The EU rules on environmental claims from 27 September 2026
By Made for Planet Carbon team • • 6 min read

From 27 September 2026, the EU's rules on environmental claims to consumers changed. Directive (EU) 2024/825, often called the Empowering Consumers Directive, added specific practices to the list of commercial practices that are always unfair. For manufacturers supplying European brands, the effect is simple: brands now need figures and evidence, not adjectives.
- 1March 2024Directive (EU) 2024/825 published
- 227 March 2026Deadline for national laws
- 327 September 2026The rules apply
What is now banned
- Generic environmental claims, such as "eco-friendly" or "green", unless the trader can show recognised excellent environmental performance relevant to the claim.
- Claims that a product has a neutral, reduced or positive impact on the environment because emissions are offset.
- Sustainability labels that are not based on a certification scheme or set up by public authorities.
- Claims about a whole product when they are true only of part of it.
Why it matters to suppliers
The rules apply to what brands say to consumers, not to the data suppliers send their customers. But a brand can only say something specific (for example, how much of a product's footprint comes from materials) if it has the product data behind it. That data starts with its suppliers.
So the practical result for factories is more requests for product carbon footprints, with a method and sources attached. We cover how to reply in how to answer a customer's carbon footprint request.
What a footprint can and cannot support
A product carbon footprint is a measured figure with a stated method. It is the kind of evidence a specific claim needs. It does not on its own make a product "low carbon" or better than another: comparisons between products need the same method, unit and boundary, and an independent critical review before they are made in public.
Our claims checker shows how a claim's wording fares against these rules and what evidence sits behind it.
What a specific claim can look like
The rules push brands away from adjectives and towards statements that can be checked. A claim about a product's climate impact can stand up when it states what was measured, how and for which unit, and when the evidence is available. A product carbon footprint with its method, boundary and sources is that evidence.
Comparisons between products, such as "lower carbon than our previous range", need the same method and boundary for both products, and in public an independent critical review.
What suppliers can do now
- Footprint the products your EU customers buy most, with a stated method.
- Keep the report and data file ready to send with each figure.
- Avoid sending marketing language with the data: let the brand decide what to claim.
- Expect follow-up questions about data quality and primary data share.
Preparing for the EU rules on environmental claims: a supplier walkthrough
Picture a packaging maker that supplies cartons to several brands selling in Europe. One brand's marketing team wants to say something about the climate impact of its new box. Before it can, its own team asks the packaging maker for evidence.
The packaging maker does not need to know every detail of the law. It needs to answer one question well: what is the carbon footprint of this carton, how was it worked out, and what does it rest on? It footprints the carton with a stated method and boundary, writes down its sources and assumptions, and sends a report and a data file. The brand's own legal and marketing teams then decide what, if anything, to say to consumers.
The supplier's job is good evidence. The claim belongs to the brand.
In practice, this means the packaging maker's preparation looks the same whether the request comes from a fashion brand, a footwear brand or a retailer. A clear footprint, a clear report and a named person to answer questions cover most of what any of them will ask.
A practical checklist for suppliers to EU brands
This list is about preparation, not legal advice. Each brand will apply the rules to its own claims; your part is to have the evidence ready when they ask.
None of these steps depends on the detail of national law. They are good practice for any customer who asks for product data, inside or outside the EU.
- List your EU customers and the products each buys most.
- Footprint those products first, with the method, unit and boundary stated plainly.
- Keep an evidence file per product: the report, the data file, your bills of materials and your sources.
- Write down assumptions and gaps, so a brand can judge what the figure can support.
- Check your own wording: in sales material and product sheets, replace adjectives with figures and methods.
- Name a contact who can answer follow-up questions from customers' teams.
- Set a date to update each footprint, and tell customers when you do.
- Group similar products, so one set of records and assumptions serves several items in a range.
Common misunderstandings among suppliers
A few beliefs come up often among manufacturers. Each one can lead to wasted effort or awkward questions from customers.
- "The rules do not concern us because we do not sell to consumers." The claims are made by brands, but the evidence behind them often starts with suppliers, so requests reach you anyway.
- "A footprint lets the brand call the product low carbon." A footprint is a figure with a method. It does not on its own support a comparison or a general label.
- "Words like eco-friendly are fine in our own sales sheets." Generic wording passed to a brand can end up in front of consumers. Figures with methods travel better.
- "Once done, the evidence lasts for ever." Products, suppliers and energy change. Keep footprints current and dated.
- "The brand will work it all out from our invoices." A brand can only use what a supplier gives it. Product data with a method behind it is far more useful than purchase records alone. See how to answer a customer's request.
- "Sending more data is risky." Clear, dated figures with stated limits are easier for a brand to use with care than vague assurances.
Each country's own law
As a directive, 2024/825 works through each member state's national law, and the national rules and enforcement differ. Brands check the rules for the markets they sell in; our compliance page lists what applies by market and company size.
Questions
What should a supplier send a brand that wants to make a climate claim?
A product carbon footprint with a report stating the method, boundary, sources and limitations, plus a data file. Leave the wording of any claim to the brand.
Should suppliers check their own marketing wording as well?
Yes. Replacing vague adjectives with stated figures and methods in sales sheets helps brands and avoids generic wording reaching consumers. Our [claims checker](/claims) can help you test a phrase.
Do the EU rules apply to suppliers outside the EU?
They apply to commercial practices aimed at EU consumers, which usually means the brand, but brands pass the need for evidence on to their suppliers.
When did the EU rules on environmental claims start to apply?
On 27 September 2026, under Directive (EU) 2024/825. Member states had to adopt their national laws by 27 March 2026.
Can a product still be called carbon neutral because of offsets?
No. Claims of a neutral, reduced or positive impact based on offsetting are banned for products under the directive.
Does the directive require product carbon footprints?
No, but specific claims need evidence, and product footprints are the usual evidence for climate claims.


