Adopted in February 2024, the Directive on Empowering Consumers for the Green Transition amends two existing pieces of EU consumer protection legislation: the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD). The directive addresses misleading environmental claims, unreliable sustainability labels and commercial practices that encourage unnecessary product replacement. It also strengthens requirements concerning product durability, repairability and guarantee information, helping consumers make more informed purchasing decisions. EU Member States were required to transpose the directive into national law by 27 March 2026, with the new rules applying from 27 September 2026. Its implementation marks an important development in the EU’s efforts to address greenwashing through stronger consumer protection.
The directive introduces several changes to how businesses communicate environmental performance and product sustainability.
Generic environmental claims such as “eco-friendly,” “green” and “environmentally friendly” are prohibited when businesses cannot demonstrate recognised excellent environmental performance relevant to the claim. Broad claims about an entire product or business may also be misleading when the stated environmental benefit relates only to a specific feature or activity. Businesses should ensure that environmental claims are specific, accurate and supported by appropriate evidence. A clear and prominent specification provided on the same medium may prevent a claim from being classified as generic. However, the claim must still comply with the other applicable requirements and must not mislead consumers.
The directive prohibits displaying sustainability labels that are not based on qualifying certification schemes or established by public authorities. Certification schemes must meet the applicable requirements, including transparency and appropriate verification. Businesses using sustainability labels, certification marks or environmental logos should review their eligibility, validity and scope to ensure that the labels accurately represent the environmental attributes being communicated.
The directive prohibits claims that a product has a neutral, reduced or positive greenhouse gas impact based on emissions offsetting. Purchasing carbon credits does not, by itself, demonstrate that a product’s own greenhouse gas emissions have been reduced. Businesses should therefore distinguish between actual product-level emissions reductions and offsetting when communicating their climate performance.
The rules address misleading claims about product lifespan and repairability, as well as practices that encourage consumers to replace consumables earlier than technically necessary. They also strengthen information requirements concerning legal guarantee rights and introduce a harmonised notice and label to help consumers identify qualifying extended commercial durability guarantees. Manufacturers and retailers should ensure that product descriptions, repairability claims and warranty information accurately reflect the characteristics of the products they sell.
Claims about future environmental performance must be supported by clear, objective, publicly available and verifiable commitments. These must be set out in a detailed and realistic implementation plan containing measurable, time-bound targets and the resources needed to achieve them. The plan must also undergo regular verification by an independent third-party expert, with findings made available to consumers. For businesses announcing long-term environmental ambitions, this reinforces the need to connect public commitments with credible implementation plans and demonstrable progress.
The directive is relevant to businesses whose commercial practices involve marketing or selling products to consumers in the EU. This includes manufacturers, distributors, retailers and other traders, depending on their activities. Companies based outside the EU may also need to assess their practices when marketing products directly to EU consumers. To prepare for the new requirements, businesses should review the following areas:
𝗠𝗮𝗿𝗸𝗲𝘁𝗶𝗻𝗴 𝗮𝗻𝗱 𝗰𝗼𝗺𝗺𝘂𝗻𝗶𝗰𝗮𝘁𝗶𝗼𝗻𝘀: Review websites, product descriptions, packaging, advertising campaigns and social media content to identify potentially misleading environmental claims.
𝗦𝘂𝘀𝘁𝗮𝗶𝗻𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗱𝗮𝘁𝗮 𝗮𝗻𝗱 𝗲𝘃𝗶𝗱𝗲𝗻𝗰𝗲: Ensure that environmental claims are supported by reliable information, including relevant emissions data, product details and certification records.
𝗦𝘂𝗽𝗽𝗹𝗶𝗲𝗿 𝗮𝗻𝗱 𝘃𝗮𝗹𝘂𝗲-𝗰𝗵𝗮𝗶𝗻 𝗶𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: Verify the accuracy of supplier disclosures and other information used to substantiate product-level environmental claims.
𝗣𝗿𝗼𝗱𝘂𝗰𝘁 𝗶𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻 𝗮𝗻𝗱 𝗰𝗲𝗿𝘁𝗶𝗳𝗶𝗰𝗮𝘁𝗶𝗼𝗻𝘀: Check sustainability labels, durability claims, repairability information and guarantee-related communications for accuracy.
𝗜𝗻𝘁𝗲𝗿𝗻𝗮𝗹 𝗴𝗼𝘃𝗲𝗿𝗻𝗮𝗻𝗰𝗲: Establish clear responsibilities across sustainability, legal, product and marketing teams to review and approve environmental claims before publication.
For senior management, the priority is to embed these requirements into business processes rather than treat them as a marketing-only exercise. Clear accountability and cross-functional coordination can help ensure that sustainability claims remain accurate, consistent and supported by evidence.
While the Empowering Consumers for the Green Transition Directive strengthens existing EU consumer protection rules, the separate proposed Green Claims Directive was intended to introduce additional requirements for substantiating and verifying explicit environmental claims. The proposed Green Claims Directive has faced significant delays. In June 2025, the European Commission announced its intention to withdraw the proposal, and the planned negotiations were cancelled. However, the proposal has not been formally withdrawn and remains listed as pending in the Commission's legislative information. Businesses should monitor further developments rather than treat the proposed requirements as enacted law. For organisations reviewing their compliance obligations, the priority is to address the requirements applicable under Directive (EU) 2024/825 while keeping track of relevant developments in the wider EU regulatory framework.
Meeting the new requirements calls for more than revising marketing language. Businesses need reliable environmental data, documented evidence and internal processes that ensure claims accurately reflect their performance. Cognitud Advisory helps organisations strengthen these areas through improved sustainability data management, governance and communications. Cognitud can support businesses in reviewing environmental claims across websites, product descriptions, marketing campaigns and corporate communications to identify potentially misleading statements and gaps in supporting evidence. We also help organisations align climate commitments with measurable targets, strengthen sustainability data management and improve internal processes for reviewing sustainability-related information. By connecting sustainability data with governance and communication, Cognitud helps businesses develop more transparent and evidence-based approaches to environmental claims. This can support regulatory preparedness, reduce the risk of misleading representations and strengthen confidence among consumers and other stakeholders.
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Abhigyan Gupta
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An Environmental Impact Statement (EIS) assesses the potential environmental effects of a proposed project and identifies measures to minimize adverse impacts.
Carbon credits are tradable units that typically represent one metric tonne of carbon dioxide equivalent (CO₂e) reduced, avoided or removed through a climate project.
Carbon credits are calculated by measuring verified emissions reductions or removals against an established baseline, using an approved methodology and accounting for relevant uncertainties.
The natural greenhouse effect keeps Earth warm enough to support life. However, rising greenhouse gas concentrations intensify this effect, causing global warming and climate change.
Yes, greenwashing can be illegal when environmental claims are false, misleading or violate applicable laws. Regulations vary by jurisdiction, including the EU’s stricter rules on misleading green claims.
