Have you ever used terms such as ‘sustainable product’, ‘eco-friendly’ or ‘green’ in your corporate communications?
From 27 September 2026, many claims of this kind will no longer be permitted under Legislative Decree No. 30 of 20 February 2026, which transposes Directive (EU) 2024/825 against greenwashing into Italian law. In some cases, the ban is absolute and applies regardless of whether supporting documentation or evidence is provided.
Penalties can reach up to €10 million or 4% of a company’s annual turnover generated within the European Union. In Italy, enforcement and oversight of the legislation are entrusted to the Italian Competition Authority (AGCM – Autorità Garante della Concorrenza e del Mercato).
For many organisations, this means reviewing packaging, websites, marketing campaigns, sales materials and ESG communications. With the new rules coming into force in the near future, the time available to achieve compliance is more limited than it may appear.
It is important to note, however, that the legislation does not prevent companies from communicating their environmental commitments. Rather, it establishes clear rules on how those commitments can be communicated. In this article, we explore what is specifically prohibited and which environmental claims remain permissible.
A 2021 European Commission study (Screening of websites for greenwashing, DG JUST) found that over 50% of environmental claims on the market were vague, misleading or lacking any verifiable basis. The result was a distorted market: those genuinely committed to sustainability were penalised by those who ‘greenwashed’ their image at no cost.
The directive was introduced to correct this imbalance. It amends two existing European regulations - Directive 2005/29/EC on unfair commercial practices and Directive 2011/83/EU on consumer rights - by introducing new practices that are prohibited regardless of the circumstances.
Who does it apply to? Any business that sends commercial communications to consumers in the EU. Packaging, websites, social media, promotional materials, email marketing, press releases and sustainability reports published online: all fall within its scope. If you’re responsible for sustainability or communications within your company, then this regulation affects you directly.
The Directive establishes two levels of intervention. The first is the blacklist: practices that are prohibited a priori, without the need to prove that they have actually misled anyone.
Terms such as ‘eco-friendly’, ‘green’, ‘sustainable’, ‘environmentally friendly’, ‘ecological’, ‘climate-friendly’, ‘biodegradable’ (without specifications) and ‘bio-based’ are explicitly listed amongst the prohibited generic claims.
Graphic elements can also constitute an implicit environmental claim. Packaging dominated by green colours, leaves and organic textures creates an implicit environmental claim which the standard treats as equivalent to a textual one.
The only exception: you may use these terms if they are immediately accompanied by a clear and measurable specification on the same medium. A QR code linking to an external website is not sufficient as a specification; instead, a recognised certification of excellence is required: the EU Ecolabel, ISO 14024 Type I certifications, or Class A under the EU energy labelling scheme.
It will no longer be possible to claim that a product, service or organisation is ‘carbon neutral’, ‘climate neutral’, ‘CO₂ neutral’, ‘net zero’ or equivalent if this is achieved by offsetting emissions through carbon credits or certified environmental projects, even when these are verified against recognised standards such as the Gold Standard or VCS/Verra.
It is prohibited to present an environmental benefit relating to only one part of the product as if it applied to the product as a whole. The claim must be limited strictly to what it measures.
Self-created sustainability logos, badges and symbols – such as the ‘eco’ circle or the ‘100% green’ badge without a certifying body – are prohibited. Only mandatory regulatory symbols (e.g. CONAI) and certifications from recognised independent third-party bodies are permitted: EU Ecolabel, FSC, PEFC, COSMOS, GOTS.
It is prohibited to advertise as an added value something that the law already requires of everyone. If a feature is mandatory for all products in the same category, it cannot be used as a marketing tool or competitive advantage.
This applies to claims such as ‘nitrate-free baby food’, ‘BPA-free feeding bottles’ or ‘organic and GMO-free’: features that do not represent a voluntary choice by the company, but simply compliance with existing regulatory obligations.
If you are using one or more of these claims in your communications, on July 21st at 11:00 we will analyse real-life cases and answer your questions live!
The second level concerns practices that are not prohibited outright, but which may be considered misleading depending on the specific circumstances. The difference compared to the blacklist: here, context is key.
False or misleading environmental claims: stating ‘produced using renewable energy’ when only 10 per cent of the energy used is renewable, or displaying images of organic fields on a non-organic product.
Future claims without a verifiable plan: declaring an intention to achieve climate neutrality by 2030 without a credible public plan setting out measurable targets, deadlines, an allocated budget and periodic verification by an independent third party.
Emphasising irrelevant benefits: ‘recycled paper label’ on a disposable plastic product, or ‘green offices’ when the core business has significant impacts that are not being addressed.
Not all environmental claims carry the same level of risk. The new legislation does not prevent companies from communicating their environmental commitment, but it does require that every claim be supported by adequate and verifiable evidence.
Below is a practical hierarchy of environmental claims, ranging from those that are generally most defensible from a regulatory perspective to those most exposed to the risk of challenges.
Level 1 - Recognised certifications: EU Ecolabel, EMAS, ISO 14001, ISO 14024 Type I (Nordic Swan, Blue Angel, ICEA), FSC/PEFC, COSMOS, GHG Protocol, SBTi, MSC. If you hold a valid certification and the claim is limited to its scope, you are in good shape.
Level 2 - Third-party verifiable data: LCA compliant with ISO 14040/14044, Guarantees of Origin for renewable energy (GSE), EPDs on a public register, supply chain audits by an accredited body. The claim must be specific and the documentation must be available.
Level 3 - Specific, measurable claims: “100% recycled PET bottle”, “100% certified renewable energy - GO GSE”, “95% EU-certified organic ingredients”. These are valid if they are specific, measurable and verifiable in practice.
Level 4 - Generic self-declarations: “We produce sustainably”, “controlled supply chain” without certification, “low impact” without measurements. Non-compliant if generic, misleading if not verifiable.
Not sure where your current communication stands, or how exposed you are? On July 21st, we’ll help you find out with practical examples and a live Q&A session.
The first step is to compile the documentation that supports the claims you wish to make: emissions measurements, ESG reporting, and supply chain certifications. These form the basis for robust, verifiable environmental communication that can stand up to any scrutiny.
Before publishing any content with environmental relevance, ensure that each claim answers these five questions:
In an increasingly stringent regulatory environment, communicating sustainability does not mean communicating less. It means communicating better: with data, evidence and transparency.
If you’d like to understand exactly how all this applies to your organisation, we’re organising a free webinar in Italian on July 21st, where we’ll analyse real-life case studies and answer your questions live.
If you would like to explore these topics in a structured way and develop professional skills in corporate sustainability, the 7th edition of the Sustainability Manager & Practitioner Advanced Training Course, an Italian course starting in September 2026, includes a module dedicated to sustainable communication and the management of green claims.
Do you have any concerns about the compliance of your environmental communications, or would you like to assess the level of risk associated with your claims?
Our team can support you with a dedicated analysis and a plan to bring your communications into line.
Sources: EU Directive 2024/825; Legislative Decree No. 30 of 20 February 2026; European Commission, DG JUST, Screening of websites for greenwashing, 2021.