The EU's Green Claims Crackdown:
What UK Businesses Need to Do Before September 2026
If your business sells into Europe, there is a deadline you need to put in your diary right now: 27 September 2026.
That is when the EU’s Empowering Consumers for the Green Transition Directive comes into effect for all 27 Member States. You don’t need to be based in the EU to be impacted. If you participate in any commercial practices affecting EU consumers the new regulations apply to you.
Are your websites, sales materials, product labels ready?
We frequently see businesses misunderstand what different sustainability phrases and language mean. It is an area of business that is an alphabet soup of acronyms and definitions (check out our sustainability and ESG glossary for help). But misunderstanding terms can now result in hefty consequences.
What are the consequences of getting it wrong?
There is no one EU-wide penalty. But rather each EU member state must create a penalty that is “effective, proportionate and dissuasive.”
However, because the rules sit inside the EU’s broader unfair commercial practices regime, the benchmark penalty for major cross-border infringements is:
- At least 4% of annual turnover in the relevant member state(s), or
- €2 million if turnover data is unavailable.
Alongside this there will likely be significant reputational damage to your brand’s trust. It is also likely that consumer compensation and competitor lawsuits will follow.
Remember the International Women’s Day chatbot that responded to corporate social media posts using the #IWD and revealed their gender pay gap?
We predict seeing tech and AI solutions doing just this. We have already seen business solutions like Eko Intelligence and Green Watch materialise.
How do I know if the EU Directive applies to me?
If you answer yes to any of these questions it applies to you:
- Do you have any EU-based customers?
- Do you advertise or market in the EU?
- Do you run any sales campaigns or sales activities in an EU country?
Why now?
The EU has been working for several years to clean up the world of environmental marketing. The problem it is trying to solve is real: the Commission found that 53% of green claims currently in circulation are vague, misleading, or unfounded, and 40% have no supporting evidence whatsoever. Half of all green labels carry weak or non-existent verification.
The market is flooded with sustainability language that consumers simply cannot trust. The most common that we see is companies interchanging carbon neutral and net zero, when they mean completely different things. What is clear to us is that greenwashing isn’t always intentional!
The Empowering Consumers for the Green Transition Directive is the EU’s response. It creates a legally binding framework that requires businesses to substantiate environmental claims before they make them.
What is green washing?
Greenwashing is when a business makes environmental claims that are exaggerated, vague, or simply untrue, presenting a greener image than the facts support.
A note on timing: You may have seen references to the Green Claims Directive in the news. That is a separate, more ambitious piece of legislation that has faced political uncertainty, including an attempted withdrawal. It is not the same as the September 2026 rule discussed in this blog.
What do you need to do?
The Empowering Consumers for the Green Transition Directive does not ban businesses from making environmental claims. What it does is raise the bar for what counts as an acceptable claim.
Under the new framework, vague or generic language will no longer be sufficient. Claims must be:
- Specific: tied to a defined attribute, product, or process, not a general brand impression.
- Accurate: factually correct.
- Evidence-based: supported by recognised scientific evidence, verifiable data and accurate lifecycle information where appropriate.
- Clearly worded: understandable to the consumer without specialist knowledge. Goodbye jargon (we love this as it makes content so much more accessible)
This has direct implications for the language businesses use across their entire customer-facing operation: website copy, product packaging, sales decks, email campaigns, tender responses, and annual reports.
Vague terms like “eco-friendly”, “green”, “environmentally friendly”, are on their way out. Everything you say must be evidenced and these terms are not specific enough.
Using the term “carbon neutral” is going to be highly contentious on any consumer facing material. The Empowering Consumers for the Green Transition Directive explicitly prohibits claiming a product has a neutral, reduced, or positive impact on the environment in terms of greenhouse gas emissions when that claim is based on carbon offsetting outside the product’s value chain.
What is carbon neutral?
Carbon neutral means that the total amount of carbon dioxide a business, product, or activity releases is balanced out, by reducing emissions at source and/or by funding equivalent carbon removal or offsetting elsewhere. Carbon neutrality always includes a level of offsetting and doesn’t always include carbon reduction.
What is net zero?
Net zero means a business or product has reduced its greenhouse gas emissions as far as possible, with any remaining emissions removed from the atmosphere, not just offset elsewhere. The emphasis is on cutting emissions. The Science-Based Target Initiative expect at least a 90% reduction in carbon emissions to achieve net zero.
Here is the grey area!
It is important to remember the Empowering Consumers for the Green Transition Directive is based on consumer facing material. It is specifically focused on B2C materials. However, there is evidence that EU case law supports the directive being used to define misleading B2B marketing. Sustainability information is routinely used in product catalogues, online databases and distribution platforms; these platforms influence consumer behaviours and could be considered in scope.
