base form.

UCPD Article 6(1) as amended by Directive 2024/825 (a comparative environmental claim is misleading where it cannot be substantiated); Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825, where the comparison is generic. Article 7(7) is NOT the basis — it governs traders who PROVIDE a comparison service, not traders comparing their own goods

A superiority claim requiring evidence about the entire class — including competitor data you probably cannot access.

UCPD Article 6(1) as amended by Directive 2024/825 (a comparative environmental claim is misleading where it cannot be substantiated); Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825, where the comparison is generic. Article 7(7) is NOT the basis — it governs traders who PROVIDE a comparison service, not traders comparing their own goods

Leadership claims need a defined field, a defined metric and a ranking that someone else produced.

UCPD Article 6(1) as amended by Directive 2024/825 (a comparative environmental claim is misleading where it cannot be substantiated); Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825, where the comparison is generic. Article 7(7) is NOT the basis — it governs traders who PROVIDE a comparison service, not traders comparing their own goods

Auf Deutsch: “die Umwelt weniger belasten”, “Umwelt weniger zu belasten”

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%.

UCPD Article 6(1) as amended by Directive 2024/825 (a comparative environmental claim is misleading where it cannot be substantiated); Directive 2005/29/EC, Annex I point 4a, inserted by Directive 2024/825, where the comparison is generic

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.

Directive 2005/29/EC, Annex I point 23g, inserted by Directive 2024/825 (false durability claims) and 23d (software update information)

Inducing the consumer to replace or replenish a consumable earlier than technically necessary is blacklisted. Vague performance wording is the usual vehicle.

Directive 2005/29/EC, Annex I point 23i, inserted by Directive 2024/825 (inducing early replacement of consumables)

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.

Directive 2005/29/EC, Annex I point 23j, inserted by Directive 2024/825 (failure to disclose designed limitation with third-party parts)

Presenting an update as necessary when it merely enhances functionality is blacklisted. So is omitting that an update will degrade performance.

Directive 2005/29/EC, Annex I point 23e, inserted by Directive 2024/825 (presenting an update as necessary when it only adds features)

Generic upgrade nudges aimed at owners of functioning products edge into the durability-misrepresentation territory the amendment targets, especially alongside end-of-support messaging.

UCPD Article 6(1)(b) as amended by Directive 2024/825 (misleading as to the main characteristics, where the message implies the product no longer works or is unsupported when it does). Annex I point 23g is NOT the basis: it prohibits FALSELY CLAIMING a certain durability, and "time to upgrade" makes no durability claim at all

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.

UCPD Article 6(1)(b) as amended by Directive 2024/825. Annex I points 23f and 23g are cited here only as the neighbouring prohibitions: 23f requires a feature ACTUALLY INTRODUCED to limit durability and 23g a FALSE durability claim — neither can be established from wording alone, which is all this scan reads

Timer-based replacement prompts that ignore actual use induce earlier replacement than necessary. This is exactly the practice point 23i names.

Directive 2005/29/EC, Annex I point 23i, inserted by Directive 2024/825 (inducing early replacement of consumables)

Auf Deutsch: “BPA-frei”

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.

Directive 2005/29/EC, Annex I point 10a, inserted by Directive 2024/825 (requirements imposed by law on ALL products within the relevant product category, presented as a distinctive feature — the prohibition only bites where the duty covers the whole category, which this scan does not determine)

Auf Deutsch: “CE-zertifiziert”

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.

Directive 2005/29/EC, Annex I point 10a, inserted by Directive 2024/825 (requirements imposed by law on ALL products within the relevant product category, presented as a distinctive feature — the prohibition only bites where the duty covers the whole category, which this scan does not determine)

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.

Directive 2005/29/EC, Annex I point 10 (rights given to consumers in law, presented as a distinctive feature)

Auf Deutsch: “tierversuchsfrei”

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.

Directive 2005/29/EC, Annex I point 10a, inserted by Directive 2024/825 (requirements imposed by law on ALL products within the relevant product category, presented as a distinctive feature — the prohibition only bites where the duty covers the whole category, which this scan does not determine)

Auf Deutsch: “REACH-konform”

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.

Directive 2005/29/EC, Annex I point 10a, inserted by Directive 2024/825 (requirements imposed by law on ALL products within the relevant product category, presented as a distinctive feature — the prohibition only bites where the duty covers the whole category, which this scan does not determine)

Auf Deutsch: “RoHS-konform”

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.

Directive 2005/29/EC, Annex I point 10a, inserted by Directive 2024/825 (requirements imposed by law on ALL products within the relevant product category, presented as a distinctive feature — the prohibition only bites where the duty covers the whole category, which this scan does not determine)

Auf Deutsch: “CLP-gekennzeichnet”

Hazard labelling under Regulation 1272/2008 is required for classified substances and mixtures. Advertising it implies a voluntary safety step.

Directive 2005/29/EC, Annex I point 10a, inserted by Directive 2024/825 (requirements imposed by law on ALL products within the relevant product category, presented as a distinctive feature — the prohibition only bites where the duty covers the whole category, which this scan does not determine)

Auf Deutsch: “phthalatfrei”

The main phthalates are restricted or authorisation-only under REACH Annex XVII and XIV, so for most consumer goods absence is the legal baseline.

Directive 2005/29/EC, Annex I point 10a, inserted by Directive 2024/825 (requirements imposed by law on ALL products within the relevant product category, presented as a distinctive feature — the prohibition only bites where the duty covers the whole category, which this scan does not determine)