From 27 September 2026 (EU Directive 2024/825), new rules apply across the European Union to environmental claims in commercial communication — and a website is commercial communication. This does not only affect the online shop with the green label next to the price. It also affects the phrase ”sustainably produced” on the home page, the leaf symbol in the logo, the paragraph about your contribution to climate protection on the about page and the three awards in the footer. The directive adds to the list of commercial practices that are unfair in all circumstances a set of cases that concern exactly such claims (EU Directive 2024/825). At the same time, a review by the European Commission shows how widespread the problem is: 53 percent (European Commission) of the environmental claims examined were vague, misleading or unfounded. If you run a site that carries environmental claims, you do not need a rebuild, but you do need an honest review of the text. This article shows which wordings are meant, what evidence belongs with them and how such a review works in practice.
Key takeaways
- Directive (EU) 2024/825 had to be transposed into national law by 27 March 2026 (EU Directive 2024/825) and applies from 27 September 2026 (EU Directive 2024/825). Two dates with two addressees: the first concerns the legislator, the second concerns your site.
- Under the directive an environmental claim is not only a sentence but also an image, a graphic element, a symbol, a brand name or a product name, as long as it suggests a positive or absent effect on the environment (EU Directive 2024/825).
- Generic environmental claims without demonstrated recognised excellent environmental performance move into the list of practices that are unfair in all circumstances (EU Directive 2024/825). A claim counts as generic when the specification is not stated clearly and prominently on the same medium.
- A sustainability label that is not based on a certification scheme and was not established by public authorities may no longer be displayed (EU Directive 2024/825). That includes the graphic that has been sitting in your footer since the last relaunch.
- Independently of this, a misleading commercial practice is already unfair today (UWG), and the Federal Court of Justice requires an ambiguous environmental term to be explained within the advertisement itself (Federal Court of Justice).
Two dates, one deadline for your website
Directive (EU) 2024/825 carries the official title Directive on empowering consumers for the green transition. It does not amend the German UWG directly; it amends the European directive on unfair commercial practices, which has been part of German law through the UWG for years. The route therefore runs through the national legislator. That is precisely why the text contains two dates, and they are regularly confused. The article on transposition first names the deadline for the member states: 27 March 2026 (EU Directive 2024/825). By that date the national provisions had to be adopted and published. The second sentence of the same paragraph names the day from which those provisions apply: 27 September 2026 (EU Directive 2024/825). For your website the second date is the one that counts.
In practice this means that for half a year the new provisions already exist but do not yet affect running advertising. This transition period is the actual purpose of the construction — it is meant for reviewing catalogues, packaging, adverts and, yes, websites. Anyone who lets the time pass will be standing at the deadline with a body of content that would have to be checked sentence by sentence while it is online. A website has one advantage over printed media here: it can be changed in an afternoon. It also has a disadvantage: nobody remembers how many environmental claims have made their way into product texts, landing pages and blog posts over the past eight years. That is why the work starts with an inventory, not with rewriting.
Transposition deadline is not the date of application
What counts as an environmental claim in law
The directive introduces its own definition, and it is considerably broader than most people expect. An environmental claim is any claim or representation, in whatever form, that is not mandatory under law and that states or implies, explicitly or implicitly, that a product, a product category, a brand or a trader has a positive or zero impact on the environment, is less damaging than others, or has improved its impact over time (EU Directive 2024/825). The definition expressly names text, pictorial and graphic representations and symbols, along with labels, brand names, company names and product names.
For a website that means the review does not stop at the body copy. A leaf motif in the background of a product section, a green tick next to a shipping option, a photograph of forest and sunlight, a product name containing the element Eco — all of these can be environmental claims without a single word about it in the text. If you are sorting out your imagery anyway, the relevant questions about origin and proof are in our article on images on your website. On the text level it is worth revisiting the principles of website copy that sells: a claim you can back up is almost without exception the more concrete one, and therefore the more convincing one.
Environmental claim
The umbrella term. Any voluntary statement that suggests a positive, neutral or improved environmental effect (EU Directive 2024/825). It can sit in a sentence, in a symbol, in a product name or in an image. Mandatory labelling required by Union law does not count.
Generic environmental claim
An environmental claim that is not carried on a sustainability label and where the specification is not stated clearly and prominently on the same medium (EU Directive 2024/825). This is exactly the form that is unlawful without demonstrated excellent environmental performance.
