On 27 September 2026, what your brand can say to its customers about the environment changes. Generic claims like “eco-friendly”, “sustainable”, “climate neutral”, without evidence behind them, stop being allowed in any B2C communication in the EU.
And one important detail for late member states: being behind on transposition does not push the date back.
Several member states are late, but the date does not move
Directive (EU) 2024/825, known as EmpCo or ECGT, was due to be transposed into national law by 27 March 2026. On 28 May 2026, the European Commission opened infringement proceedings against 20 member states for failing to communicate the full transposition. Spain is on that list, along with France, the Netherlands, Portugal, Belgium and Luxembourg, among others.
It is easy to misread the signal. The fact that a country has not transposed does not mean there is extra margin. The application date, 27 September 2026, is the same for all member states, whether they are ahead or behind with their national law. Spain already has the Sustainable Consumption Law bill in motion to adapt, so the regime arrives all the same.
What exactly is banned
The directive does not invent a new law from scratch. It modifies two existing ones, the Unfair Commercial Practices Directive and the Consumer Rights Directive. The goal is to cut greenwashing in consumer communication.
In practice, the following are off the table:
- Generic environmental claims without verifiable evidence (“sustainable”, “green”, “environmentally friendly”).
- Climate neutrality promises that rely only on offsets, with no real reduction plan behind them.
- Sustainability seals not backed by a recognised certification system.
What is required in exchange is simple to say and hard to improvise: every environmental claim must be specific, demonstrable and verifiable.
Who it affects
Every brand with B2C communication in the EU. It is not a “sustainability companies” issue. It is packaging, websites, product pages, campaigns, ads. If you say anything about the environment to a consumer, you are in scope.
Sanctions will depend on how each country transposes the directive, but the range includes fines and, depending on the state, possible exclusions from public procurement.
What to do before September
You have until the end of the summer, which in practice is not much. A realistic plan:
- Audit your claims. Make a list of every environmental statement you currently use: website, packaging, social, sales decks, presentations.
- Classify them. Which can you back with verifiable data right now? Which are generic or rest only on offsets?
- Decide. Every unsupported claim has two exits. Either you back it with data or you retire it before September.
The full directive text is here: Directive (EU) 2024/825.
Three examples to recalibrate
The directive’s text is technical, but the practical effect is straightforward. Three common cases that need work before September:
- “Carbon neutral” on packaging. If it relies only on offsets, with no internal reduction plan, it does not pass. The fix is either a clear methodology page, with sources and method, or pulling the claim and switching to something verifiable like “60% recycled materials” with proof.
- “100% sustainable” on a landing page. Too generic. Either you specify which dimension (energy, materials, supply chain) and back each with data, or you retire it.
- Self-declared seals or icons. A leaf and the word “green” without a recognised certification is exactly the type of claim the directive targets. Either you obtain certification, or the icon needs to go.
The reflex is to think this slows down marketing. In practice, it forces marketing and sustainability to share a source of truth, and that usually produces stronger claims, not weaker ones.
Evidence does not get improvised in August
This is the point that separates those who arrive calm from those who arrive running. A verifiable claim needs verifiable data behind it, and that data does not appear out of thin air the day before an audit.
If you can trace where each statement comes from, the real consumption, the footprint calculated with method, the material origin, defending a claim stops being scary. And the ones you cannot defend, you see them in time to pull them without rushing.
From data chaos to control: the difference between being able to say “this is verifiable” and having to say it and pray.
For B2C teams reviewing claims this summer, Dcycle’s carbon footprint platform and evidence and traceability layer give you the audit trail behind every environmental statement. Request a demo to see how it works, or browse our CSRD compliance hub for related disclosure context.