Quick answer
Since 27 September 2026, EU countries must apply Directive (EU) 2024/825, known as EmpCo. It bans three common listing claims in all circumstances: generic environmental claims such as “eco-friendly” or “green” without recognised excellent environmental performance, sustainability labels that aren’t based on a certification scheme or set up by public authorities, and “carbon neutral” claims based on offsetting. The rules work through each country’s national law, and some countries, Spain among them, are still late. They cover stock already on the market and apply to sellers based outside the EU. Great Britain has its own framework: the DMCC Act 2024 and the CMA’s Green Claims Code.
If you sell on Amazon’s EU stores, your titles, bullet points, images, A+ Content and packaging are all commercial communications to consumers, and the new rules apply to every one of them. Words like “eco”, “sustainable” or “planet-friendly” are common in listings, often with nothing to back them up. These are the banned practices, what you can still say, where each EU country with an Amazon store stands on transposition, and what applies in the UK.
Directive (EU) 2024/825 on empowering consumers for the green transition (EmpCo, also called ECGT) amends two existing EU consumer laws: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). The change that matters most for sellers is a set of new entries in the Unfair Commercial Practices Directive’s blacklist: practices that are unfair in all circumstances. An authority doesn’t have to show that the claim misled anyone in particular; making it is enough. This is not the separate Green Claims Directive proposal, which is stalled in the EU legislative process.
| Date | What happened |
|---|---|
| 6 March 2024 | Directive (EU) 2024/825 is published in the Official Journal of the EU |
| 26 March 2024 | The directive enters into force |
| 27 March 2026 | Deadline for EU countries to adopt and publish their national rules |
| 28 May 2026 | The European Commission sends letters of formal notice to 20 EU countries that hadn’t notified full transposition |
| 27 September 2026 | The national rules apply, together with the harmonised guarantee notice and label of Implementing Regulation (EU) 2025/1960 |
The rules cover business-to-consumer practices. According to the Commission, sales between businesses are outside their scope, although other EU rules on misleading advertising still apply to them.
These are the new blacklist entries that matter most for a seller, with typical examples from a listing:
| Banned practice | Example in a listing | What to do |
|---|---|---|
| A generic environmental claim when you can’t demonstrate recognised excellent environmental performance relevant to the claim | “Eco-friendly product”, “green bottle”, “biodegradable” | Specify the benefit on the same medium, or remove the claim |
| A sustainability label that isn’t based on a certification scheme or established by public authorities | A “100% eco” leaf badge designed by the brand itself | Keep only labels from a certification scheme or a public authority |
| An environmental claim about the whole product when it only concerns one aspect | “Recycled product” when only the packaging is recycled | Say exactly which part: “recycled cardboard packaging” |
| Claiming a neutral, reduced or positive greenhouse gas impact based on offsetting | “Climate-neutral product”, “CO2 neutral” | Remove it; report climate investments separately |
| Presenting legal requirements that apply to every product in the category as a distinctive feature | “Free from substances banned in the EU” | Remove it: every competitor has to comply too |
| Falsely claiming that a product lasts a certain time or number of uses, or presenting it as repairable when it isn’t | “Repairable” with no spare parts available | Only claim it if you can prove it |
Recital 9 of the directive lists examples of generic claims: “environmentally friendly”, “eco-friendly”, “green”, “nature’s friend”, “ecological”, “environmentally correct”, “climate friendly”, “gentle on the environment”, “carbon friendly”, “energy efficient”, “biodegradable” and “biobased”. The Commission’s Q&A (non-binding guidance from its services) adds that brand and product names count too: “eco” or “green” in a product name can be an environmental claim when it is likely to suggest an environmental benefit.
Check your images as well. According to the Commission, a leaf, a tree or a green background on its own is not a generic environmental claim, but it can still be an implied environmental claim, judged case by case, and combined with text it can become a generic one. A leaf or a water drop next to statements about sustainability may be read as a sustainability label. Your main image, infographics and A+ modules all count.
The directive doesn’t stop you talking about the environment. It stops vague claims and claims you can’t back up. A claim is no longer generic when its specification appears in clear and prominent terms on the same medium, and for an online sale that includes the selling interface. The directive’s own example: “climate-friendly packaging” is generic, while “100% of energy used to produce this packaging comes from renewable sources” is specific. On Amazon, “Packaging made from 100% recycled cardboard” in the same bullet point is specific; “Eco” on its own in the title is not. A specific claim still has to be true, and you need the evidence for it.