Sustainability label
A voluntary trust mark, quality mark or equivalent that highlights environmental or social characteristics (EU Directive 2024/825). Without an underlying certification scheme or establishment by public authorities it may not be displayed.
- Claims such as ”environmentally friendly”, ”green”, ”eco” or ”climate friendly” that stand alone and are explained nowhere on the same page (EU Directive 2024/825)
- A label the agency once delivered as a graphic, with no certification scheme and no public establishment behind it (EU Directive 2024/825)
- A claim about the whole business that in truth relates only to one site, one product line or a single step in the process (EU Directive 2024/825)
- Presenting a product as climate neutral where the statement is based on offsetting greenhouse gas emissions (EU Directive 2024/825)
- Legal obligations that apply to every supplier in the same product category, presented as a distinctive feature of your own offer (EU Directive 2024/825)
- A claim about future environmental performance without a publicly accessible implementation plan and without verification by an independent third-party expert (EU Directive 2024/825)
Climate neutral: the term where everything becomes visible
No term has shaped the debate like this one, and none is better suited to explaining the principle. On 27 June 2024 (Federal Court of Justice) the German Federal Court of Justice ruled that advertising with an ambiguous environmental term is as a rule only permissible if the advertisement itself explains what that term specifically means. The court reasoned that reducing emissions and offsetting them are not equivalent measures. Clarifying information outside the environmental advertising is not sufficient under this decision (Federal Court of Justice) — so a link to a sub-page carrying the explanation does not save the claim on the home page.
From the deadline onwards the case becomes even clearer, because the directive expressly adds the offset-based neutrality claim to the list of practices that are unfair in all circumstances (EU Directive 2024/825). Anyone advertising a product or a shipping option as climate neutral today on the basis of offsetting has a wording in their content that cannot be rescued by an explanation. The alternative is uncomfortable but clean: name the actual measure. So not the attribution of a state, but the description of a process — what share of emissions was reduced, through which measure, over which period, and what happens to the remainder.
The difference between generic and specific
What the UWG already says today
It would be a misunderstanding to read the deadline as the start of regulation. Environmental claims have been open to challenge for a long time, simply through the general provisions. Anyone who engages in a misleading commercial practice that is likely to cause a consumer to take a transactional decision they would not otherwise have taken is already acting unfairly (UWG). Added to that is misleading by omission: withholding material information that is needed for an informed decision is unfair as well (UWG). Both regularly apply to an environmental claim without a reference point.
What changes at the deadline is above all the evidential position. The list in the annex to the UWG contains practices that are unfair towards consumers in all circumstances (UWG) — there no case-by-case balancing is required, the facts alone are enough. It is exactly this list that the new environmental cases move into. A discussion about whether a particular wording misleads in the specific case turns into the simple question of whether the facts are met. Anyone who reviews their site regularly will recognise the routine from other topics: the mandatory legal notice details and the rules for product reviews follow the same logic.
- A misleading commercial practice is unfair where it is capable of influencing a transactional decision (UWG)
- Withholding material information is unfair as well, as is providing it in an unclear or ambiguous manner (UWG)
- The practices listed in the annex are unfair towards consumers in all circumstances, with no examination of the individual case (UWG)
- Claims are available to competitors, and additionally to registered trade associations and qualified consumer associations (UWG)
- Before court proceedings a warning letter should be sent, with an opportunity to give a cease-and-desist undertaking (UWG)
- The warning letter must state clearly and comprehensibly on what the entitlement is based and which factual circumstances constitute the infringement (UWG)
Who can challenge an environmental claim
Labels and awards in the footer
Almost every website that has grown over the years carries a row of small graphics in the footer: memberships, awards, voluntary commitments, occasionally a label whose origin nobody in the company can name precisely any more. From the deadline onwards, displaying a sustainability label that is not based on a certification scheme or was not established by public authorities is a practice that is unfair in all circumstances (EU Directive 2024/825). The directive describes precisely what constitutes a certification scheme: open and non-discriminatory participation, verifiable criteria and monitoring of compliance by a third party.