The directive is not aimed at corporate level reporting such as ESG Impact Reports and Annual Reports and Accounts. However, it is hard to evidence that these documents do not influence consumer perceptions.
But the water is muddy. Most businesses have some form of consumer facing material. For example, in a recruitment, legal, or accountancy practice you likely have individual as well as business customers.
Employer brand is also not clearly covered by the regulation however if consumers access the same material (like the same URL) when making purchasing decisions this could be an issue. But even without the legal trigger, the directive is going to lead to improved understanding and climate literacy. The reputational damage of misleading future employees alongside high turnover levels will be impactful.
Our advice is to err on the side of caution. And ensure you follow the rules of specific, accurate, evidence-based and clear wording in all communications.
A Practical Example
What you say today vs what you should say when the EU’s Empowering Consumers for the Green Transition Directive is in place:
Today: “our eco-friendly packaging”
Sept 2026: “packaging made from 60% recycled materials”
Today: “powered by renewable energy”
Sept 2026: “50% of the energy used to deliver this service was renewable”
Today: “We will be net zero by 2030”
Sept 2026: “We will be net zero by 2030, and here is our detailed plan to deliver this”
What do you need to do before September 2026?
The good news is there is still time to act.
If sustainability is a large part of your brand but you don’t have the evidence, you must act now. Doing a full audit, data collection, lifecycle assessment, product declarations (if applicable) takes time. Some certification schemes have a 3+ month waiting list.
No matter where sustainability shows up in your brand a sensible starting point is a structured review of all environmental claims currently in use, mapped against the evidence available to support each one. From there, businesses need to decide which claims to retain (with stronger documentation), which to reword, and which to retire altogether.
That process is not especially complicated, but it does require someone to own it, and the expertise to do it properly. For businesses without an in-house ESG or legal team, the risk is that it simply does not happen in time.
Frequently Asked Questions About the Empowering Consumers for the Green Transition Directive
What is the Empowering Consumers for the Green Transition Directive?
The Empowering Consumers for the Green Transition Directive (ECGT) is a new EU law designed to tackle greenwashing and misleading environmental marketing. It introduces stricter rules around how businesses communicate sustainability claims to consumers.
When does the EU Green Claims legislation come into force?
EU Member States must introduce the legislation into national law by 27 March 2026. The rules become applicable from 27 September 2026.
Does the directive apply to UK businesses?
Yes. You do not need to be based in the EU to be affected. If your business markets, sells, distributes, or promotes products or services to EU consumers, the rules may apply to your marketing and communications.
What types of environmental claims are affected?
The directive targets broad or unsubstantiated environmental claims such as:
- “Eco-friendly”
- “Green”
- “Sustainable”
- “Environmentally friendly”
- “Climate neutral”
Claims must be specific, accurate, evidence-based and understandable to consumers.
Are carbon neutral claims banned?
Not entirely, but they are becoming significantly more restricted. The directive prohibits claims that a product has a neutral, reduced, or positive environmental impact based solely on carbon offsetting outside the product’s value chain.
Does the directive only apply to product packaging?
No. The rules may affect any consumer-facing communication, including:
- Websites
- Social media
- Product labels
- Sales materials
- Advertising campaigns
- Tender responses
- Email marketing
What evidence do businesses need to support sustainability claims?
Businesses should be able to demonstrate environmental claims using recognised scientific evidence, verifiable data, and where appropriate, lifecycle information or certification schemes.
Does the directive apply to B2B marketing?
The directive is primarily focused on consumer protection and B2C communications. However, sustainability claims used in B2B materials may still create legal or reputational risk, particularly where those claims influence consumer purchasing decisions indirectly.
What should businesses do before September 2026?
Most businesses should begin with:
- A review of all environmental claims currently in use
- Identification of supporting evidence
- Removal or rewording of vague claims
- Improved documentation and governance processes
- Alignment between sustainability, marketing, and legal teams
Is the Empowering Consumers for the Green Transition Directive the same as the Green Claims Directive?
No. They are separate pieces of legislation. The Empowering Consumers for the Green Transition Directive has been formally adopted and applies from September 2026. The proposed Green Claims Directive is a separate and more detailed proposal focused on substantiating environmental claims.
How ENVOLV can help?
ENVOLV works with businesses that are serious about sustainability but do not have the in-house resource to navigate every piece of incoming regulation on their own. We bring the expertise to translate complex requirements like this directive into practical, proportionate action, without committing to headcount costs.
We are supporting businesses from simply audits and improvement plans to fully partnering with Marketing teams.
If you want to understand what the Empowering Consumers for the Green Transition Directive means for your specific marketing and reporting, we can help you get there before the deadline arrives.
*ENVOLV provides sustainability intelligence and ESG support for UK businesses. This article is for informational purposes and does not constitute legal advice. Businesses should seek appropriate professional guidance specific to their business.*
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