New EU Green Claims Rules: A Checklist for UK Sellers

New European consumer rules take effect on 27 September 2026. UK businesses selling to consumers in the European Union or European Economic Area need to review environmental claims, sustainability labels and product information now.

The rules come from the European Union’s Empowering Consumers for the Green Transition Directive. They strengthen protection against misleading environmental claims and introduce clearer requirements around durability, repairability and product guarantees.

This is relevant beyond businesses based in the European Union. Official guidance from Ireland’s Department of Enterprise, Tourism and Employment states that the requirements apply to companies outside the EU when they sell products or services to EU or EEA consumers.

Who should review their marketing?

A UK business should investigate the rules if it sells directly to consumers in the EU or EEA through its website, an online marketplace, a distributor or another consumer sales channel.

The review should include website pages, product descriptions, advertisements, packaging, labels, social media posts and any environmental comparison with competing products.

A business selling only to UK consumers is not brought into EU law simply because its website can be viewed abroad. However, UK environmental marketing is already subject to consumer protection and advertising rules, including the Competition and Markets Authority’s Green Claims Code and Advertising Standards Authority guidance.

Which environmental claims create risk?

The official directive addresses several practices that smaller businesses may currently use without realising the consequences.

Generic environmental language

Terms such as green, environmentally friendly, eco friendly, climate friendly and biodegradable can be prohibited when the business cannot demonstrate recognised environmental performance relevant to the claim.

Adding a green colour, leaf symbol or natural image does not automatically avoid the issue. Environmental claims can be communicated through words, symbols, graphics, brand names and presentation.

Claims about the whole product or business

A business should not suggest that an environmental benefit applies to an entire product when it concerns only one component. For example, recycled packaging does not necessarily make the product itself recycled.

Carbon claims based on offsetting

The directive prohibits claims that a product has a neutral, reduced or positive environmental impact when that claim is based on offsetting greenhouse gas emissions outside the product’s value chain.

Businesses can still communicate investments in environmental initiatives when the information is accurate and not misleading. The crucial point is that buying credits should not be presented as though it changed the actual lifecycle impact of the product.

Unverified sustainability labels

Sustainability labels generally need to be established by a public authority or supported by a qualifying certification scheme with independent monitoring. Creating a logo internally and placing it on packaging can create a misleading impression of independent approval.

Future environmental promises

Claims about future performance require clear, objective and publicly available commitments. Plans need measurable targets, appropriate resources and regular independent verification.

A practical environmental claim audit

Environmental compliance should not be treated as a final check performed by the marketing team. A claim is a factual business statement. It needs an owner, evidence and a review date.

1. Create a complete claim register

List every environmental statement appearing on websites, product pages, packaging, advertisements and social media. Include graphics, badges and product names that may imply an environmental benefit.

2. Record the exact evidence

For each claim, identify the document, test, supplier evidence or certification that supports it. Evidence should be current and relate to the claim as an ordinary customer would understand it.

3. Narrow claims that are too broad

Replace vague descriptions with specific, measurable statements where the evidence permits. A precise statement about packaging material may be more defensible and more informative than describing the whole product as sustainable.

4. Verify every label

Confirm who created the label, what standard it represents, how compliance is monitored and whether the scheme meets the applicable requirements. Do not assume that a supplier badge is automatically acceptable.

5. Assign approval responsibility

Name the person who can approve environmental wording before it is published. Keep the evidence and approval record together so that the business can respond quickly if a claim is questioned.

6. Review product guarantees and information

The new rules extend beyond environmental wording. Businesses selling goods should review information about durability, repairability, software updates and product guarantees. The European Commission provides an official overview and supporting guidance.

What about UK marketing?

The EU changes should not encourage UK only sellers to ignore their existing responsibilities. The CMA’s Green Claims Code sets six principles for environmental marketing. Claims should be truthful, clear, substantiated, complete and fair, while considering the full lifecycle where relevant.

Recent ASA guidance also emphasises that broad claims require strong evidence and that businesses should explain the basis of terms such as sustainable rather than leaving customers to infer an absolute benefit.

My view: evidence should come before marketing language

Small businesses should not stop discussing genuine environmental improvements. Silence would make it harder for customers to identify businesses making responsible changes.

However, environmental language must be treated with the same discipline as pricing, financial and performance claims. Marketing teams should not be expected to prove statements after they have already been published.

The practical answer is a simple operating process: define the claim, identify the evidence, confirm its scope, approve it and review it when the product or evidence changes.

This article provides general business information rather than legal advice. Businesses selling into the EU should confirm how the directive has been implemented in the countries where their customers are located and obtain specialist advice where necessary.

Key takeaway: Environmental claims are factual business claims. Do not publish them until the evidence, scope, owner and review process are clear.