On 27 September 2026, a handful of phrases that fill fashion product pages became unlawful to use in the EU: "eco-friendly", "sustainable" collections, "carbon neutral" shipping and "kind to the planet". None of them is now a matter of tone or best practice. Under the Empowering Consumers Directive, each one sits on a list of commercial practices banned in all circumstances.
This is the part of the green claims conversation that small brands most often get wrong, because the law that actually applies is not the one with the famous name. The Green Claims Directive is still a proposal. The rules in force come from Directive (EU) 2024/825, usually called EmpCo, which amended the Unfair Commercial Practices Directive. This article covers what changed, which claims are now banned with examples of the wording small brands typically use, what to write instead and a self-check to run on your own copy.
What Changed on 27 September 2026
EmpCo added new entries to Annex I of the Unfair Commercial Practices Directive, the blacklist of practices that are unfair without any case-by-case test. If a claim falls under one of these points, it does not matter whether a shopper was actually misled.
Three facts decide whether this applies to your brand:
- It is EU-wide. Every member state was due to transpose it by 27 March 2026, and it has applied since 27 September 2026. Transposition is uneven, and the Commission opened infringement proceedings against 20 member states in May, but the safe position is to comply everywhere.
- There is no small-business exemption. A two-person label selling on Shopify is in the same position as a high-street chain.
- There is no grandfathering for copy already published. The rules apply to what a consumer sees today, including product pages written in 2023. EU consumer authorities have agreed a phased approach for physical old stock, such as printed swing tags made before the date, where a brand has a documented plan to correct it. Online claims get no such latitude and are named as a priority for review.
Scope follows the consumer, not the brand. A UK or US brand selling direct to shoppers in the EU is covered for the copy those shoppers see.
The Claims That Are Now Banned
Generic environmental claims (point 4a)
A generic environmental claim is a broad statement of environmental merit that is not specified in clear and prominent terms on the same medium. Point 4a bans these unless the brand can show recognised excellent environmental performance relevant to the claim. That bar is narrow: an EU Ecolabel, or an officially recognised EN ISO 14024 type I ecolabel such as the Nordic Swan or the Blue Angel. A Life Cycle Assessment (LCA), however careful, does not meet it.
Typical wording that now falls foul of point 4a:
| On the page today | Why it fails | Write instead |
|---|---|---|
| Our "eco-friendly" hoodie | Generic, no ecolabel | "80% organic cotton (certified), 18% recycled polyester" |
| "Kind to the planet" (Instagram caption) | Generic, no ecolabel | The measured fact: "X kg CO₂e per hoodie, cradle to gate", with X calculated for that product |
| "Responsibly made" | Generic, no ecolabel | Name what was done: the factory, the process, the measured figure |
| "Climate friendly" or "carbon neutral" | Generic carbon wording, caught by 4a on its own | Remove it, or state the measured figure and its boundary |
The Commission's guidance is explicit that generic carbon wordings such as "carbon neutral" and "climate neutral" fall under point 4a independently of the offsetting ban below.
Whole-product claims about one part (point 4b)
Point 4b bans an environmental claim about the entire product, or the entire business, when it really concerns only one aspect. A T-shirt with 18% recycled polyester cannot be sold as "made from recycled materials". A brand that switched its mailers to paper cannot call itself "plastic-free".
The fix is to scope the claim to what is true: "18% recycled polyester by weight", "shipped in paper mailers".
Offset-based carbon claims (point 4c)
Point 4c bans claiming that a product has a neutral, reduced or positive impact on greenhouse gas emissions on the basis of offsetting. "Carbon neutral" delivery, thanks to a tree-planting partner, is the classic small-brand version.
Two things remain open. Brands can still describe investment in climate projects, as long as it is transparent and not misleading: "We fund a reforestation project in Scotland. This does not reduce the footprint of the products we sell." And the Commission's guidance confirms that point 4c does not apply to a reduced-impact claim resting on the product's actual footprint within its own value chain, substantiated by proper life cycle assessment. Measured reductions are not offsets, though a reduction claim still has to be accurate and clear about what it is compared with.
