Picture a business owner reading their own website footer in the summer of 2026. It says the company is eco-friendly, sustainable, and carbon neutral. Now ask them to prove it: the measured numbers, the certification, the evidence an enforcement body would accept. Most could not produce a single document. That gap has always existed. What is new is that, from a fixed date this autumn, the gap is no longer just embarrassing. In the EU, it is unlawful.
TL;DR
- From 27 September 2026, EU law bans “eco-friendly,” “green,” and similar claims without proof of recognised excellent environmental performance.
- The binding rule is Directive (EU) 2024/825. The Green Claims Directive is a separate, stalled proposal.
- Offset-based “carbon neutral” and “net zero” claims are banned outright in consumer marketing.
- Website copy, footers, and “carbon-neutral hosting” badges all count as commercial claims in scope.
- A defensible claim needs a measured number, verifiable renewable hosting, and a methodology you could hand to a regulator.
The internet runs on green claims nobody checks
Open the footer of almost any small business website and you will find a sustainability claim. Eco-friendly. Green. Environmentally conscious. Carbon neutral. These words appear on agency homepages, product pages, and email signatures across thousands of sites, usually with nothing behind them: no measurement, no certification, nothing to check.
For years this was tolerated. A vague green claim was, at worst, a reputational risk. If a journalist or a sharp customer pushed on it, the company might face an awkward conversation, but rarely a consequence. The claim cost nothing to make and almost nothing to leave unproven, so it spread. Sustainability became a default adjective, applied the way “premium” or “trusted” get applied, as tone rather than fact.
We have always found this uncomfortable, and not only on principle. A market where everyone claims to be green and nobody has to prove it is a market where the businesses doing the actual work get no credit for it. The claims become noise, and noise drowns signal.
The rule changed, and not the way the headlines said
In 2025, a lot of coverage announced that EU green-claims regulation was collapsing. That coverage was half right, and the half it got wrong is the half that matters.
Here is the accurate version. There are two separate instruments, and they are easy to confuse.
The first is the Green Claims Directive, a proposal known by its file number COM(2023) 166. It would have required businesses to substantiate every environmental claim with scientific evidence and have it verified by an independent third party before publication. In June 2025 the European Commission announced its intention to withdraw this proposal, and its future is genuinely uncertain. This is the directive the headlines were reporting on.
The second is the Empowering Consumers for the Green Transition Directive, Directive (EU) 2024/825. This one is not a proposal. It was adopted in early 2024, it amends existing EU consumer-protection law, and it carries the ban on vague and misleading green claims. Member states must write it into national law by 27 March 2026, and it applies from 27 September 2026.
So the substantiation-and-verification machinery is on hold. The ban on unprovable green marketing is law, with a date attached. Treating “the Green Claims Directive is dead” as an all-clear is the single most expensive misreading a business could make this year.
What the Empowering Consumers Directive actually bans
The directive does three things that bear directly on marketing copy.
First, it bans generic environmental claims. If you describe your business or product as “eco-friendly,” “green,” “environmentally friendly,” or “climate friendly,” and you cannot demonstrate recognised excellent environmental performance, the claim is prohibited. Vague is the problem. Specific and evidenced is the way through.
Second, it bans carbon-neutral claims based on offsetting. Terms like “carbon neutral,” “climate neutral,” and “net zero” are not allowed in consumer marketing when the basis is buying offsets rather than cutting emissions in your own value chain (your operations and supply chain). A business can advertise a reduced climate impact only if it has actually reduced that impact. Offsets do not count toward the claim.
Third, it restricts sustainability labels. A label or badge may only be used if it rests on a certification scheme with independent third-party monitoring, or is established by a public authority. Self-issued badges are out.
Who is in scope is broad. The rules apply to commercial communication aimed at EU consumers, which includes any website a consumer in the EU can read. Penalties are set by each member state, and the framework allows fines reaching up to 4 percent of annual turnover in coordinated cross-border cases. The exact figure depends on where enforcement happens, but the direction is clear: this is consumer-protection law, with consumer-protection teeth.
Why this lands on websites specifically
It is easy to read “consumer marketing” and picture packaging and television advertising. For most businesses, the exposure is closer to home. It is on the website.
