---
title: "EU Greenwashing Directive 2024/825: Bans and Examples"
description: Discover the implications of EU Directive 2024/825 on greenwashing. Learn how to ensure your company's sustainability claims are transparent and compliant.
image: https://page.greenfutureproject.com/hubfs/Greenwashing.png
---

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# EU greenwashing directive (2024/825): what is banned and examples of greenwashing

giugno 19, 2026

 

In this article we will cover:

1. [What greenwashing means](https://page.greenfutureproject.com/making-impact-possible-a-green-future-project-blog/eu-greenwashing-directive#what-greenwashing-means)
2. [The directive and national transposition](https://page.greenfutureproject.com/making-impact-possible-a-green-future-project-blog/eu-greenwashing-directive#directive-and-transposition)
3. [Who must comply](https://page.greenfutureproject.com/making-impact-possible-a-green-future-project-blog/eu-greenwashing-directive#who-must-comply)
4. [The 5 banned practices](https://page.greenfutureproject.com/making-impact-possible-a-green-future-project-blog/eu-greenwashing-directive#examples-of-greenwashing)
5. [Misleading green claims](https://page.greenfutureproject.com/making-impact-possible-a-green-future-project-blog/eu-greenwashing-directive#misleading-green-claims)
6. [How to avoid greenwashing: action plan](https://page.greenfutureproject.com/making-impact-possible-a-green-future-project-blog/eu-greenwashing-directive#action-plan)
7. [FAQs](https://page.greenfutureproject.com/making-impact-possible-a-green-future-project-blog/eu-greenwashing-directive#faqs)
8. [Greenwashing maturity test](https://page.greenfutureproject.com/making-impact-possible-a-green-future-project-blog/eu-greenwashing-directive#maturity-test)

---

If your packaging or website uses terms such as "eco-friendly", "green", "nature-friendly" or "zero emissions", since 27 September 2026 they are no longer a marketing asset but a liability. Under the EU greenwashing directive, formally Directive (EU) 2024/825, many of these claims are now banned commercial practices across all 27 EU Member States.

Europe has said no to misleading environmental claims. Any company selling to EU consumers faces a paradigm shift: from a self-referential system, with general rules and communications often lacking objective evidence, to an approach built on transparency and accountability. Understanding how to protect your business from reputational and financial risk is now essential.

Each Member State sets its own penalties and enforcement authority. For widespread infringements affecting several Member States, national laws must allow fines of at least 4% of the trader's annual turnover in the countries concerned, or at least €2 million where turnover data is not available. In Italy, for example, the competition authority (AGCM) can impose fines of up to €10 million.

 

## What does greenwashing mean under the new EU rules?

The directive does not use the word greenwashing, but it bans the practices behind it. In practice, greenwashing means making generic environmental claims such as "biodegradable" or "ecological" without being able to demonstrate recognised excellent environmental performance (for example, the EU Ecolabel), or using sustainability labels that are not based on an independent certification scheme.

An environmental claim is any written, oral, graphic or symbolic message, including one contained in a company or product name, that attributes an environmental benefit. Every claim of this kind must be backed by transparent and precise evidence, so that consumers are not misled.

 

## The EU greenwashing directive and its national transposition

Directive (EU) 2024/825, also known as the *Empowering Consumers for the Green Transition Directive,* amends two existing EU laws: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). Member States had to transpose it into national law by 27 March 2026, and the new rules apply from 27 September 2026. In Italy, for example, it was transposed by Legislative Decree no. 30/2026.

These are not mere recommendations: they mark the end of the era of generic environmental claims. Transparency is no longer an ethical option but a strict compliance requirement:

- **For the entrepreneur**, it creates **operational risk**. A non-compliant claim exposes the company to fines for unfair commercial practices and to orders to change or withdraw the communication, with relabelling costs and reputational damage.
- **For the investor**, it creates **financial risks**. The European supervisory authorities, including the EBA (European Banking Authority) and ESMA (European Securities and Markets Authority) are clear: greenwashing has a direct impact on ESG ratings and, as highlighted in the Bank of Italy’s Working Papers, can significantly alter the cost of credit.

The answer is not to stop communicating sustainability, and thereby falling into the practice of [greenhushing](https://page.greenfutureproject.com/making-impact-possible-a-green-future-project-blog/communicate-environmental-sustainability-avoid-greenwashing), but of doing so through recognised excellence, with integrity, transparency and the correct tools. Every green claim must be supported by scientific evidence and detailed implementation plans for future climate targets.

