The blacklist
Banned green claims: what you can no longer say
The rule in one line
Short answer
Making a generic environmental claim is banned in all circumstances unless the trader can demonstrate recognised excellent environmental performance relevant to that claim (Annex I, point 4a of the UCPD, as added by the EmpCo Directive).
A claim is "generic" when it is broad and unexplained. If you specify the claim in clear and prominent terms on the same medium, right next to it, it stops being generic. Then it is a specific claim. Specific claims are not automatically banned. But they still must be true, provable and not misleading.
Words on the watch list
The directive's Recital 9 names these examples of generic claims. This is not a closed list. Any similarly vague wording gets the same treatment.
Careful: "energy efficient" is only fine when you can point to recognised top performance, for example under the EU Energy Labelling rules. And "biodegradable" as a bare word is generic. "The packaging is biodegradable through home composting in one month" is specific.
Generic vs specific: side by side
| Banned as generic | Allowed when true and provable |
|---|---|
| "Climate-friendly packaging" | "100% of the energy used to produce this packaging comes from renewable sources" (the Commission's own example) |
| "Eco-friendly detergent" | "Awarded the EU Ecolabel" (with the genuine label) |
| "Green delivery" | "Delivered by electric vehicles charged with certified renewable electricity" |
| "Biodegradable" | "Certified home-compostable within 12 weeks (EN 13432 based scheme)" |
| "Made with care for the planet" | "Made with 80% post-consumer recycled polyester, verified by an independent certifier" |
The specification must sit on the same medium as the claim. Same packaging, same ad, same product page. A link to a sustainability page buried elsewhere is not enough. On small packaging there is some flexibility, but the average consumer must be able to understand the link between the claim and the explanation.
The escape hatch: recognised excellent environmental performance
There is exactly one way to keep a truly generic claim. Prove recognised excellent environmental performance that is relevant to the claim. The Commission's June 2026 Q&A lists three routes:
| Route | What it means |
|---|---|
| EU Ecolabel | Your product carries the official EU Ecolabel under Regulation (EC) No 66/2010. |
| National ISO 14024 type I ecolabels | Officially recognised schemes like the Nordic Swan, Blue Angel, the Austrian Ecolabel or the Dutch Milieukeur. |
| Top performance under other EU law | For a specific characteristic. Example: top energy class under the Energy Labelling Regulation supports an energy claim. |
Relevance matters. An A energy label supports "energy efficient". It does not support "biodegradable". The proof has to match the promise.
Design, colours and packaging artwork
The rules do not stop at words. The Commission warns that green leaves, water drops, trees, animals and green or blue colour schemes can act as implicit claims. On their own, images are not "generic environmental claims" in the legal sense. That term needs text or speech. But combine imagery with a word or a logo and you may create a claim, or something consumers read as a trust mark. Then the label rules kick in too.
The benchmark is always the average consumer: reasonably well informed, reasonably observant. Authorities do not need consumer surveys to decide what your packaging implies. If the overall look oversells the environmental benefit, that is a problem.
The rules apply from 27 September 2026
That includes products already on the shelf. Check your claims, labels and product pages now, not after enforcement starts.
Frequently asked questions
Which green claims are banned under the EmpCo Directive?
Generic environmental claims are banned unless you can prove recognised excellent environmental performance. Examples from the directive itself: environmentally friendly, eco-friendly, green, nature's friend, ecological, environmentally correct, climate friendly, gentle on the environment, carbon friendly, energy efficient, biodegradable, biobased and similar vague terms.
What is a generic environmental claim?
It is any environmental claim, written or spoken, that is not on a sustainability label and is not specified in clear and prominent terms on the same medium. 'Climate-friendly packaging' is generic. '100% of the energy used to produce this packaging comes from renewable sources' is specific, because it explains itself.
How can a company still use a generic green claim legally?
Three routes. One: the product carries the EU Ecolabel. Two: it carries an officially recognised national ISO 14024 type I ecolabel, like the Nordic Swan, Blue Angel or Dutch Milieukeur. Three: it shows top environmental performance for that specific characteristic under other EU law, like the highest energy class under the Energy Labelling Regulation. The proof must be relevant to the claim you make.
Does a green logo or leaf image count as an environmental claim?
It can. The Commission says purely visual elements on their own are not generic environmental claims, because those need text or speech. But images like leaves, trees or water drops combined with words or logos can create an implicit claim or even act like a sustainability label. Context and consumer perception decide.
Can brand names like 'GreenClean' break the rules?
Yes. The Commission's June 2026 Q&A confirms that brand, company and product names count as commercial practices, even when trademarked. A word like 'green' in a name is not automatically a claim. But if the name makes an average consumer expect an environmental benefit, it is treated as an environmental claim and must follow the rules. Misleading names can even be refused registration as trademarks.
Is 'organic' still allowed as a claim?
For food, yes, under the EU organic rules. Sector-specific EU law takes precedence. Terms for organic food production under Regulation (EU) 2018/848 stay valid when the product complies with those rules. Outside regulated sectors, 'organic' style claims are judged like any other environmental claim.
