Directive (EU) 2024/825 · 16 CFR Part 260
Green claims: the EU rules & the FTC Green Guides
ReferenceListrar documents this text; no dedicated record field yet.
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, was slated for withdrawal by the Commission in June 2025 and has not advanced since. 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
- 20 June 2025
- Commission announces the withdrawal of the Green Claims Directive proposal (COM(2023) 166); no progress since
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: September 22, 2026