Directive (EU) 2024/825: what changes for corporate merchandise on 27 September 2026

August 13, 2026

From 27 September 2026, EU rules on environmental claims tighten, with no transition period for existing stock. What the directive prohibits, whether it reaches a B2B purchase, and what a merchandise buyer can usefully do before the date.

This article presents Directive (EU) 2024/825 for information purposes. It does not constitute legal advice.

On 27 September 2026, Directive (EU) 2024/825 begins to apply across the European Union. It changes what companies may say about the environmental qualities of what they sell, and it does so without a transition period for existing stock.

If your company orders branded merchandise, the directive is not a rule about that purchase. It is a rule about what you then print on the product, publish about it and put on the packaging your own customers see. That distinction is where most of the practical consequence sits.

What the directive is, precisely

Directive (EU) 2024/825 was adopted on 28 February 2024 and amends two existing pieces of EU consumer law, the Unfair Commercial Practices Directive and the Consumer Rights Directive. It is commonly called the Empowering Consumers for the Green Transition Directive, shortened to EmpCo or ECGT. The full text is published on EUR-Lex (new tab).

Member States were required to transpose it into national law by 27 March 2026, with the rules applying from 27 September 2026.

Because it is a directive rather than a regulation, the detail of application varies by Member State. National transposition may go further than the minimum in some countries. That is worth checking for each market you communicate in.

What it prohibits

The EU Retail Platform summary (new tab) sets out the core of it. Four prohibitions matter most for merchandise.

Generic environmental claims without substantiation. Terms such as environmentally friendly, eco friendly or biodegradable may not be used without demonstrated and recognised environmental performance relevant to the claim. The claim and its justification have to appear together.

Sustainability labels that are not backed by a certification scheme. The directive prohibits displaying sustainability labels that do not rest on a certification scheme or that were not established by a public authority. The recital text on EUR-Lex is specific about what a qualifying scheme requires: publicly available terms, minimum conditions of transparency and credibility, and objective monitoring of compliance by a third party whose competence and independence from both the scheme owner and the trader are assured.

In plain terms, a label a company created for its own products does not qualify, however carefully it was designed.

Product level carbon neutrality claims based on offsetting. Claims that a product is climate neutral, CO2 neutral or carbon compensated, where the basis is offsetting rather than reduction, are prohibited at product level.

Unverified forward looking claims. Environmental commitments about future performance require an implementation plan and independent verification.

Does it apply to B2B purchases?

Not directly. The directive governs business to consumer commercial practices. A supply relationship between two companies falls outside its scope.

That is the accurate statement, and it is where most summaries stop. Two qualifications are worth adding, because both have practical weight.

The claims travel. Sustainability claims are lifecycle based, and upstream information about composition, manufacturing and supply chain is routinely carried into consumer facing communication. If your marketing team wants to describe a branded product as sustainable in a campaign, somebody has to hold the evidence for that claim. In most cases the evidence sits with the supplier. The obligation is yours; the documentation is theirs.

The standard is spreading beyond its formal scope. Analysis by Eversheds Sutherland (new tab) notes that EU case law supports the directive’s requirements being used to define what counts as misleading advertising in a business to business context as well. This is an interpretive point rather than a settled rule, and it is one to raise with your legal team rather than to assume either way.

What about the Green Claims Directive?

The Green Claims Directive was a separate proposal, and it has not been adopted. Any supplier presenting it to you as an approaching legal deadline is mistaken.

The sequence is worth knowing because the confusion is widespread. The Commission proposed the Green Claims Directive in March 2023. On 20 June 2025 it announced its intention to withdraw the proposal, following a call from the European People’s Party and the cancellation of the final trilogue session. The European Economic and Social Committee (new tab) has published its account of the withdrawal and the reasoning behind it.

The status is not entirely closed. Latham & Watkins (new tab) observes that the position is more nuanced than the headlines suggested, and that the proposal remained subject to adoption at the time of the announcement. Parliamentary committee chairs have signalled a readiness to resume negotiations.

What is not in doubt is that Directive 2024/825 was adopted, is law, and applies from 27 September 2026 regardless of what happens to the other proposal.

Two dates and what sits between them

Adoption, transposition, application. Only the last one changes what you may print.
Date	What happens
28 February 2024	Directive (EU) 2024/825 adopted
6 March 2024	Published in the Official Journal
27 March 2026	Deadline for transposition into national law
27 September 2026	Rules begin to apply across the EU

There is no sell through window. Stock produced before the application date is not exempt from the rules that apply after it. A campaign printed in August 2026 and running in October 2026 is subject to the new framework.

What a merchandise buyer can do about it now

The useful work is documentary rather than legal, and most of it is a matter of asking earlier than you otherwise would.

Audit the wording you already use. Catalogue descriptions, intranet pages, packaging inserts and campaign copy. Any environmental adjective standing on its own is a candidate for rewriting. Registered trade marks and product names are not exempt from the rules.
Check that every label you display rests on a third party scheme. A label created by a supplier for its own range does not meet the standard, however credible the underlying practice may be.
Ask suppliers for certificate numbers rather than logos, at quotation stage. A number can be verified with the issuing body. A logo cannot be verified at all.
Look at how long a supplier takes to produce documentation. This is the most informative question you can ask, and it is rarely asked. A supplier who sends a certificate the same day already had it. A supplier who takes three weeks is assembling something.
Treat any carbon neutrality claim on a product as a live risk. If the basis is offsetting rather than reduction, it falls squarely within the prohibition.

Where this leaves the merchandise market

The directive raises the cost of an unsubstantiated claim and leaves the cost of a documented one unchanged. That is the whole of its commercial effect, and it favours suppliers who already hold the paperwork.

For buyers, the practical shift is that a supplier’s ability to produce evidence quickly becomes a selection criterion rather than an afterthought. It is a reasonable thing to ask about before an order rather than after one.

On the limits of this article. It summarises publicly available regulatory information and does not constitute legal advice. National transposition varies, Commission guidance continues to be updated, and interpretation will develop through enforcement. If environmental claims appear in your commercial communication, have the text reviewed by qualified counsel.

Frequently asked questions

When does Directive (EU) 2024/825 apply?

The rules apply from 27 September 2026. Member States were required to transpose the directive into national law by 27 March 2026.

Does the directive apply to B2B transactions?

The directive governs business to consumer commercial practices. It does not directly regulate business to business supply, though claims sourced from suppliers frequently end up in consumer facing communication, where the rules do apply.

Is the word “sustainable” banned?

Generic environmental claims are prohibited where they are not substantiated by recognised environmental performance relevant to the claim, presented on the same medium. A specified and substantiated claim remains permitted.

Was the Green Claims Directive adopted?

No. The Commission announced its intention to withdraw the proposal on 20 June 2025. Directive (EU) 2024/825 is a separate instrument that was adopted and applies from 27 September 2026.

Can we still use a supplier’s own sustainability label?

Only if it rests on a certification scheme meeting the directive’s transparency and third party monitoring conditions, or was established by a public authority. A self created label does not qualify.

Is there a grace period for existing stock?

No sell through window is provided. Claims made after the application date are subject to the rules regardless of when the product was manufactured.