Website copy, landing pages, email footers, product descriptions, and the small green badges in the corner of a checkout page are all commercial communications. They are exactly the surface the directive governs. A claim does not have to be printed on a physical product to be in scope.
Two ordinary examples show how this works. A service business has a homepage line reading “we are a sustainable, eco-friendly company.” There is no certification behind it and no measurement, so under the new rules it is a generic claim that cannot stand. Second, a digital agency advertises “carbon-neutral websites” on the strength of an offsetting arrangement. That is precisely the offset-based neutrality claim the directive prohibits.
The second example carries a complication worth naming. When an agency makes a sustainability claim on a client’s behalf, on the client’s website, the claim sits on the client’s domain. If it fails the test, the business hosting the claim is the one exposed, not only the agency that wrote it. Plenty of businesses are carrying claims they did not write and have never checked.
What the Green Claims Directive would have added
The stalled proposal still tells you where the direction of travel points.
The Green Claims Directive would have moved from banning bad claims to actively policing good ones. Every explicit environmental claim would have required substantiation grounded in widely recognised scientific evidence, assessed across a product’s life cycle, with a verified methodology for any comparative claim such as “greener than the alternative.” An accredited independent verifier would have had to check the claim before it was published, not after a complaint.
That regime is on hold, and may not arrive in its proposed form. But notice what the Empowering Consumers Directive already does without it. The hard work, removing claims that cannot be evidenced, is done. The verification layer would have raised the bar for the claims that remain. A business that reads the withdrawal as permission to keep its unprovable copy has misunderstood which directive was doing the work.
What a defensible approach looks like
Strip away the regulation and a simple test remains. Could you hand an enforcement body your working? If the honest answer is no, the claim is not ready to publish.
A claim you can defend has four properties. It rests on a measured number, the actual carbon output of the site, produced by a tool rather than estimation. It runs on hosting you can verify is powered by renewable energy, which is a different and stronger thing than hosting that has been offset to nominal neutrality. It comes with a quantified outcome, a before and an after, rather than an adjective. And it carries a methodology you can cite, so a regulator can see how the number was reached.
None of this is exotic. It is ordinary measurement applied to a domain where measurement has been rare. When we rebuilt our own site, we treated it as a client project and measured it the same way, precisely so that every claim on it could be backed with a number. The point is not that this is hard. The point is that most green marketing has simply never been asked to do it. From this autumn, in the EU, it will be.
The practical next step
If you do one thing after reading this, make it a measurement, not a rewrite. Run your live website through a public carbon-measurement tool to see what it actually emits per visit. Then read your hosting provider’s energy documentation and look for the specific claim: is the electricity renewable at source, or is “neutral” being carried by offsets? Those two facts are the start of knowing what you can honestly say.
From there, the job is an inventory: every environmental word on the site, sorted into what you can prove, what is generic, and what rests on offsets. The first you keep. The second and third you fix or remove before 27 September 2026.
Start with what you can actually measure
Measure your site and list every environmental claim on it before 27 September 2026. If you would like a second pair of eyes on what has to change, book a short audit conversation or drop us an email. The point is not to sell you certainty. It is that the deadline is real.
Frequently asked questions
Is the EU Green Claims Directive still happening?
The standalone Green Claims Directive, proposal COM(2023) 166, is on hold. The Commission announced its intention to withdraw it in June 2025 and its future is uncertain. But a separate instrument, the Empowering Consumers Directive (EU 2024/825), already bans vague green claims and applies from 27 September 2026.
Does this apply to my business if I am based outside the EU?
It applies to commercial communication aimed at consumers in the EU. If your website is accessible to EU consumers and markets to them, the claims on it are in scope regardless of where your business is registered.
Can I still say my product is “carbon neutral”?
Not if the basis is offsetting. From September 2026 the directive bans carbon-neutral, climate-neutral, and net-zero claims in consumer marketing when they rest on offsets rather than actual emissions reductions in your own value chain.
What is Directive (EU) 2024/825?
It is the Empowering Consumers for the Green Transition Directive. It amends EU consumer-protection law to ban generic environmental claims, offset-based neutrality claims, and untrustworthy sustainability labels. It applies across member states from 27 September 2026.
What counts as a defensible green claim?
One backed by a measured number, verifiable renewable-powered hosting or operations, a quantified outcome, and a methodology you could show to a regulator. Specific and evidenced, not generic.