The scale of the confusion can be quantified. According to the European Commission there are 230 sustainability labels (European Commission) in the EU plus around 100 (European Commission) green energy labels, with vastly different levels of transparency. For half of all green labels the verification is weak or non-existent (European Commission). For your footer that means every logo needs an answer to three questions — who awards it, against which criteria, and who checks compliance. If the answer to any of the three is missing, the logo comes off the page. How to organise this kind of content upkeep in a predictable way is described in our article on ongoing website maintenance.
| Element on the page | Frequently found | Sound after the deadline |
|---|---|---|
| Home page claim | ”Sustainable since 1998” | Named measure with period and reference point |
| Product text | ”environmentally friendly packaging” | What the packaging consists of, with a share |
| Shipping option | ”climate neutral shipping” | Description of the measure instead of a state attributed |
| Label in the footer | Graphic with no traceable origin | Label with certification scheme and audit body |
| About us | Claim about the entire business | Claim stating what it actually relates to |
| Target statement | ”climate neutral by 2030” | Implementation plan, publicly accessible and externally verified |
| Imagery | Leaf symbols with no textual basis | Image motif that picks up the substantiated claim |
A link to a sub-page is not enough
Reviewing the environmental claims you already have
The review is less legal than it sounds. It consists of three passes, and the first is pure inventory. Collect every place where an environmental reference appears: home page, service pages, product texts, shipping information, about page, footer, blog posts, newsletter archive, image captions and alternative texts. A full-text search across your own site finds the obvious terms. The quiet cases — symbols, image motifs, product names — are only found by a person clicking through the pages. For a mid-sized company site, expect half a day.
The second pass assigns each finding to one of three groups: substantiated and specific, substantiated but worded generically, not substantiated. The first group stays. The second is rewritten so that the evidence moves into the sentence. The third disappears. The third pass secures the evidence: every remaining claim needs a file, a test report, a certificate or a calculation — filed somewhere a person will still find it in two years. How to assemble that kind of material cleanly is described in our article on preparing a website project.
First pass: find
Full-text search for the known terms, then a manual pass through every page type. Symbols, image motifs and product names count too, because they can be environmental claims as well (EU Directive 2024/825). The result is a list with page address and location.
Second pass: sort
Every finding gets one of three marks: specific and substantiated, generic but substantiable, no evidence. The middle group is the largest and the most interesting, because the information already exists in the company and is merely missing from the sentence.
Third pass: secure
For every remaining claim the evidence goes into an organised archive, with a date and an owner. For claims about future environmental performance, external verification belongs with it (EU Directive 2024/825).
Two side effects are pleasant. First, the texts get better. In the supplementary survey accompanying its 2022 environmental awareness study, published in 2024, the German Environment Agency recorded that a clear majority of 79 percent (German Environment Agency) of respondents are often unsure which products are genuinely environmentally sound. Taking that uncertainty seriously pays off: a substantiated statement achieves more than a slogan, because a specific claim is more concrete, and concrete claims convince in a sales conversation as much as in a search result. Second, you end up with a body of substantiated material that can fill product pages, newsletters and posts. If you send marketing emails anyway, the same rules apply to the claims in them — the formal requirements are covered in our article on compliant newsletters. For shops there is an additional layer of mandatory information, described in the overview of GPSR and ProdSG.
- Every page type captured, including the footer, image captions and alternative texts
- For every label: who awards it, against which criteria, who verifies (EU Directive 2024/825)
- Every generic claim either specified or removed (EU Directive 2024/825)
- Offset-based neutrality claims replaced by a description of the measure (EU Directive 2024/825)
- Target statements backed by a publicly accessible implementation plan and external verification (EU Directive 2024/825)
- Evidence filed, with date, source and the person responsible
From the rule text to the revised page
The effort depends less on the size of the site than on how many unsubstantiated claims are sitting in it. For a company site of twenty to forty pages, one working day is enough for inventory and sorting, a second for rewriting. For a shop with many product texts it becomes a task best solved with text modules: the claim moves to a place that is maintained centrally instead of into a thousand descriptions. If a rebuild is due anyway, the timing is good — the typical relaunch mistakes can then be dealt with in the same pass.
We take on this review as a defined package: inventory, sorting, wording proposals and the implementation in the text, on request with a short set of guidelines for your team so that new copy does not fall back into the old pattern. What it costs depends on the scope; the ranges are set out in our pricing overview, and the ongoing upkeep afterwards is described on the website care page. If you would first like to know where your site stands, get in touch — an initial assessment usually emerges while walking through the home page. An overview of the full range of work is on the services page, and if you want to sort out data protection in parallel, the points are in the GDPR checklist for websites.
Sources and Studies