The EU Just Put a Date on Generic Green Claims. It's 27 September 2026.

There is now a date in the calendar that most businesses making environmental claims have not put there themselves. It is 27 September 2026. From that day, across all 27 EU member states, a set of green claims that are currently legal become illegal. Not discouraged. Not risky. Banned, with no defence available for some of them.

The law is Directive (EU) 2024/825, usually shortened to the ECGT Directive, short for Empowering Consumers for the Green Transition. It entered into force back in March 2024, which is why it has barely registered. The deadline for EU member states to write it into their own national law passed on 27 March 2026. The rules themselves start to bite on 27 September 2026.

If you sell to consumers in the EU, this applies to you. It does not matter that you are based in the UK. It does not matter that you are small. The rules attach to the act of selling to an EU consumer, not to where your office is. That is the part most UK businesses have missed, and it is the part that matters most.

Most of the coverage so far has come from law firms and large consultancies, written for compliance teams at companies that already have a carbon footprint and a head of sustainability. That leaves out almost everyone we work with. So this is the plain version. What changes, who it applies to, and what you can usefully do in the three months you have left.

What the ECGT Directive Actually Bans

The ECGT works by adding new entries to an existing EU blacklist of unfair commercial practices. That blacklist sits inside the Unfair Commercial Practices Directive, and the point of a blacklist is that the listed practices are banned outright. There is no "but we meant well" exemption. If a practice is on the list, doing it is an infringement.

Three of the new bans matter to almost every business making an environmental claim.

Generic environmental claims without proof

The first is the one that catches the most people. From 27 September 2026, you cannot make a generic environmental claim unless you can demonstrate recognised, excellent environmental performance relevant to the claim.

"Generic" is doing a lot of work in that sentence, so be clear about what it means. It means a broad environmental claim with no specifics attached and no evidence presented alongside it. The words that get flagged most often are the ones that have become wallpaper: eco-friendly, green, environmentally friendly, sustainable, climate friendly, gentle on the planet, conscious. On their own, with nothing behind them, these become prohibited.

The test the regulation sets is "recognised, excellent environmental performance." In practice that means certification under a scheme like the EU Ecolabel or an equivalent ISO Type I scheme. If you cannot point to that, you cannot use the generic word. You can still describe what your product actually does, in specific terms, with evidence. You just cannot wave at the general idea of being good for the planet and leave it there.

Offset-based carbon neutral claims on products

The second ban is sharper and, for some businesses, more expensive. You can no longer claim that a product is "carbon neutral," "climate neutral," "CO2 neutral," "climate positive" or has a "reduced" or "neutral" environmental impact when that claim rests on carbon offsetting.

This is point 4c of the blacklist, and it is worth understanding precisely because the line it draws is not where most people assume it is. The ban is on offset-based product claims. If you have bought carbon credits and used them to declare a product climate neutral, that specific construction is gone. What survives is a claim built on actual measured emissions reductions in your own operations and value chain. Real reductions, reported honestly, are fine. Reductions you have purchased from somewhere else and applied to a product are not.

For a lot of businesses, "carbon neutral" was the headline. It was the thing on the label, the website, the packaging. If that headline was paid for with offsets, it has roughly three months left.

Sustainability labels you made up yourself

The third ban is the quietest and the easiest to overlook. You cannot display a sustainability label unless it is based on a proper certification scheme or was established by a public authority.

That rules out the self-made badge. The little green roundel that says "Eco Approved" with your own logo in the middle, the in-house five-leaf rating, the self-certified seal that looks official but answers to no one but you. If you created the standard and you grade yourself against it, the label goes.

"But We're In The UK" Is Not The Defence You Think It Is

Here is where UK businesses tend to relax, and they shouldn't.

The UK is outside the EU. The ECGT is an EU directive. The instinct is to file it under "not our problem." That instinct is wrong, and the reason is simple. The directive governs commercial practices directed at EU consumers. If a consumer in Ireland, Germany or France can buy your product, see your claim, or land on your website and order from it, you are making a commercial practice towards an EU consumer. The rules follow the consumer, not the company.

This is the same logic that caught a lot of businesses out with GDPR. People assumed a European data law was a European company's problem, right up until they realised it applied to anyone holding data on European citizens. The ECGT works the same way. Sell into the EU and you are inside its scope, whatever your postcode.

So the question is not "are we an EU company." The question is "does anything we make end up in front of an EU consumer." For a surprising number of UK SMEs, the answer is yes, through their own website, through a marketplace listing, through a distributor, or through a single product line that happens to ship to Dublin.

And there is a second reason not to relax. The UK is not standing still on green claims either. The CMA has spent the past two years sharpening its own Green Claims Code, extending liability down the supply chain, and gaining real enforcement power under the Digital Markets, Competition and Consumers Act. The ASA has upheld complaints against businesses for exactly the kind of vague absolute claims the ECGT is banning. The direction of travel is the same on both sides of the Channel. The EU has simply put a date on it.

What The Penalties Look Like

It is tempting to ignore a rule until someone is fined under it, so it is worth being honest about the exposure.

Penalties are set by each member state, because each one writes the directive into its own law and decides its own enforcement. That means there is no single EU-wide fine to quote. What we can say is that for serious, cross-border infringements handled under the EU's coordinated consumer enforcement rules, fines can reach at least 4% of a trader's annual turnover in the member states concerned. Some national regimes go further, and enforcement can also involve being ordered to stop the claim, having to publish a correction, and the reputational cost that comes with both.

Treat the exact figure as secondary. The point is not the number. The point is that this moves environmental claims out of the "best practice" column and into the "compliance" column, where the cost of getting it wrong is no longer just an awkward conversation.