 

## Who must comply with the EU rules on green claims?

The rules apply to any business that makes commercial communications to consumers in the EU, regardless of size, sector or where the company is based. What matters is the market, not the headquarters: a manufacturer outside the EU that sells to European consumers must comply just like an EU company.

This covers:

- **EU manufacturers and brands** selling to consumers in any Member State;
- **non-EU exporters**, including UK, US and Asian companies, whose products reach EU consumers;
- **importers and distributors** placing products on the EU market with claims on packaging or labels;
- **online sellers and marketplaces** targeting EU consumers.

Every channel that carries an environmental message is in scope: packaging and labels, websites and e-commerce, social media and email marketing, promotional materials, catalogues and press releases, and ESG content used for promotional purposes.

The same applies to claims you receive from suppliers: if you display them on your product, you are responsible for them towards the consumer. For exporters, this often means adapting packaging and marketing specifically for the EU market.

## The 5 banned practices for green claims

The directive adds specific practices to the EU black list of unfair commercial practices. These are banned in all circumstances, with no need to prove that anyone was actually misled.

**1. Generic environmental claims.** Terms such as "eco-friendly", "green", "sustainable", "ecological", "environmentally friendly", "climate-friendly", "biodegradable" or "bio-based" are banned when used on their own. You may only use them if you state clearly, on the same medium, exactly what they refer to, or if you can demonstrate recognised excellent environmental performance (the EU Ecolabel or an officially recognised EN ISO 14024 Type I ecolabel). A QR code linking to an external website is not enough.

![Claim 1](https://page.greenfutureproject.com/hs-fs/hubfs/Claim%201.png?width=1552&height=274&name=Claim%201.png)

**2. Product claims based on carbon credits.** You cannot claim that a product or service has a neutral, reduced or positive impact on greenhouse gas emissions if that result relies on buying carbon credits, even when those credits are certified under Gold Standard or VCS/Verra. Buying carbon credits is not the same as neutralising emissions.

![Claim 2](https://page.greenfutureproject.com/hs-fs/hubfs/Claim%202.png?width=1552&height=274&name=Claim%202.png)

**3. Partial claims presented as total.** You cannot attribute to a whole product a benefit that concerns only one part of it. The claim must be limited to exactly what it measures.

![Claim 3](https://page.greenfutureproject.com/hs-fs/hubfs/Claim%203.png?width=1552&height=243&name=Claim%203.png)

**4. Self-made sustainability labels.** The "home-made label" is gone. Only labels based on a third-party certification scheme or established by public authorities are allowed, such as the EU Ecolabel, FSC, PEFC, COSMOS and GOTS. Mandatory environmental labelling of packaging remains, because it is a legal requirement.

**5. Legal requirements presented as a distinctive feature.** You cannot present as an advantage something that the law already requires of every product in the same category.

## Misleading green claims practices and premature obsolescence

Misleading practices 

Beyond the black list, a practice is misleading when it leads consumers to a purchasing decision they would not otherwise have taken, through:

- **Action**: providing false information, or presenting information in a way that misleads consumers about the environmental or social characteristics of a product.
- **Omission**: hiding relevant information, or presenting it in an unclear or untimely way.

Planned Obsolescence

The directive strengthens a key pillar of the circular economy by banning business strategies that artificially shorten a product's life. Companies must now pay attention to:

- **Limiting functionalities:**  it is banned to withhold from consumers the existence of features introduced to limit a product's durability or prevent its repair.
- **Repairability transparency:** durability alone is not enough; consumers must be clearly informed about the availability of spare parts and how easy the product is to repair.
- **Software updates:** in the tech sector, it is banned to push consumers to replace a product because of software updates that slow down performance or impair its use without a genuine technical need.

## How to avoid greenwashing: an action plan

The rules already apply, and good intentions are not enough to communicate correctly. You need to:

### **1. Eliminate generic environmental claims**

The first practical step is to overhaul existing communications. Terms such as ‘environmentally friendly’, ‘natural’ or ‘sustainable’ without supporting technical specifications are now classified as generic environmental claims.

Any claim seeking to ‘greenwash’ itself must be verified by an accredited conformity assessment body. Sustainability thus shifts from a marketing cost to a certified corporate asset, protecting the brand from claims for compensation and reputational damage that could jeopardise access to bank credit.