To use a generic claim, you need recognised excellent environmental performance relevant to that claim. The directive allows three ways to show it:
The proof has to match the claim. “Energy efficient” can rest on the energy label, but “biodegradable” can’t rest on the EU Ecolabel if the Ecolabel criteria for that product don’t cover biodegradability. And “sustainable”, “conscious” or “responsible” can’t rest on environmental performance alone, because they also suggest social characteristics.
Sustainability labels are allowed if a public authority established them or they are based on a certification scheme: third-party verification, public requirements, open to any trader on fair terms and monitored by an independent third party. If you sell from the UK or the US, note one detail in the Commission’s Q&A: a label set up by a public authority outside the EU only counts if it is also based on a certification scheme. And if you sell organic food, the terms protected by the EU organic rules, such as “bio” and “eco”, can still be used to show compliance with those rules.
Yes. The Commission’s Q&A says that from 27 September 2026 claims and labels must comply for existing products too, including packaging already made, ordered or in distribution, and the directive gives no transition period. For products already packed, it mentions practical fixes such as stickers that cover or correct the claim. Enforcement is national: authorities and courts can take into account whether you made reasonable and proportionate efforts to comply, including for products already in the distribution chain.
EmpCo is a directive, so it reaches you through national law. Each EU country had to adopt and publish its rules by 27 March 2026 and apply them from 27 September 2026. On 28 May 2026 the Commission opened infringement procedures against 20 countries that hadn’t notified full transposition, including Spain, France, the Netherlands, Belgium, Poland and Sweden. Germany, Italy and Ireland were not on that list. This is where the EU countries with an Amazon store stand:
| Country | Letter of formal notice on 28 May 2026 | National rules (official gazettes and EUR-Lex) |
|---|---|---|
| Germany | No | Third Act amending the Act against Unfair Competition (UWG), Federal Law Gazette 2026 I No 43, in force since 27 September 2026 |
| Italy | No | Legislative Decree No 30 of 20 February 2026, applying from 27 September 2026 |
| Ireland | No | S.I. No 124 of 2026, in operation since 27 September 2026 |
| Netherlands | Yes | Act of 27 May 2026 amending Book 6 of the Civil Code, published on 24 June 2026 |
| Belgium | Yes | Transposition act published in the Belgian Official Gazette on 4 August 2026 |
| France | Yes | Three existing provisions of the Environmental and Consumer Codes notified |
| Spain | Yes | None notified to the Commission yet; the draft Sustainable Consumption Act is pending |
| Poland | Yes | None notified to the Commission yet |
| Sweden | Yes | None notified to the Commission yet |
EUR-Lex shows what each country has notified, and the Commission still checks whether transposition is complete and correct. If you sell in a country, check its national text with a lawyer there.
Spain is an example of a country that is late. Its planned vehicle is the Sustainable Consumption Act: the Council of Ministers approved the draft at first reading on 1 July 2025, and the competition authority (CNMC) published its report on it on 11 March 2026. EUR-Lex lists no Spanish measure, and the consolidated Unfair Competition Act in the Official State Gazette (BOE) shows no amendment since December 2025.
In countries that are late, the existing rules on misleading practices already apply to greenwashing, according to the Commission’s Q&A. You probably reuse the same images and A+ designs across Amazon’s EU stores, and the new blacklist already applies through national law in Germany, Italy and Ireland. The simplest approach is to clean up your catalogue once, to the directive’s standard, for every EU store. If you are adding offers on Amazon.nl and Amazon.com.be for Pan-EU FBA, include those listings: see our article on Pan-EU FBA requirements for the Netherlands and Belgium.
EmpCo is EU law and doesn’t apply in Great Britain; if you sell to Northern Ireland, check with your adviser which rules apply there. In Great Britain, green claims fall under the Digital Markets, Competition and Consumers Act 2024 (DMCC Act), whose rules on unfair commercial practices replaced the Consumer Protection from Unfair Trading Regulations 2008 for practices from 6 April 2025. The DMCC Act extends to the whole UK, Northern Ireland included.
The CMA’s Green Claims Code sets six principles: claims must be truthful and accurate, clear and unambiguous, must not omit or hide important information, comparisons must be fair and meaningful, claims must consider the full life cycle, and they must be substantiated. The code warns that broad terms such as “green”, “sustainable” or “eco-friendly”, especially without explanation, are much more likely to mislead. In January 2026 the CMA added guidance on responsibility across the supply chain: a retailer that repeats a brand’s misleading claim can be liable too. Under the DMCC Act, the CMA can decide itself whether consumer law has been broken and fine businesses without going to court: up to 10% of global turnover or £300,000, whichever is greater.
