Directive (EU) 2024/825 · 16 CFR Part 260
Green claims: the EU rules & the FTC Green Guides
Listrar summary
The era of the free-floating 'eco-friendly' label is closing. In the EU, Directive 2024/825 amends consumer law to ban generic environmental claims that cannot be backed by recognised excellent performance, carbon-neutrality claims built on offsetting, and sustainability labels that are not grounded in a certification scheme — applying from 27 September 2026. A second text, the Green Claims Directive on how claims must be substantiated, remains a proposal with an uncertain fate. In the US, the FTC's Green Guides play the same role through enforcement. The common thread: a claim is either substantiated by evidence, or it is a liability.
Who does it apply to?
- Any trader making environmental claims to EU consumers — B2C, all channels
- Operators of sustainability labels and certification marks
- US-market advertisers, under the FTC Act as read through the Green Guides
- Marketplaces, whose listings inherit their sellers' claims
Main obligations
- Drop generic claims — 'green', 'eco', 'climate-friendly' — unless recognised excellent performance can be shown
- Stop claiming neutrality on the strength of offsets alone
- Base any future environmental promise on a verifiable, published commitment path
- Use only sustainability labels backed by a certification scheme or public authority
- Hold the substantiation file before the claim is published, not after the complaint
Key dates
- 6 March 2024
- Directive (EU) 2024/825 published; in force 26 March 2024
- 27 March 2026
- Transposition deadline — national laws in place
- 27 September 2026
- The new rules apply to traders
- Since 2012
- FTC Green Guides, 16 CFR 260 — revision under review since 2022
- Pending
- Green Claims Directive (substantiation) still a proposal; progress stalled in 2025
Products in scope
- Every product marketed with an environmental angle — the scope follows the claim, not the category
- Highest exposure: textiles, cosmetics, food, packaging, energy-consuming goods
Obligations by actor
- Brand
- Inventory every live claim; attach evidence or retire it before September 2026
- Label operator
- Run a genuine certification scheme or the label becomes illegal in the EU
- Marketplace
- Police claim language in listings; the DSA makes ignoring it costly
- US advertiser
- Qualify claims per the Green Guides; keep substantiation current
Documents and evidence to keep
- A claim register: every public environmental statement, mapped to its proof
- Test reports, LCAs and certificates with validity windows and issuers
- The certification-scheme documentation behind any label you display
- Records of when claims were published, amended and retired
Sanctions and risks
- EU: unfair-commercial-practice sanctions, including fines reaching at least 4 % of turnover for cross-border infringements
- Competitor and NGO actions — greenwashing litigation is now routine
- US: FTC enforcement — injunctions, consent orders, civil penalties in rule-based cases
- The quiet one: platforms delisting products whose claims fail their checks
Key articles
- Directive (EU) 2024/825 — the 'empowering consumers' amendments — full text
- COM(2023) 166 — the Green Claims Directive proposal (substantiation)
- 16 CFR Part 260 — the FTC Green Guides
Official text
Last verified by Listrar: 14 August 2026