Labels, Badges and Future Promises
Home-made sustainability badges (point 2a). Many small brands add an icon of their own design: a leaf, a "Conscious Choice" badge, an "Earth Edit" tag on a collection page. EmpCo bans displaying a sustainability label that is not based on a certification scheme or established by public authorities. A certification scheme here means independent third-party checks, published requirements and monitoring by an independent body. A badge your designer drew does not qualify, and there is no transition period.
Legal requirements dressed as features (point 10a). Presenting something the law requires of every product in the category as a selling point is banned. "Free from banned azo dyes" is an example: those dyes are restricted for every textile of that kind sold in the EU.
Future-performance claims. "Net zero by 2030" and "carbon neutral" by 2028 are not banned outright, but they now need a detailed and realistic implementation plan with measurable targets, checked by an independent third-party expert whose findings are made available to consumers. For most small brands, the honest answer is to remove the promise until that plan exists.
What Is Still Allowed
EmpCo does not ban talking about the environment. It bans claims that are vague, overstated or bought. What survives is the claim that is specific, substantiated and scoped:
- Specific. It names the material, the share, the process or the figure. "70% recycled polyester" rather than "recycled".
- Substantiated. The brand holds the evidence: a certificate, a supplier document, a calculation with a stated method.
- Scoped. It says what it covers. "Cradle to gate" for a footprint. "This style" rather than "our clothes".
Product-level figures are the strongest version of this, and our guide to green claims sets out the wider rules. A climate impact in kilograms of CO₂e per garment, calculated for that product with a stated method and boundary, is not a generic claim. Neither is a water scarcity impact stated per garment. They are measurements, and they can sit on a product page beside the material breakdown. For how those figures are produced, our guide to Life Cycle Assessment for brands covers the method.
One related duty lands on the same date. The other half of EmpCo amends the Consumer Rights Directive, and since 27 September 2026 every point of sale, online included, must show the EU's harmonised notice on the two-year legal guarantee in a fixed format. Our article on what it costs to sell into the EU in 2026 sets it alongside the rest of the market-access stack.
A Quick Self-Check for Your Copy
Run this across product pages, collection pages, the About page, email templates, Instagram captions, swing tags and the product names themselves. EmpCo counts brand and product names as possible claims.
- Search for the generic words. "Eco", "green", "sustainable", "conscious", "responsible", "natural", "planet-friendly", "climate friendly" and "carbon neutral". Each hit needs rewriting unless you hold an EU Ecolabel or type I ecolabel for that product.
- Check every "made from" claim against the composition. If the claim describes the whole product, does the whole product meet it?
- Find any mention of offsetting near a product. If a product claim rests on offsets, remove the claim and keep, if you want, a transparent description of the investment.
- List every badge and icon. For each one, name the certification scheme or public authority behind it. If you cannot, remove it.
- Look for future promises. If there is no independently checked implementation plan, take them down.
- Look for legal minimums sold as features. If every competitor must meet it too, it is not a feature.
- Check that each surviving claim has a document behind it that you could send to an authority the same day.
How ENVRT Approaches Green Claims
ENVRT calculates product-level climate impact (CO₂e) and water scarcity impact (AWARE) for each garment, cradle to gate, with ENVRT LAB™, aligned with ISO 14040 and ISO 14044 and the PEFCR for apparel and footwear. Those figures give a brand something specific and substantiated to say in place of a generic word, scoped to one product and one boundary.
On the Pro plan, "Can I say this?" under Compliance in the ENVRT dashboard lets a brand paste a sentence and get a plain verdict on point 4a and 4c wording, the reason and measured facts from its own product data to use instead. It flags wording. It never says a claim is lawful or gives an all-clear, because that judgement depends on the full context in which the claim appears.
If you want to replace generic claims with figures measured for your own products, get in touch with the ENVRT team.