The main difference from the EU: Great Britain has no rule banning generic claims or offset-based claims in all circumstances. Claims are judged case by case against the rules on misleading actions and omissions. The DMCC Act’s list of practices that are always unfair does include displaying a trust mark, quality mark or equivalent without the necessary authorisation. If you sell the same products on Amazon.co.uk and in the EU, one set of specific, provable claims is easier to manage for both markets.
On the same date, Commission Implementing Regulation (EU) 2025/1960 started to apply. It sets two formats that traders must use under the Consumer Rights Directive:
| Format | What it tells the consumer | When it is required |
|---|---|---|
| Harmonised notice | That the legal guarantee of conformity exists, with its minimum of two years in the EU | Always, when selling goods to consumers |
| Harmonised label | That the producer offers a commercial guarantee of durability, and for how long | When the producer offers, at no extra cost, a guarantee covering the whole product for more than two years and makes that information available to you |
For online sales both must be shown in colour, and the label can use a nested display that opens in full on the first click, mouse-over or tap. The Commission’s Q&A gives examples: the notice as a general reminder on the seller’s website, the label next to the picture of the product. On Amazon, check what the marketplace displays and what you have to provide as the seller; on your own website, it’s all on you.
On 27 September 2026, the date from which EU countries must apply their national rules transposing Directive (EU) 2024/825. They cover commercial communications to consumers, including Amazon titles, bullet points, images and A+ Content.
Only if you can demonstrate recognised excellent environmental performance relevant to the claim, such as the EU Ecolabel or an officially recognised EN ISO 14024 type I ecolabel. Otherwise, replace it with a specific claim stated clearly on the same medium, for example “packaging made from 100% recycled cardboard”, and keep the evidence.
No. Claiming that a product has a neutral, reduced or positive greenhouse gas impact based on offsetting is banned in all circumstances. Such claims are only possible when they are based on the product’s actual life cycle impact. You can still report your investments in climate projects separately, as long as that information isn’t misleading.
Yes, for sales to consumers in the EU. According to the Commission’s Q&A, the rules apply to commercial practices aimed at consumers in the single market, wherever the trader or the product comes from. For customers in Great Britain, the DMCC Act 2024 and the CMA’s Green Claims Code apply instead.
Not yet. EUR-Lex lists no Spanish measure, and the planned vehicle, the Sustainable Consumption Act, was approved as a draft at first reading on 1 July 2025. Spain was one of the 20 countries that received a letter of formal notice on 28 May 2026.
Yes. The Commission’s Q&A says claims and labels must comply from 27 September 2026 for existing stock too, with no transition period. For products already packed, it mentions stickers that cover or correct the claim as a practical option.
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Discover ax Design →Sources: Directive (EU) 2024/825 on empowering consumers for the green transition (EUR-Lex), Articles 1, 2 and 4, Annex and recitals 7 to 12; European Commission, Questions & Answers on Directive (EU) 2024/825 (September 2026); European Commission, infringement decisions of 28 May 2026 (INF/26/1097); EUR-Lex, national transposition measures for Directive (EU) 2024/825; Germany, Drittes Gesetz zur Änderung des Gesetzes gegen den unlauteren Wettbewerb, BGBl. 2026 I Nr. 43 (19 February 2026); Italy, Decreto legislativo 20 febbraio 2026, n. 30 (Normattiva); Ireland, S.I. No. 124/2026 (Irish Statute Book); Spain’s Ministry of Social Rights, Consumer Affairs and 2030 Agenda, draft Sustainable Consumption Act (1 July 2025); CNMC, report IPN/CNMC/053/25 (11 March 2026); BOE, Ley 3/1991 de Competencia Desleal, consolidated text; Commission Implementing Regulation (EU) 2025/1960 (EUR-Lex); Digital Markets, Competition and Consumers Act 2024 (legislation.gov.uk), sections 225 to 227 and 338 and Schedule 20; CMA, Unfair commercial practices (CMA207); CMA, Green claims code: making environmental claims (20 September 2021); CMA, Making green claims: getting it right, across the supply chain (22 January 2026); CMA, How the CMA uses its direct consumer enforcement powers; European Parliament, Legislative Observatory, Green Claims Directive 2023/0085(COD). Checked on 7 October 2026. This article is for information only and is not legal advice.