Words you can no longer use on EU product listings after September 2026
From 27 September 2026, the EU Empowering Consumers Directive (EmpCo) — Directive (EU) 2024/825 — makes certain environmental marketing claims unlawful when used without substantiation. This is not a guideline or a best practice recommendation. It is enforceable law, transposed into the national consumer protection rules of every EU Member State.
From 27 September 2026, the EU Empowering Consumers Directive (EmpCo) — Directive (EU) 2024/825 — makes certain environmental marketing claims unlawful when used without substantiation. This is not a guideline or a best practice recommendation. It is enforceable law, transposed into the national consumer protection rules of every EU Member State.
This guide lists the specific types of claims that are affected, provides examples of language that is now problematic, and offers compliant alternatives.
The rule in one sentence
A generic environmental claim is prohibited unless the trader can demonstrate recognised, excellent environmental performance that is relevant to the claim being made.
In practice, this makes it extremely difficult — effectively impossible — to use broad environmental terms as marketing language, because they imply overall environmental excellence that almost no product can comprehensively prove.
Claims that are now prohibited or restricted
Category 1: Generic environmental endorsements
These terms suggest a product is good for the environment in general. Unless you can prove that the product excels across all relevant environmental dimensions, these cannot be used.
| Prohibited language | Why it fails |
|---|---|
| "Eco-friendly" | Generic — implies overall environmental benefit without specifying what or how |
| "Environmentally friendly" | Same — unsubstantiated overall claim |
| "Green" (in environmental context) | Generic — no specific measurable attribute |
| "Sustainable" (standalone) | Generic — covers social, environmental, and economic dimensions without specifying which |
| "Good for the planet" | Generic — unsubstantiable overall claim |
| "Earth-friendly" | Generic |
| "Nature-friendly" | Generic |
| "Climate-friendly" (standalone) | Generic — does not specify which aspect of climate impact is addressed |
| "Conscious" (in sustainability context) | Generic — implies environmental awareness without measurable commitment |
| "Responsible" (in sustainability context) | Generic |
| "Clean" (in environmental context) | Generic |
| "Kind to the environment" | Generic |
| "Planet-positive" | Generic — implies net positive environmental impact, which is almost impossible to prove |
Category 2: Offset-based neutrality claims
These are explicitly banned when the claim relies on carbon credits or offsetting outside the product's value chain.
| Prohibited language | Why it fails |
|---|---|
| "Carbon neutral" | Banned if based on offsetting |
| "Climate neutral" | Banned if based on offsetting |
| "CO2 neutral" | Banned if based on offsetting |
| "CO2 compensated" | Banned if based on offsetting |
| "Carbon negative" | Banned if based on offsetting |
| "Climate positive" | Banned if based on offsetting |
| "Net zero emissions" | Banned if based on offsetting rather than actual value-chain reductions |
| "Carbon balanced" | Banned if based on offsetting |
| "Offset certified" | The offset itself is not the issue — using it to claim neutrality is |
Category 3: Unsubstantiated future commitments
These are not banned outright but require specific backing: a published implementation plan, measurable targets, and independent verification.
| Restricted language | What is required |
|---|---|
| "Carbon neutral by 2030" | Published plan + measurable targets + independent verification |
| "100% recyclable by 2028" | Published plan + measurable targets + independent verification |
| "Zero waste by [year]" | Published plan + measurable targets + independent verification |
| "We're on a journey to sustainability" | Must be backed by verifiable commitments, not aspirational language |
| "Working towards [environmental goal]" | Requires specificity and verification |
Category 4: Self-created sustainability labels
Any badge, logo, score, or visual mark that implies environmental certification must be based on a recognised scheme.
| Prohibited | Why it fails |
|---|---|
| Self-created "green" badges | Not based on a recognised certification scheme |
| Brand-specific sustainability scores (e.g. "EcoScore: 8/10") | Not independently certified |
| "Verified sustainable" without naming the verification body | No recognised scheme backing the claim |
| In-house sustainability tier labels (e.g. "Gold level sustainable") | Self-certification |
What you CAN still say
EmpCo does not ban environmental communication. It bans vague, misleading, and unsubstantiated claims. Specific, factual, and verifiable statements remain compliant.
| Compliant language | Why it works |
|---|---|
| "Made from 85% post-consumer recycled plastic" | Specific, measurable, verifiable |
| "GOTS-certified organic cotton" | Backed by a recognised certification scheme |
| "FSC-certified paper" | Backed by a recognised certification scheme |
| "EU Ecolabel certified" | Recognised EU scheme |
| "This product's carbon footprint is 2.1 kg CO2e per unit, verified by [body]" | Specific, measured, independently verified |
| "Packaging is recyclable in household waste streams in [country]" | Specific and geographically scoped |
| "Reduced water usage by 30% compared to our 2022 baseline, verified by [body]" | Specific, comparative with baseline, independently verified |
| "Compostable according to EN 13432" | Specific standard reference |
| "Contains no intentionally added PFAS" | Factual statement about composition |
| "Manufactured using 100% renewable electricity, certified by [scheme]" | Specific, verifiable |
The pattern: name one thing, measure it, prove it, cite the source.
How to audit your listings
Step 1: Search for flagged terms
Go through every product listing, description, bullet point, image, and A+ content on every EU marketplace where you sell. Search for the terms listed above. Flag each one.
Step 2: Decide — substantiate or remove
For each flagged claim:
- Can you replace it with a specific, verifiable statement? → Rewrite it.
- Can you not substantiate it? → Remove it.
Do not attempt to soften prohibited language. "Somewhat eco-friendly" is not more compliant than "eco-friendly." The issue is the claim's vagueness, not its strength.
Step 3: Check your images and packaging
EmpCo applies to all commercial communications, not just text. Green imagery (leaves, trees, earth imagery) used to imply environmental credentials without substantiation can also be challenged. Review product images and packaging graphics for implied environmental claims.
Step 4: Run the Regonance EmpCo Checker
Paste your product URL or marketing copy into the free Regonance EmpCo Checker. The tool flags generic eco-claims, offset-based neutrality language, unrecognised labels, and unsubstantiated future commitments — each cited to the specific EmpCo provision it engages.
Check your claims now → free, no account required
How Regonance helps
Regonance scans product listings and marketing copy against EmpCo requirements alongside GPSR, PPWR, DPP, and other EU mandates. Each flagged claim includes the regulation reference, risk level, and a suggested compliant rewrite. Available on all plans.
Educational information only. Not legal advice. National transposition of EmpCo may introduce additional requirements — check your local consumer protection authority's guidance.
Flag risky claims in 30 seconds — no account
Paste your product copy and see which environmental claims risk breaching the Empowering Consumers Directive before enforcement starts.
Run the free claims checkEvery EU deadline, on one page.
Nine mandates, each with dates attached between now and 2030. Get the calendar, plus a note when the guidance behind an article like this one changes.
- → Every applicable EU compliance date
- → Which mandate hits your category first
- → An alert when a rule or guidance changes
Compliance guidance based on published EU regulatory texts. Not legal advice. Consult qualified counsel for your specific situation.