What You Can Still Say, and What You Can't

The fastest way to understand the change is to look at real claims either side of the line. The pattern is consistent once you see it. The banned version gestures at goodness. The allowed version states a fact you can prove.

"Our eco-friendly packaging" does not survive. "Our packaging is made from 80% recycled cardboard" does. Same packaging, same truth, but the second one says something a regulator can check and a customer can believe.

"This product is carbon neutral," resting on offsets, does not survive. "We've cut the emissions from making this product by 30% since 2023" does, if the number is real and you can show your working. One is a claim about a state you have purchased. The other is a claim about work you have done.

"Sustainable since 2010" does not survive as a standalone badge. "We've used renewable electricity across our two sites since 2019" does. Specificity is not a compliance chore here. It is simply the better sentence. It tells the reader more, and it happens to be the one that's allowed.

"Certified green by our own EcoStandard" does not survive, because you cannot certify yourself. "Certified to the EU Ecolabel" does, because someone independent stands behind it.

Notice what is happening across all four. Nothing true is being taken away from you. What's being removed is the ability to imply more than you can show. If your communication was already specific, this reads as a list of things you don't do. If it wasn't, it reads as a list of habits to break.

What to Actually Do Before 27 September

Three months is enough time to get this right if you start now and do not overcomplicate it. You do not need a consultancy and a twelve-week programme. You need to look honestly at what you currently say and fix what won't survive.

Here is the order I would do it in.

Start with an inventory of your claims. Walk through everywhere you make an environmental claim. Website, product pages, packaging, social media, email footers, sales decks, the line in your About page you wrote three years ago and forgot. Write them all down. You cannot fix what you haven't found, and almost everyone underestimates how many claims they have made.

Pull out the generic ones. For each claim, ask a blunt question: if a regulator asked me to prove this, could I, with evidence, today? "Sustainable" with nothing behind it fails. "Made with 60% recycled material, verified by our supplier" passes. Either replace the generic word with the specific fact underneath it, or remove it. The specific fact was always the better claim anyway. The vague word was hiding it.

Find every offset-based neutrality claim and deal with it. If you have a "carbon neutral" claim on a product that depends on offsets, that claim cannot continue past September in the EU. You have two honest options. Drop the neutrality claim and instead describe the real reductions you have actually made. Or, if offsetting genuinely is part of your approach, talk about it separately and accurately as offsetting, not as neutrality. What you cannot do is keep the headline and hope.

Audit your labels. Any badge, seal or rating you display needs to trace back to a real certification scheme or a public authority. If it traces back to you, it goes. This one is quick. It is usually obvious which labels are real and which you designed in-house.

Keep your evidence where you can reach it. For every claim that survives, you should be able to put your hand on the proof without a three-day search. The substantiation is the claim now. A claim you cannot evidence on request is a claim you cannot make.

None of this requires you to go quiet. Going quiet, what people have started calling greenhushing, carries its own risks and helps no one. The businesses that come out of this well are not the ones that delete everything in a panic. They are the ones that already said specific, true, evidenced things, and who now find they have very little to change.

FAQ

We're a small UK business. Are we really in scope? If EU consumers can buy from you, yes. The directive applies to commercial practices aimed at EU consumers regardless of where the trader is based. Being small does not exempt you, and being outside the EU does not either. The thing that determines scope is whether your claims reach an EU consumer.

Does this kill the word "sustainable" completely? No. It bans "sustainable" used as a bare, generic claim with no evidence. You can still talk about specific, substantiated environmental attributes in plain language. The issue is the empty word standing alone, not the underlying communication. If anything, the rule pushes you towards better claims, not silence.

We use carbon offsets. Is all of that banned? Offsetting itself is not banned. What is banned is using offsets to claim a product is carbon neutral, climate neutral or climate positive. You can still buy credits and you can still talk about it, as long as you describe it accurately as offsetting and do not convert it into a neutrality claim on the product.

What if the EU Green Claims Directive changes things again? You may have seen that a separate, broader law, the Green Claims Directive, has been stuck in negotiation and was nearly withdrawn. That is a different instrument. The ECGT is already law, already in force, and its 27 September 2026 date is not in doubt. Do not let the uncertainty around one directive create the impression that nothing is happening. The ECGT is happening.

We only sell in the UK. Can we ignore this? You can deprioritise the EU-specific deadline, but you cannot ignore the underlying direction. The UK's own regime under the CMA and ASA targets the same practices: vague claims, unsubstantiated absolutes, misleading neutrality language. A claim that breaches the ECGT will very likely also struggle under UK rules. Fixing it once tends to fix it for both.

How long does the cleanup actually take? For most SMEs, the claims inventory is a day or two of honest work, and the fixes are mostly editing rather than rebuilding. The businesses that struggle are the ones whose entire positioning rests on a single offset-based neutrality claim, because for them this is a strategic question, not a copy edit. The sooner you know which one you are, the better.

The Date is the Point

The most useful thing about 27 September 2026 is that it is a date. Green claims regulation has spent years feeling like a fog of guidance, codes and intentions, the kind of thing you know you should look at and never quite do. The ECGT turns the fog into a deadline. After that day, certain claims are simply not allowed.

Deadlines are clarifying. They turn "we should probably tighten our language at some point" into "we have until late September." If your claims are specific, true and evidenced, you will find there is very little to do, which tells you something about how you have been communicating. If you are looking at the list and feeling uneasy, that unease is information too. It is pointing at the claims that were never quite standing on solid ground.

My Green Comms helps SMEs cut through sustainability regulation and communicate with credibility. If you're unsure whether your current claims stand up to scrutiny, get in touch — we'll tell you what we think.

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This article is for informational purposes only and does not constitute legal advice. If you have concerns about your legal accountability for environmental claims, speak to a qualified solicitor.