If your company uses “eco-friendly”, “sustainable”, “green”, or “carbon neutral” in marketing materials, product labels, or its website, EU Directive 2024/825 changes the rules from September 2026. Spain missed its transposition deadline on March 27, 2026, but companies should not wait: the prohibitions will enter into force across the EU in September regardless.
This article breaks down what the directive requires, who is affected, and the practical steps your sustainability and marketing teams need to take in the next six months.
What Directive 2024/825 prohibits
The EU adopted Directive 2024/825/EU on 28 February 2024. Published in the EU Official Journal on 6 March 2024, it amends two cornerstones of EU consumer law: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU).
The new rules introduce specific prohibitions on misleading environmental claims:
Generic environmental claims. Terms like “eco-friendly”, “green”, “natural”, “biodegradable”, “environmentally friendly”, “climate friendly”, or “sustainable” are banned unless substantiated with specific, recognised scientific evidence. A general claim about the company as a whole does not justify an unsupported claim about a specific product or service.
Carbon neutrality based on offsets. Claiming that a product is “carbon neutral” or “climate neutral” solely on the basis of purchased carbon credits or offset schemes is prohibited. These claims must reflect real emissions reductions in the company’s value chain, not compensations.
Unverified sustainability labels. Third-party sustainability labels and certifications used in marketing must come from certification schemes officially approved under EU or national authority processes. Self-created green badges or unverified third-party logos are not acceptable.
Vague future commitments. Statements like “working toward net zero by 2035” are only permissible if backed by a documented, credible, independently verified transition plan that includes specific interim milestones. Aspirational language without a roadmap no longer qualifies.
Penalties for violations: a minimum fine of 4% of annual turnover in the member state where the infringement occurred, plus the possibility of public enforcement actions that add reputational damage on top of the financial penalty.
Which companies are affected
The directive applies to all businesses that make environmental claims toward consumers operating within the EU, regardless of company size or sector. The scope covers advertising, product labeling, digital content, sustainability reports shared publicly, and social media communications.
This is not limited to regulated industries or large multinationals. Any company, including SMEs, that uses environmental language in its external communications must comply.
For companies that have already invested in ESG data collection and reporting, this is a direct connection between internal data and external communication. A carbon footprint calculation stored in an internal system is not sufficient: it must serve as documented, auditable evidence behind every green claim made in public.
The companies most exposed to enforcement risk are those that adopted sustainability messaging as brand positioning without building the underlying data infrastructure to support it. The directive draws a clear line between substantiated claims and greenwashing.
At Dcycle, we work with companies across food, logistics, manufacturing, and professional services to make their ESG data audit-ready. The shift from internal compliance to external substantiation is exactly the challenge this directive places on every marketing and sustainability team.
The September 2026 deadline: what changes in practice
Spain’s transposition deadline passed on March 27, 2026. While the national legislation has not yet been formally enacted, the directive will apply from September 27, 2026, once the 18-month implementation period from publication concludes.
From that date, consumer protection authorities in each EU member state can act against companies using unsupported green claims. In Spain, enforcement falls primarily to the CNMC and regional consumer agencies. In Germany, the Bundeskartellamt and the Wettbewerbszentrale have enforcement powers. In Portugal, the Direção-Geral do Consumidor and the ASAE handle these cases.
The six months ahead are not a grace period. They are the preparation window. Companies that use this time proactively will avoid enforcement risk and gain a competitive advantage with customers and investors who increasingly scrutinise environmental claims.
Practically, this means:
- Product packaging with “eco” or “green” wording needs documentation or redesign before September
- Website pages that describe the company as “sustainable” without substantiation need revision
- Marketing campaigns referencing carbon neutrality must disclose the calculation methodology
- Third-party labels need to be checked against approved certification registries
How to prepare in the next six months: a practical checklist
Preparing for Directive 2024/825 requires coordination between sustainability, marketing, legal, and communications teams. Here is a starting framework:
Step 1: Audit all green claims. Collect every environmental claim used in external communications: packaging, website, social media, sales collateral, press releases, and the sustainability section of your annual report.
Step 2: Map each claim to its evidence. For every claim, identify whether there is documented, up-to-date, scientific evidence behind it. Claims without substantiation must be removed, modified to add specific scope, or replaced with qualified language.
Step 3: Review your sustainability labels. Verify that any third-party certification or eco-label you display appears on the European Commission’s official registry of approved certification schemes. Labels not listed there must be removed.
Step 4: Align external claims with your ESG data. Your public communications must be consistent with the figures in your official reports. If your emissions data and ESG metrics are structured and traceable in a platform like Dcycle, discrepancies between what you report and what you claim publicly become easy to identify and fix.
Step 5: Document forward-looking commitments. Any claim about future sustainability goals must be backed by a verified transition plan. Vague aspirations without timelines and independently verified interim targets are no longer permissible.
Step 6: Train your marketing team. Create a pre-publication review process for any external content that includes environmental claims. Legal and sustainability sign-off should be standard practice before any green claim goes live.
Companies that have already built structured ESG data infrastructure are in a much stronger position. If you track Scope 1, 2, and 3 emissions, measure product-level carbon footprints, and produce CSRD-aligned reports through a structured platform, the documentation needed to substantiate most claims is already within reach.
Turning compliance into a competitive advantage
The companies that will be most affected by Directive 2024/825 are not those with robust ESG data. They are the ones that adopted sustainability language as a marketing narrative without building the data foundation to support it.
For companies that have invested in real ESG measurement, compliance with this directive is not a burden. It is a validation of that investment and a competitive differentiator. A company that can say “our product reduced its carbon footprint by 23% versus 2022, measured according to GHG Protocol methodology and verified by an independent auditor” is not just compliant. It is credible in a market where trust in environmental claims is at a historic low.
Dcycle’s platform is built for exactly this transition: centralising ESG data, ensuring full traceability from data source to published figure, and generating the documentation that makes environmental claims legally defensible under EU law. Whether it is a product-level carbon footprint, a Scope 3 supplier assessment, or a CSRD-aligned ESRS disclosure, the data in Dcycle is the evidence base your marketing team needs.
If your company is starting this process now, request a demo to see how Dcycle can help you build the data foundation that makes your sustainability communications both credible and compliant.
For broader context on how the EU sustainability reporting landscape is evolving, explore our CSRD resource hub and the complete guide to greenwashing regulations that have shaped today’s compliance requirements.