Methodology1 Aug 2026by Haydn

Generic “eco-friendly” claims become illegal in eight weeks. Here’s what will count instead.

From 27 September 2026, generic claims like “eco-friendly” and offset-based “carbon neutral” become unlawful in the EU under Directive 2024/825. Here’s what evidence will count — with real examples.

On 27 September 2026 — eight weeks from now — the EU's Empowering Consumers Directive (2024/825) starts to apply across all 27 member states.1 From that date, consumer-facing environmental claims change category: from marketing copy to regulated statements. There is no transition period, and the rules cover products already on shelves.2

What stops being allowed, in plain terms:

Generic claims without proof. "Eco-friendly," "green," "sustainable," "climate neutral" — banned unless backed by recognised, demonstrable performance. A generic environmental claim used without substantiation becomes an unfair commercial practice.3 For the first time, the cheapest green claim becomes the most expensive one to defend.

Offset-based neutrality claims. "Carbon neutral" built on purchased credits is no longer lawful under the directive's blacklist — regardless of volume or credit type.3 Claims must rest on what a product or company actually emits, not what it paid to cancel out.

Unverified promises. Future claims — "net zero by 2040" — need a real implementation plan and independent verification behind them.3 Ambition without a published, checkable plan no longer counts as a claim you can make.

Labels without standards. Sustainability labels must come from a public authority or a certification scheme with independent third-party verification. Self-awarded badges end.2

One honest caveat: this is a directive enforced through national consumer authorities, so the first months will not look identical in every member state. The direction, though, is uniform — and a distinction worth knowing: the practices above sit on the directive's blacklist, banned outright with no case-by-case test, while other environmental claims remain subject to the general misleading-practices assessment.

Why this is good news

If your company does genuine environmental work, this law is on your side.

For years, a company that measured its footprint, published the numbers, and set a real target has competed on the same shelf as a company that printed a leaf on the packaging. The measured company paid for assurance and disclosure; the leaf was free. From September, the leaf becomes a liability — and specific, evidenced claims become the only kind that survive.

That inverts the economics of honesty. The unglamorous work — registry filings, assured inventories, validated targets — becomes the legal permission to talk about any of it. Put another way: companies that already invested in emissions reporting are about to discover their compliance costs have quietly become marketing assets.

What counts as evidence

We review environmental evidence for a living — every score on this index is built from it — so here is what the strong version looks like in practice, from companies we've scored:

Registry filings under your own name. France's ADEME registry, the UK's SECR regime, Germany's DEHSt, India's BRSR — official, public, entity-level. When LYOVEL, a French vending operator, pointed us to its own BEGES filing on the ADEME registry, it carried scope figures, a per-category breakdown, and 2030 targets — filed, dated, attributable. That is what a substantiated claim rests on. (It also moved their score from 42 to 49 — evidence works in both directions of this relationship.)

Third-party assurance. Harmony Gold's emissions reporting carries ISAE 3000 assurance and a CDP Water 'A' — the kind of independently verified evidence that will be far easier to defend under the new rules, and the reason they lead a sector where our baseline expectations are second-lowest.

Specific claims about one named thing. The directive still allows precise, substantiated statements — "this product's packaging is 80% recycled content, certified by X" survives where "eco-friendly" dies.3 Fairphone has built its entire public case this way: specific, sourced longevity and repairability claims rather than a green halo — and it shows in a 64/100.

The pattern across all three: named entity, published number, independent check. If a claim can't point to those, eight weeks from now it isn't a claim — it's a risk.

A quiet test you can run today

Whoever runs it — your own team, an auditor, or an index like ours — the test is the same: take each consumer-facing claim you make and ask whether it points to a named entity, a published number, and an independent check. Claims that pass need nothing. Claims that don't have eight weeks.

(Every SINK company page runs the public half of that test, free, for every company we cover — and it's open to challenge; the best one we received this summer permanently improved how we score. Full methodology: /methodology.)

Eight weeks. The companies with the evidence already filed have nothing to do but keep going. From 27 September, environmental claims stop being a branding exercise — they become an evidence exercise. The winners won't be the companies with the greenest marketing. They'll be the companies with the strongest evidence.

  1. 1. Directive (EU) 2024/825, adopted 28 February 2024, amending the Unfair Commercial Practices Directive and Consumer Rights Directive; member-state transposition deadline 27 March 2026, application from 27 September 2026.
  2. 2. European Commission FAQ on the directive (first edition November 2025, updated 18 May 2026); rules apply to products already on the market.
  3. 3. Directive (EU) 2024/825, Annex provisions on generic environmental claims, offset-based claims, and future environmental performance claims; sustainability-label requirements per the amended UCPD.
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