The EU ban on generic environmental claims

Directive (EU) 2024/825, applicable from 27 September 2026 (Art. 4). Read from the Publications Office Cellar text on 26 September 2026 (EUR-Lex itself returned an empty request-challenge page that day); every reference below is given. Germany's transposition: BGBl. 2026 I Nr. 43. This is not legal advice.

From 27 September 2026, Directive (EU) 2024/825 amends Annex I of the Unfair Commercial Practices Directive (2005/29/EC): several ways of making an environmental claim about a product become, on their own, a misleading commercial practice. Three of the added points reach ordinary product texts directly — the kind of wording a shop writes on a product page, not only advertising.

What makes a claim "generic"

Annex I, point 4a of Directive 2005/29/EC, as amended, bans a generic environmental claim where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. Recital 9 explains what "generic" means and gives this list of examples:

Point 4b — the whole product, only one aspect is green

An environmental claim about the entire product or the whole business, when in truth it concerns only one aspect of the product, one process, or a part of the business.

Annex I, point 4b of Directive 2005/29/EC, as amended by Directive (EU) 2024/825.

Point 4c — neutrality claims based on offsetting

Claiming, on the basis of offsetting greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment because of those emissions. Wording this reaches includes "climate neutral", "carbon neutral", "CO2 neutral", "net zero" and "climate positive" — however the underlying reduction was actually achieved.

Annex I, point 4c of Directive 2005/29/EC, as amended by Directive (EU) 2024/825.

When a claim stops being "generic"

Recital 9 also states the exemption: a claim whose specification is given "in clear and prominent terms on the same medium" — for example the online selling interface itself — is not a generic claim. The recital's own example: "climate-friendly packaging" is generic on its own; "100 % of the energy used to produce this packaging comes from renewable sources" is specific, and is not caught by point 4a.

The difference is not the topic, but whether the page states a specific, checkable fact next to the claim — not on a separate page, not in a linked certificate, but in clear and prominent terms on that same medium.

Practical steps for a shop

  1. Search your product titles and descriptions — and your homepage, About page and email templates — for the recital 9 words above and for neutrality wording ("climate neutral", "carbon neutral", "net zero", "CO2 neutral").
  2. For every match, ask: does this same page also state a specific, verifiable fact backing it up, in clear and prominent terms? If yes, the claim is not generic under recital 9. If no, either add that fact or remove the claim.
  3. If a "neutral" or "net zero" claim rests on buying carbon offsets rather than actually cutting the product's own emissions, remove it: point 4c bans it regardless of how the wording is phrased.
  4. Bare "green" used as a colour word (a green T-shirt) is not what the recital targets; it is a claim about environmental performance that is generic.

Sources

Directive (EU) 2024/825 amending Directives 2005/29/EC and 2011/83/EU — on EUR-Lex, CELEX:32024L0825, Annex I points 4a, 4b and 4c, recital 9. Germany's transposition: BGBl. 2026 I Nr. 43.

This page reproduces and explains provisions of Directive (EU) 2024/825 and names Germany's transposition. It is not legal advice, and it does not decide whether a specific claim on a specific page breaks the law — that depends on the exact wording used and cannot be judged from a list of words alone.