Green claims in shop texts: the new EU rules

What changes and since when

Directive (EU) 2024/825 amends the EU directive on unfair commercial practices (2005/29/EC), which is about how traders deal with consumers. Member States had to adopt and publish their rules by 27 March 2026 and apply them from 27 September 2026 (Article 4).

Germany put the rules into the Act against Unfair Competition (UWG) with the Third Act amending the UWG of 12 February 2026 (BGBl. 2026 I No. 43). It entered into force on 27 September 2026; one provision already applied from 19 June 2026. A transition rule, § 15b UWG, covers goods placed on the market before that date: claims over breaches of the new rules are to be made in good faith and in proportion. § 15b will be deleted on 27 September 2028.

Poland amended its act on counteracting unfair market practices with the act of 4 September 2026 (Dz.U. 2026 item 1353), published on 19 October 2026. According to its Article 3, it enters into force on 27 September 2027. If you sell in Poland, ask an expert what this means for you.

What counts as an environmental claim

The directive defines the term broadly: any message not required by law that states or suggests that a product, brand or trader is good for the environment, does no harm, does less harm than others or has improved over time. Text counts, and so do images, symbols, labels and brand, company or product names. A green leaf next to a product name can be a claim, too.

A claim is generic if it is not on a sustainability label and its specification is not given clearly and prominently on the same medium. ‘Eco-friendly’ on its own is generic.

New entries on the list of bans

Annex I of the directive lists practices that are unfair in all circumstances, without a case-by-case test. The directive adds:

• 2a: displaying a sustainability label that is not based on a certification scheme and not established by public authorities.
• 4a: a generic environmental claim when the trader cannot demonstrate recognised excellent environmental performance relevant to the claim.
• 4b: a claim about the entire product or business when it only concerns one aspect or one activity.
• 4c: claiming, based on offsetting greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment.
• 10a: presenting requirements that the law sets for all products of a category as a special feature of your offer.

In Germany, the same points are in the annex to § 3(3) UWG (No. 2a, 4a, 4b, 4c and 10a), the list of practices always unlawful towards consumers. In Poland, the 2026 act adds them to art. 7.

Generic words such as ‘eco-friendly’

The recitals give examples of generic claims: ‘environmentally friendly’, ‘eco-friendly’, ‘green’, ‘nature’s friend’, ‘ecological’, ‘climate friendly’, ‘gentle on the environment’, ‘energy efficient’, ‘biodegradable’ and ‘biobased’. Such a claim needs recognised excellent environmental performance: the EU Ecolabel, an officially recognised type I ecolabel under EN ISO 14024 or top performance under other EU law.

The recitals also show the way out. ‘Climate-friendly packaging’ is generic. ‘100 % of energy used to produce this packaging comes from renewable sources’ is specific and not covered by this ban, but it still has to be true and must not mislead.

Sustainability labels

A sustainability label is a voluntary trust mark or quality mark, public or private, for environmental or social characteristics. Labels required by law do not count. A voluntary label may now only be shown if it is based on a certification scheme or set up by public authorities.

Such a scheme is run by third parties and has public requirements. It is open to all traders on fair terms, its requirements are developed with experts and stakeholders, it can withdraw the label and an independent party monitors the traders. A ‘green choice’ badge that a shop designs itself has none of this. Check every badge and seal on your pages.

‘Climate neutral’ through offsetting

Point 4c covers claims of a neutral, reduced or positive climate impact that rest on offsetting. The recitals name ‘climate neutral’, ‘CO2 neutral certified’, ‘carbon positive’, ‘climate net zero’, ‘climate compensated’, ‘reduced climate impact’ and ‘limited CO2 footprint’. Such claims should only be possible when based on the actual lifecycle impact of the product. You may still report investments in climate projects if you do it in a way that does not mislead: say what you support, not what your product supposedly is.

Claims about the future

‘Climate neutral by 2030’ is a claim about future performance. It is misleading without clear, objective, public and verifiable commitments in a detailed and realistic implementation plan with measurable, time-bound targets and resources. An independent expert has to verify the plan regularly, and consumers must be able to see the findings. In Germany this is § 5(3) No. 4 UWG, in Poland art. 5(2) point 6 of the amended act. It is assessed case by case.

How to word a claim specifically

1. 1Name the part: the packaging, the cap or the box, not the whole product.
2. 2Give the figure and its basis: share, unit, period, method.
3. 3Put the explanation right next to the claim, on the same page, pack or ad.
4. 4Keep the evidence: certificates, measurements, supplier documents, each with a date.
5. 5Remove leaves, globes and symbols that suggest more than you can prove.
6. 6Check your claims again when a material, supplier or process changes.

Example: instead of ‘Our eco-friendly bottle’, write ‘The bottle is made of [share] % recycled plastic, confirmed by [certificate].’ Fill in the brackets only with facts you can prove.

Work with Do4U

Green claims check reads a page address or a pasted shop or ad text. Word lists in English, German and Polish find generic claims, offsetting claims, claims about material and packaging, label names and future claims, and the code quotes each passage word for word. The AI rates each one: type, risk, the rule of Directive (EU) 2024/825, the reason, the evidence you need and a more specific wording with placeholders. The code checks every quote and removes wordings with figures that are not in your text. It does not see claims in images or logos and does not know your evidence.

Do4U finds hints and builds a draft. It never says that a claim is allowed. You check each passage against your evidence and decide.