Regulation
Directive 2024/825, in the parts that affect a shop
Also called EmpCo, or ECGT, or — misleadingly — the Green Claims Directive. It amends the Unfair Commercial Practices Directive, and the amendments that matter most are additions to a blacklist where no misleadingness test applies.
Two directives, one nickname
“Green Claims Directive” usually refers to COM(2023)166, a separate proposal on substantiating and verifying environmental claims. It was never adopted. When people heard it had stalled, many concluded the rules had gone away.
They had not. Directive (EU) 2024/825 was adopted, is in force, and is the instrument that adds green claims to the blacklist of practices considered unfair in all circumstances. It applies from 27 September 2026.
Why the blacklist matters more than the general prohibition
Most of the Unfair Commercial Practices Directive works through a test: was the average consumer likely to be misled, and was their behaviour likely to change? That test gives a trader room to argue.
Annex I to Directive 2005/29/EC does not. A practice listed there is unfair in all circumstances — no evidence of consumer harm required, no defence that nobody was actually misled. The 2024 amendment put self-made labels, generic claims and offset-based neutrality claims on that list.
Who is caught
Any trader making environmental claims to consumers in the EU — including sellers based outside it. The rules follow the consumer, not the company. A US or UK shop selling into Germany is inside the scope, and the German wording of its claims is what will be assessed.
Timeline
How we got here
Including the year everyone assumed the rules had been dropped.
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March 2023
Two proposals, often confused
The Commission published the Green Claims Directive proposal, COM(2023)166, alongside work already under way on the Empowering Consumers Directive. Two separate instruments, one shared nickname — the source of most of the confusion since.
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6 March 2024
Directive (EU) 2024/825 published
The Empowering Consumers for the Green Transition Directive is published in the Official Journal, amending the Unfair Commercial Practices Directive and the Consumer Rights Directive.
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26 March 2024
Enters into force
Entry into force starts the transposition clock. Nothing changes for traders yet.
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2025
The Green Claims Directive stalls
The separate substantiation-and-verification proposal loses political support and is not adopted. This did not soften 2024/825 — the blacklist additions were never in the withdrawn text.
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27 March 2026
Transposition deadline
Member states must have the amendments in national law. Several were already ahead of it: France since 2023, Germany through UWG amendments.
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27 September 2026
Application begins
National rules start applying to commercial practices. From this date the blacklist bites directly.
Requirements
Six things a claim now has to survive
Specific, not generic
A generic environmental claim is only allowed where you can demonstrate recognised excellent environmental performance relevant to the claim. In practice that means an EU Ecolabel or an equivalent Type I scheme — not an internal assessment.
Scoped to what it covers
A benefit that applies to one component, one stage or one product line cannot be presented as applying to the whole product or the whole business.
Not built on offsetting
Claims that a product has neutral, reduced or positive environmental impact on the basis of purchased credits are prohibited outright. Buying credits is still lawful; using them to make the claim is not.
Labels backed by a scheme
A sustainability label must be based on a certification scheme or established by a public authority. Self-issued badges, scores and ticks are on the blacklist.
Future claims need machinery
Targets and pledges require clear, objective, publicly available and verifiable commitments, a detailed implementation plan, and independent third-party monitoring.
Durability messaging is regulated
Presenting an update as necessary when it merely adds features, prompting early replacement of consumables, and concealing designed limitations with third-party parts are all now blacklisted practices.
Annex I to Directive 2005/29/EC
Unfair in all circumstances
No misleadingness test, no defence that nobody complained. These are the additions that matter most to an online shop.
- Displaying a sustainability label not based on a certification scheme or established by public authorities (point 2a of Annex I to Directive 2005/29/EC, inserted by Directive 2024/825).
- Making a generic environmental claim without demonstrable recognised excellent environmental performance (point 4a).
- Making an environmental claim about the whole product or business when it concerns only one aspect (point 4b).
- Claiming neutral, reduced or positive environmental impact on the basis of emissions offsetting (point 4c).
- Presenting requirements imposed by law on all products in the category as a distinctive feature of the offer (point 10a).
- Presenting a software update as necessary when it only enhances functionality (point 23e).
- Any commercial communication about a good that contains a feature introduced to limit its durability, where the trader has information about that feature and its effect (point 23f). Disclosure does not cure it — the practice is listed, not the silence.
- Inducing the consumer to replace or replenish consumables earlier than technically necessary (point 23i).
A note on what this page is
A working summary written for people who have to fix product copy, not a legal opinion. Provisions are paraphrased, national implementations differ, and the transposing statute in your market is the text that governs. Where a decision turns on this, read the Directive and talk to a lawyer who practises in the relevant jurisdiction.
See which of your claims fall under it
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