### 2. Use only labels and claims verifiable by independent third parties

The ‘homemade label’ has officially been consigned to history. To be valid, sustainability labels must be based on a certification system for sustainability labels managed by independent third parties and underpinned by transparent and verified procedures.

Using recognised certifications such as the EU Ecolabel or EPD reduces legal risk and improves scores in due diligence processes, whilst also simplifying ESG risk assessments.

### 3. Set an implementation plan for future climate targets

If you want to claim you will become "net zero by 2040" or cut your emissions by 50%, that commitment must now be supported by a detailed, publicly available implementation plan.

A simple announcement is no longer sufficient. The regulatory authority will verify the presence of:

- Measurable interim targets: clear objectives set on an annual or biennial basis
- **Allocation of resources**, demonstrating the allocation of budgets and technologies to achieve the objectives
- **Ongoing monitoring** via a reporting system that allows progress to be tracked.

### 4. Use the right tools to support your communication

Transparency towards consumers also depends on the means used to convey information. The new regulatory framework requires adjustments not only to the content, but also to the visual and digital tools used for communication. The information must be comprehensive and clearly visible at the first click, when the cursor is moved, or when the QR code is scanned.

In terms of internal governance, secure communication requires the use of diagnostic tools to systematically map all environmental claims disseminated through the various physical and digital touchpoints (from packaging to websites and e-commerce platforms). A centralised approach ensures that every claim made – even indirectly via suppliers – is consistent, verified and monitored over time.

 

## FAQs

### When did the EU greenwashing directive come into force?

Directive (EU) 2024/825 entered into force on 26 March 2024, but its rules apply from 27 September 2026. Member States had to transpose it into national law by 27 March 2026. From the application date, banned environmental claims can be sanctioned by national enforcement authorities.

### What are green claims?

Green claims are statements, including graphic or symbolic ones, that attribute an environmental benefit or a reduced impact to a product, service or company. They can appear on packaging, websites, advertising and social media. Since 27 September 2026, they must be specific and backed by evidence.

### Does the directive apply to non-EU companies?

Yes, if they sell to consumers in the EU. The directive applies to commercial practices directed at EU consumers, wherever the company is based. Exporters, importers and online sellers must align claims on packaging, labels and marketing for the EU market.

### Is the EU greenwashing directive the same as the Green Claims Directive?

No. Directive (EU) 2024/825 is already in force and applies from 27 September 2026. The Green Claims Directive is a separate proposal, COM(2023)166, which set out more detailed rules on how claims should be substantiated and verified. The rules currently applicable are those of Directive 2024/825 and its national transpositions.

### Can I still say "carbon neutral" on a product?

Not if the claim relies on buying carbon credits: that practice is banned in all circumstances. You can communicate actual, measured and documented reductions in a product's emissions. Support for climate projects should be presented as a contribution, kept separate from the product's footprint.

## Is your company ready for the Maturity Test on greenwashing?

The EU greenwashing directive marks the end of "good intentions marketing". Since 27 September 2026, the market has been separating transparent companies from vulnerable ones.

Greenwashing is no longer a "communication error" but an operational risk that directly affects the cost of capital and investor confidence.

Before publishing any content with an environmental message, check that every claim passes these five questions:

![Green claims - Infografica ENG](https://page.greenfutureproject.com/hs-fs/hubfs/Green%20claims%20-%20Infografica%20ENG.png?width=2160&height=2180&name=Green%20claims%20-%20Infografica%20ENG.png)

Cutting out the background noise of generic claims allows truly outstanding companies to stand out, protected by a legal framework that finally prioritises scientific evidence over creative storytelling.

Is your communication strategy ready? Or are you navigating a sea of legal risk without a map? Operating and communicating through this transition requires professional diligence that goes well beyond updating your labels.

The Consultancy and Communication team at [Green Future Project Group](https://greenfutureproject.com/en)can help you assess your environmental claims and redefine your marketing strategies.

[Contact our team](https://page.greenfutureproject.com/book-a-demo-blog-eng)

Written by Miriam Dri, Legal and Administrative Advisor di Baker Tilly Hidra Sb part of [Green Future Project Group](https://page.greenfutureproject.com/richiedi-demo-blog?utm_source=organic&utm_medium=blog&utm_campaign=greenwashing_cta1).

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