This Sunday, September 27, 2026, a claim that is acceptable on a package today may become unlawful in every EU market. That's the date the Empowering Consumers for the Green Transition Directive, Directive (EU) 2024/825, starts to apply across all 27 Member States, and there is no transition period.
For FMCG and CPG brands, this is not only a marketing question. Environmental claims live on packaging, and packaging lives across dozens or hundreds of SKUs, pack sizes, and language versions. Removing or substantiating a claim is a labeling change, and every labeling change is an opportunity for an error.
What the Directive Changes
The Directive amends two laws every EU seller already operates under: the Unfair Commercial Practices Directive and the Consumer Rights Directive. It was adopted in February 2024, Member States had until March 27, 2026 to write it into national law, and the national rules apply from September 27, 2026.
The changes most relevant to packaging:
Generic environmental claims are banned unless you can prove them. Terms like "eco-friendly," "green," "natural," or "environmentally friendly" can no longer be used on their own. A claim needs to be specific, and generic wording is only permitted where the product can demonstrate recognized excellent environmental performance.
Self-created sustainability labels are banned. A sustainability label or badge must be based on an independent certification scheme or established by a public authority. In-house eco-logos and badges designed by the brand itself no longer qualify.
Climate neutrality claims based on offsetting are banned. A product can no longer be labeled "climate neutral," "carbon neutral," or similar where that claim rests on offsetting emissions elsewhere rather than on the product's own impact.
Whole-product claims about partial improvements are banned. If only the packaging is recycled, a claim cannot imply the entire product is sustainable.
Future performance claims need a plan behind them. A statement such as "net zero by 2030" requires a detailed, realistic implementation plan with independent verification.
The European Commission has published a Q&A document to support consistent application across Member States. It is worth reading alongside your national transposition law, since enforcement runs through national authorities.
Why This Is a Labeling Problem
Most brands will treat the Directive as a claims review: marketing and legal go through the list of environmental statements, decide what stays, what goes, and what needs evidence. That review is necessary. It is also where the work usually stops, and where the risk begins.
The decision is made once. The change has to land everywhere the claim appears. A single "eco-friendly" line removed from a master artwork may still be sitting on the Italian variant, the multipack, the seasonal edition, or the private-label version produced for a retailer. A self-certified badge taken off the front panel may still appear on the back of a carton or a shipper case.
This is the same failure pattern that drives most FMCG labeling errors: a change applied correctly in one version and missed in another, because each version is reviewed on its own rather than compared against the approved master and against each other. We've written about how this plays out with allergen highlighting across language versions. Green claims removal follows exactly the same path.
What to Check Before Sunday, and After
Build an inventory of every environmental claim and label on pack. Front of pack, back of pack, secondary and shipper packaging, and every language and market variant. Include logos and badges, not just text.
Match each claim to evidence or a certification scheme. Claims without substantiation need to be made specific, backed by proof, or removed.
Treat every change as an artwork revision. Each removal or rewrite creates a new version that needs to be verified against the updated approved master.
Verify across all variants, not just the one you changed. Compare every SKU, pack size, and language version against the master, so a claim removed in one place isn't still printed in another.
Check where this overlaps with other packaging changes. Many brands are also revising packaging for PPWR, which applied from August 12, 2026, and for the BPA and PFAS restrictions phasing in through 2026. When several regulatory changes land on the same artwork in quick succession, the risk of one revision undoing another goes up. Our FMCG/CPG Packaging Compliance Checklist covers those requirements in one place.
A Note on the Green Claims Directive
The separate Green Claims Directive, which would have introduced harmonized EU-wide rules for substantiating environmental claims, did not move forward. That does not reduce your obligations. The Empowering Consumers Directive is the binding law, and it applies from September 27.
The rules on what you can claim are clear, and they apply from Sunday. The harder part is making sure the claims you've decided to remove are actually gone from every version of every pack.
Content Compare verifies every artwork revision against the approved master, across every SKU, language, and market version, so a claim removed from one label isn't still printed on another. See how it works on your own artwork.
