Who regulates a green claim, and how
Three jurisdictions, three different instruments, and one EU directive that starts applying this month. The rules are not converging, and a claim that is lawful in one market can be an offense in another.
Directive (EU) 2024/825 becomes applicable. Generic environmental claims without demonstrated performance, and sustainability labels without certified or authorised backing, become prohibited commercial practices across the EU.
The directive amends the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). Rather than creating a new green-claims regime from scratch, it adds specific practices to the existing blacklist — which means enforcement runs through consumer protection machinery that already exists in every Member State.
| Milestone | Date |
|---|---|
| Adopted | 28 February 2024 |
| Entered into force | 26 March 2024 |
| Member State transposition deadline | 27 March 2026 |
| Applies from | 27 September 2026 |
What becomes prohibited
- Unsubstantiated generic claims. Assertions such as "eco-friendly" without demonstrated environmental performance.
- Unaccredited sustainability labels. Displaying a sustainability label not based on a certification scheme or established by public authorities.
- Misleading offsetting claims. Claims about offsetting greenhouse gas emissions that obscure a product's true environmental impact.
- Durability and reparability deception. False statements about how long a product lasts or how repairable it is, and undisclosed features designed to limit its lifespan.
The two EU instruments that keep getting confused
| Instrument | What it is | Status |
|---|---|---|
| Empowering Consumers for the Green Transition Directive (EU) 2024/825 | Amends existing consumer law to prohibit specific green-claim practices | Adopted and in force. Applies from 27 September 2026. |
| Green Claims Directive proposal | A separate, broader proposal covering substantiation and verification of explicit environmental claims | A different instrument. See the open item below. |
The UK took a different route. Rather than new prohibitions, the Competition and Markets Authority issued guidance on how existing consumer protection law applies to environmental claims. The obligations were always there; the code explains them.
The six principles
Claims must be truthful and accurate
Correct information, without overstating sustainability or positive environmental impact.
Claims must be clear and unambiguous
Wording transparent and straightforward enough that consumers understand the message without confusion.
Claims must not omit or hide important information
Material details consumers need to make an informed decision cannot be left out.
Comparisons must be fair and meaningful
Like compared with like, using clear, objective and current information.
Claims must consider the full life cycle
Every stage from manufacturing to disposal factors into whether a claim is accurate rather than deceptive.
Claims must be substantiated
Robust, credible, relevant and current evidence behind the assertion.
The US approach is enforcement-led. The Federal Trade Commission regulates fiber naming under the Textile Rules and polices environmental claims under the FTC Act, requiring that sellers hold competent and reliable evidence — scientific tests and analyzes — for the claims they make. Relying on a supplier's assurance is explicitly not substantiation.
In April 2022 it collected $5.5 million in civil penalties from two retailers over bamboo labelling and the associated environmental claims, twelve years after warning the industry in writing. That record is set out on our page on bamboo fabric.
What this means in practice
- The strictest jurisdiction sets your copy. Product pages, packaging and labels cross borders. Writing to the EU test is simpler than maintaining regional variants of the same claim.
- Generic adjectives are the exposure. "Eco-friendly", "green" and "conscious" are precisely what the EU directive targets when unsubstantiated. Specific, evidenced claims are safer than vague favorable ones — which inverts the usual marketing instinct.
- Your labels are now part of your compliance surface. Which schemes sit behind the marks on your packaging is now a legal question.
Common questions
When does the EU green claims law take effect?
Directive (EU) 2024/825 applies from 27 September 2026. Member States were required to transpose it into national law by 27 March 2026. It entered into force on 26 March 2024, having been adopted on 28 February 2024.
Is "eco-friendly" still allowed in the EU?
Only with evidence. From 27 September 2026 a generic environmental claim such as "eco-friendly" is a prohibited commercial practice where the trader cannot demonstrate recognized excellent environmental performance relevant to the claim. The word is not banned; unsubstantiated use of it is.
Is the Green Claims Directive the same as Directive 2024/825?
No. They are separate instruments. Directive (EU) 2024/825, Empowering Consumers for the Green Transition, is adopted, in force and applies from 27 September 2026. The Green Claims Directive is a distinct proposal covering substantiation and verification of explicit claims; commentaries report the Commission announced an intention to withdraw it and describe its status as unclear.
Can I still display a sustainability label on packaging in the EU?
Only if it is based on a certification scheme or established by public authorities. From 27 September 2026, displaying a sustainability label without that backing is a prohibited practice. Labels must meet minimum standards of transparency and credibility with independent third-party monitoring.
What are the CMA's six green claims principles?
Claims must be truthful and accurate; clear and unambiguous; must not omit or hide important information; comparisons must be fair and meaningful; claims must consider the full life cycle of the product or service; and claims must be substantiated.
Does the UK follow the EU rules on green claims?
No. The UK regulates environmental claims through existing consumer protection law, with the CMA's Green Claims Code explaining how it applies. That code was published on 20 September 2021 and last updated on 3 June 2026.
Who enforces green claims in the United States?
The Federal Trade Commission, under the FTC Act and the Textile Fiber Products Identification Act. Sellers must hold competent and reliable evidence for their claims; a supplier assurance does not count. In April 2022 the FTC collected $5.5 million in civil penalties over bamboo labelling and related environmental claims.
What this page does not settle
Open items
- The status of the Green Claims Directive proposal. Multiple legal commentaries report that the Commission announced an intention to withdraw it and describe the position as unclear. No primary Commission source confirming its current status was located, so none is asserted here.
- National transposition detail. The directive sets a floor; Member States implement it in national law and may go further.
- Penalties under 2024/825. Sanctions are set at Member State level and are not covered here.
- UK divergence. Whether and where the CMA and EU tests produce different outcomes in practice has not been analyzed here.
Sources and method
- European Union. Directive (EU) 2024/825 of 28 February 2024. EUR-Lex · European Commission
- Competition and Markets Authority. Green Claims Code. gov.uk
- Federal Trade Commission. Business guidance on bamboo textiles.
ftc.gov
The numeric tests inside the Green Guides are set out on what the FTC Green Guides require.
Dates, prohibitions and principles are taken from the legislative text and the issuing authorities' own guidance. The six CMA principles are reproduced as the CMA states them. Where a status is contested it is recorded as an open item rather than settled from secondary legal commentary, however consistent that commentary is.
Sources verified 13 September 2026.