Generic green claims and eco-labels without proper backing are now on the EU blacklist

Directive 2024/825 entered into application on September 27

According to the European Commission's sustainable consumption page, Directive (EU) 2024/825 amends the Consumer Rights Directive and the Unfair Commercial Practices Directive to tighten the rules against greenwashing and early obsolescence. It was adopted on February 28, 2024, and Member States had until March 27, 2026 to transpose it. The page puts the milestone in one line: "Since 27 September 2026, the Directive entered into application."

The same page lists a Questions and Answers document dated September 22, 2026. It presents preliminary views of Commission services, not a legally binding interpretation; only the Court of Justice of the EU can interpret EU law authoritatively. Travel trade outlet Skift reported that the law took effect on Sunday; Skift calls it EmpCo, while the Q&A uses the short name ECGT Directive.

Three bans: generic claims, unbacked labels and offset-based climate claims

The changes add entries to Annex I of the Unfair Commercial Practices Directive (UCPD), the blacklist of practices banned in all circumstances, with no need to prove an effect on the average consumer's decisions. Point 4a bans generic environmental claims where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. A claim is generic when it is not part of a sustainability label and its specification is not spelled out clearly and prominently on the same medium; the recital examples include ‘environmentally friendly’, ‘eco-friendly’, ‘green’ and ‘climate friendly’. Unqualified ‘climate-friendly packaging’ is generic, whereas saying that 100 percent of the energy used to make the packaging is renewable is a specific claim outside this ban, though the rest of the UCPD still applies. Recognised excellent performance can be shown through the EU Ecolabel, officially recognised EN ISO 14024 type I ecolabels such as the Nordic Swan or Blue Angel, or top performance under other Union law such as the Energy Labelling Regulation.

Point 2a bans showing a sustainability label unless it rests on a certification scheme or was set up by a public authority. A certification scheme needs independent third-party verification, publicly available requirements and monitoring by a competent, independent third party, with the scheme owner and the monitoring party being separate legal entities. Every label on the market as of September 27, 2026 must comply; non-compliant schemes must be adapted or their labels dropped from commercial communications. The Q&A is blunt: "The ECGT Directive does not provide for a transition period beyond this date." Point 4c bans claiming, on the basis of greenhouse gas offsetting, that a product has a neutral, reduced or positive emissions impact; the Q&A's example is an airline calling a specific flight climate neutral because it invests in tropical rainforest reforestation. Company-level offsetting claims fall outside 4c but remain subject to the rest of the UCPD.

A wide reach: non-EU traders, brand names, future targets and old stock

The Q&A says the UCPD applies whether traders or products come from inside the Union or from third countries, and that labels set up by public authorities of non-EU countries are prohibited under point 2a unless they are based on a certification scheme. Skift makes the same point: "companies based outside of the economic bloc are still covered." It adds that the rules cover comparison tools and hotel eco-labels; under the Q&A, a trader offering a service that compares products on environmental or social characteristics must disclose the compared products and their suppliers, the comparison method and how the data is kept current. Skift says travel sustainability chiefs welcomed the law and expect fewer hotel eco-labels. Its key points say the Commission points to Nordic Swan, Blue Angel and the Austrian and Dutch ecolabels as compliant; in the Q&A the four appear as examples of recognised type I ecolabels that can back a generic claim. Skift adds that Green Key now relies on audit-based accreditation.

Words such as ‘green’, ‘eco’ or ‘natural’ in a brand or product name may count as an environmental claim if the average consumer is likely to link them to the environment, judged case by case. Colours or images alone, without written or spoken text, cannot be generic environmental claims, though with such text they can be; imagery may still be judged case by case as an implicit claim, and features like green leaves or water drops can count as a sustainability label depending on context and consumer perception. Future-performance claims, such as a move to climate neutrality, need a detailed, realistic plan with verifiable commitments that an independent third-party expert checks regularly. Only business-to-consumer practices are covered. From September 27, old stock must comply too; the Q&A mentions covering or correcting claims with stickers, or extra information where the products are sold. Enforcement lies with national authorities and courts, and some national laws let individuals and companies bring proceedings. Enforcers may weigh how serious a breach is, whether the trader made reasonable, proportionate efforts to comply, including for goods already in the distribution chain, and whether compliance would bring disproportionate costs or needless environmental harm.

The sources do not name Türkiye, so this section is UNALSOFT commentary

Neither the Commission page, nor the Q&A, nor the accessible part of Skift's article names Türkiye, Turkish companies or Turkish labels, so the Türkiye conclusions below are explicitly UNALSOFT commentary. Our reading: because the rules apply to traders from third countries, Türkiye-based e-exporters reaching EU consumers through product pages, marketplace listings, packaging or ads, and hotels marketing to EU guests, can be assessed under the same rules. And since the Q&A bars labels set up by non-EU public authorities unless they are certification-based, we read this as covering labels from Turkish public bodies in communication aimed at EU consumers.

The unknowns, one by one. The sources offer no data or example about companies selling from Türkiye, no word on which Turkish labels rest on a certification scheme and, in the parts we could read, no penalty or fine amounts. They do not list which Member States have completed transposition (the Q&A calls it still ongoing), do not address marketplaces as such beyond the comparison-service duty above, and do not summarise the Consumer Protection Cooperation (CPC) Network's Common Understanding on old stock, which the Commission page only links to. We covered the same Directive's legal guarantee notice and GARAN label on September 21.

Sources

European Commission, Sustainable consumption (DG Justice and Consumers) · European Commission, Questions and Answers on the Directive on empowering consumers for the Green Transition (PDF) · Skift, EU anti-greenwashing rules take effect