New EU rules put pressure on corporate sustainability communications – ”climate neutral” and ”green” may soon be prohibited terms

In September 2026, the EU's Empowering Consumers for the Green Transition Directive comes into force for all companies communicating sustainability to consumers – regardless of size or listing status. The Directive puts a stop to greenwashing and tightens requirements on how sustainability may be communicated, from product claims to climate targets and sustainability labels. 

On 26 March 2024, the EU Directive on Empowering Consumers for the Green Transition (EmpCo, also referred to as the ECGT Directive) entered into force. The Directive aims to protect consumers from misleading environmental claims and to provide them with clearer information about the environmental and climate impact of products. At the same time, it creates a level playing field for companies that genuinely live up to their sustainability commitments and currently compete against actors making misleading environmental claims without consequence. 

The rationale behind the Directive is clear: greenwashing – presenting a product or service as a better environmental choice than it is – is a widespread problem in the European market. According to a European Commission study, 53 percent of all environmental claims in the European market are vague, misleading, or unsubstantiated, and as many as 40 percent lack any basis whatsoever. Meanwhile, 90 percent of EU citizens believe there should be stricter rules governing how environmental impact is calculated and communicated. 

It is against this backdrop that EmpCo was introduced. The Directive forms part of the European Green Deal and amends the EU's existing frameworks on unfair commercial practices and consumer rights. The broader Green Claims Directive, which would have introduced requirements for pre-approval and scientific verification of environmental claims, is currently on hold following political pressure within the EU and has no confirmed timeline. EmpCo is therefore the greenwashing framework that is in force and will begin to apply this autumn. 

The Directive applies to all companies making environmental claims in communications directed at consumers (B2C), regardless of size, sector, or whether the company is publicly listed. Non-European companies selling to consumers in the EU market are also covered. In Sweden, B2B communications are also affected, since the Swedish Marketing Act generally prohibits misleading marketing between businesses as well. Companies that cannot substantiate their environmental claims therefore risk having communications directed at business customers deemed unlawful. 

Sustainability reporting, such as annual sustainability reports prepared in accordance with the Corporate Sustainability Reporting Directive (CSRD), generally falls outside the scope of the Directive, as such reports are typically mandatory and directed at investors rather than constituting commercial communication aimed at consumers. However, if companies draw on information from their sustainability reports in voluntary advertising or marketing directed at consumers, that marketing will be subject to the Directive. 

Misleading environmental claims 

One of the most significant changes concerns what the Directive refers to as general environmental claims. Terms such as ”green”, ”eco-friendly”, ”climate-friendly”, ”ecological”, ”energy-efficient”, and ”bio-based” are prohibited unless they can be linked to recognised, substantiated environmental performance – for example, an approved third-party certification or an official EU requirement. The distinction between a general and a permissible claim is that the permissible claim is specific and verifiable. A claim such as ”100 percent of the energy used to produce this packaging comes from renewable sources” is therefore not covered by the prohibition, whereas ”climate-friendly packaging” is classified as a general claim. 

Whether an environmental claim is permissible ultimately depends on whether the underlying substantiation is specified clearly and visibly in the same medium – that is, in the same advertisement, on the packaging, or in the digital environment. Referring consumers elsewhere for further information is not sufficient; the information must appear directly alongside the claim. Overall impression also matters: colours, imagery, and tone that create a general sense of environmental friendliness may in themselves constitute a general environmental claim, even if the text is neutral. 

The Directive also prohibits claims about an entire product or an entire business when the claim in fact applies only to a part of it. Marketing a product as ”made from recycled materials” implies that the statement applies to the product as a whole. If only the packaging is made from recycled material, the claim is misleading and therefore prohibited. Similarly, a company may not give the impression that its entire operations run on renewable energy if this applies only to certain offices or production facilities. 

