Green claims: what is banned from 27 September

The five bans that always apply

The directive adds five green practices to the EU blacklist of commercial practices that are unfair “in all circumstances” (Annex I of Directive 2005/29/EC). It does not matter whether anyone was actually misled. If it is there, it is banned.

An environmental claim is not only text. The directive explicitly includes images, graphic elements, symbols, brand names, company names and product names. A product line called “EcoLine” or a green leaf next to the buy button can already be a claim.

• Climate neutral through offsetting (point 4c): claims that a product has a neutral, reduced or positive greenhouse gas impact because emissions were offset. The directive’s examples: “climate neutral”, “CO₂ neutral certified”, “carbon positive”, “climate net zero”, “climate compensated”, “reduced climate impact” and “limited CO₂ footprint”. Product means goods or services.
• Generic environmental claims without proof (point 4a): “environmentally friendly”, “eco-friendly”, “green”, “ecological”, “climate friendly”, “biodegradable” and the like, if you cannot demonstrate recognised excellent environmental performance. More in the next section.
• Your own labels (point 2a): a sustainability label that is neither based on a certification scheme with independent monitoring nor established by public authorities. This covers social labels too, such as a self-designed “fairly made” badge.
• Whole product when only part (point 4b): for example “made from recycled material” when only the packaging is recycled.
• Legal requirement as a feature (point 10a): presenting something as special to your offer that the law already requires for all products in that category in the EU. The directive’s example: “free from substance X” when substance X is banned for that product category anyway.

What stays allowed

You can still advertise green features. The way forward is being specific. A claim is no longer “generic” if you state clearly and prominently on the same medium what exactly it means. Online, that means on the same page, not somewhere in the FAQ. The directive’s example: “climate-friendly packaging” is generic, “100 % of energy used to produce this packaging comes from renewable sources” is specific. The specific claim still has to be true and verifiable.

Generic words like “eco-friendly” only work with recognised excellent environmental performance. The directive names three routes: the EU Ecolabel, an officially recognised EN ISO 14024 type I ecolabel in a member state (Germany’s Blue Angel describes itself as one), or top performance under other EU law, such as energy class A for “energy efficient”. The proof has to cover the whole claim. According to the directive, “sustainable”, “conscious” or “responsible” cannot rest on an ecolabel alone, because those words also promise social qualities.

You can still support climate projects and talk about it, as long as you do not claim your product becomes neutral or better through it. And a claim about the future (“climate neutral by 2030”) needs a public, verifiable implementation plan with measurable targets, regularly checked by an independent expert.

Word list: say this instead

What follows the arrow is a pattern, not a clearance. Every specific claim must be true and provable for your product before it goes live.

• “Climate neutral” (via offsetting) → “For every order, we give €1 to reforestation project X.” No “neutral”, no “compensated”.
• “Carbon neutral shipping” (via offsetting) → drop it, or say what actually happens: “Shipped in boxes made from 100 % recycled paper.”
• “Eco-friendly” or “green” → name the one property that is true: “Housing made from 70 % recycled plastic.”
• “Sustainable” → get specific: “Cover made from 100 % organic cotton.” Only if a certificate or supplier proof backs it up.
• “Made from recycled material” (packaging only) → “Packaging made from recycled cardboard.”
• “Biodegradable” → say where and how: “Industrially compostable to EN 13432, not for home compost.”
• “Reduced CO₂” → compared to what, measured how: “30 % less CO₂ in production than our 2023 model, calculated according to …”
• Your own “Eco Choice” badge → remove it. Use the specific fact or a real, certified label instead.
• “Free from …” for substances that are banned anyway → remove it.
• “Climate neutral by 2030” without a plan → remove it until a verified implementation plan is public.

How to check your shop

1. 1

   Export your product data

   Download all products as a CSV file; every common shop system can do this. You need titles, descriptions, short descriptions, variants, meta descriptions and image alt texts.

2. 2

   Search for word stems

   Search the sheet for: climate, carbon, co2, co₂, neutral, offset, compensat, eco, green, nature, natural, sustain, recycl, biodegrad, bio, plastic-free, fair, responsib, conscious, plus the same words in every language you sell in. Every hit goes on a list.

3. 3

   Look at images and symbols

   Leaves, globes, green ticks, your own badges in the theme, filters or categories like “Sustainable”. Also product photos where the packaging carries a climate promise.

4. 4

   Beyond the product page

   Home page, about page, shipping page, newsletter templates, order emails, marketplace listings, ads, bios and pinned posts on Instagram and TikTok.

5. 5

   Decide on every hit

   Prove it, make it specific or delete it. Keep your evidence: certificate, measurement, supplier declaration. In a dispute, you have to be able to show it.

What is still unclear

Even before the new rules, “climate neutral” was risky in Germany: on 27 June 2024 the Federal Court of Justice ruled that an ambiguous environmental term like “climate neutral” has to be explained in the advertisement itself (I ZR 98/23). From 27 September, an explanation no longer saves an offsetting-based claim; the claim is banned.