It will also become prohibited to claim that a product is ”climate neutral”, ”carbon neutral”, or has ”net zero emissions” if the claim is based on offsetting measures outside the product's own value chain. According to the Directive, such claims create a false impression for consumers – suggesting that the product itself has no climate impact, when in reality emissions are being compensated for elsewhere. Companies that have communicated climate neutrality as a product attribute will therefore need to reassess these messages. The prohibition does not, however, prevent companies from communicating about their investments in climate projects or carbon credits, provided this is done in a non-misleading manner and in compliance with other applicable EU requirements. It should also be noted that the prohibition operates at the product level: overarching claims about a company's climate neutrality are not caught by this specific provision, but may nonetheless be prohibited if considered misleading under the Directive's general rules. 

It is also not permissible to highlight that a product meets requirements that are mandatory under law for all products in the same category. Marketing a product as free from a substance that is already prohibited across the entire product category in the EU constitutes a misleading claim and creates the impression of an advantage that does not in practice exist. 

Stricter requirements on forward-looking environmental claims 

The Directive also tightens requirements on communications relating to future sustainability and climate targets. A company communicating net zero emissions by a specified year, or committing to reduce its climate impact, must be able to substantiate that claim with a detailed and realistic implementation plan. The plan must include measurable and time-bound interim targets, resource allocation and monitoring methodology, and must be publicly available and verifiable. The implementation plan does not need to appear in the same medium as the claim; a reference via a link for further information is sufficient. 

In addition, the Directive provides that the plan should be regularly reviewed by an independent third party with no conflicts of interest and with expertise in environmental matters, and that their conclusions should be made available to consumers. Climate commitments must therefore not only be documented – they should also be externally verified and transparent to avoid the risk of being classified as misleading. This applies to more specific forward-looking statements as well. Communicating that a product will be climate neutral by a specified future date requires that the claim can be substantiated already today. Forward-looking claims about environmental performance that are insufficiently supported will be prohibited under the new Directive. 

New requirements for sustainability labels 

The Directive introduces new requirements for voluntary sustainability labels used to market a product or business by reference to its environmental or social attributes. To be used in consumer communications, a label must either be based on a certification scheme with independent third-party oversight or have been established by a public authority. A certification scheme is understood as a control system open to all operators on transparent and non-discriminatory terms, whose requirements have been developed in consultation with relevant experts and stakeholders, and where compliance is monitored by an independent third party. Self-created labels and symbols without external verification are prohibited. 

There are currently at least 230 different sustainability labels in use across the EU, and a significant number of these do not meet the new requirements. Labels such as the EU Ecolabel and the Nordic Swan Ecolabel (Svanen) satisfy the requirements as Type I environmental labels under ISO 14024 and may continue to be used. Companies using proprietary sustainability symbols or unverified labels in their consumer-facing communications will need to review these. 

When do the rules take effect? 

The rules will begin to apply across the EU on 27 September 2026. In Sweden, however, national implementation is expected to be delayed. The Swedish government inquiry (SOU 2025:124) has been completed, but the Riksdag has yet to adopt the legislation. Under the current proposal, the Swedish legislative amendments are not set to enter into force until 1 January 2027 – three months after the rules have already taken effect in the rest of the EU. For Swedish companies, this means that EU rules will in practice apply from September 2026 regardless of whether Swedish legislation has entered into force, as the Directive will be applied directly in other member states where companies operate or sell products. 

The delayed Swedish implementation has drawn criticism from the business community, which lacks support and guidance on how to interpret and comply with the rules. The concern is that this uncertainty risks placing Swedish companies in a situation where existing marketing, communications, and packaging materials do not meet EU requirements when they come into force in autumn 2026. 

That said, the full Directive is not subject to the Swedish delay. The prohibition rules set out in Annex I of the Directive – the so-called black list – require no new legislation and apply in Sweden from 27 September 2026. This means that the prohibitions on general environmental claims, non-compliant sustainability labels, and offset-based product claims apply with immediate effect. Requirements relating to future environmental performance and irrelevant benefits, which require amendments to the Swedish Marketing Act, will not take effect in Sweden until 1 January 2027.