The regulatory framework governing environmental claims and sustainability-related consumer information has entered a new phase in the European Union.

Directive (EU) 2024/825 on empowering consumers for the green transition amends both the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). Its objective is to strengthen consumer protection against misleading environmental claims, unreliable sustainability labels, planned obsolescence practices and other commercial practices that may prevent consumers from making informed and sustainable purchasing decisions.

In Greece, Directive (EU) 2024/825 was transposed by Law 5317/2026 (Government Gazette A’ 108/10.7.2026), which amended, among other provisions, Greek Consumer Protection Law 2251/1994. The new rules apply from 27 September 2026

The framework concerns business-to-consumer (B2C) commercial practices. Mandatory corporate sustainability disclosures are not, as such, the target of the Directive. However, information originating from such disclosures may become subject to consumer-law scrutiny where it is subsequently reused in advertising, product marketing or other voluntary commercial communications addressed to consumers.

Importantly, Directive 2024/825 should not be confused with the proposed Green Claims Directive. The latter remains, as of the date of this article, a pending legislative proposal and is not currently in force.

1.       What constitutes an environmental claim?

The concept of an environmental claim is deliberately broad.

It may include any non-mandatory message or representation, in any form, which states or implies that a product, product category, brand or trader has a positive or zero impact on the environment, is less damaging to the environment than alternatives, or has improved its environmental impact over time.

Environmental claims are therefore not limited to written statements. They may also arise from images, graphics, labels, product names, trade names, branding or other elements of a commercial presentation. Depending on the overall context, oral statements made by sales personnel may also fall within the relevant consumer-protection rules.

The overall impression conveyed to the average consumer remains important. The use of a colour such as green or blue is not inherently unlawful, but visual elements, wording and presentation taken together may amount to an implied environmental claim. The Greek memorandum accordingly identifies product communications, labels, websites, social media, physical stores and sales staff as key areas requiring review.

2.       Generic environmental claims

The new framework significantly restricts the use of generic environmental claims. Expressions such as “green”, “eco-friendly”, “environmentally friendly”, “biodegradable” or similar broad statements require particular caution. Generic environmental claims may not be used where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim.

This means that businesses should move away from broad, undefined sustainability messaging and towards specific, objectively verifiable statements.

For example, a precise claim such as: “Made from 80% recycled plastic” may be permissible where the statement is accurate and adequately substantiated. Images of leaves, nature, water or similar visual elements can also contribute to an environmental message and must therefore be assessed in the context of the overall presentation. Greenwashing memo

2.1.Carbon-neutral and offsetting claims

One of the most significant changes concerns product-level climate claims based on carbon offsetting. Claims suggesting that a product has a neutral, reduced or positive impact on greenhouse-gas emissions are prohibited where that conclusion is based on the offsetting of emissions, particularly outside the product’s own value chain.

Examples requiring particular caution include:

• “climate-neutral product”;
• “carbon neutral”;
• “CO₂ neutral”;
• “net zero emissions”; and
• similar claims whose asserted climate performance depends on the purchase or use of carbon credits.

The mere acquisition of carbon-offset certificates is therefore not sufficient to justify a product-level “climate neutral” claim.

This prohibition should nevertheless be distinguished from statements based on actual and verifiable reductions in the product’s own emissions footprint or life cycle, which remain subject to the general requirements of accuracy and substantiation. Corporate communications concerning investments in environmental projects or carbon-credit initiatives are also not automatically prohibited but remain subject to the general rules against misleading commercial practices. Greenwashing memo

2.2.Claims about part of a product versus the whole product

Businesses should also ensure that a positive environmental characteristic of one element of a product is not presented as a characteristic of the product as a whole.

For example:

• describing an entire garment as “100% recycled” where only its packaging is made from recycled material may be prohibited;
• describing an entire retail business as “green” because one limited product line has certain environmental characteristics may also be problematic;
• by contrast, a specific statement such as “packaging made from 100% recycled cardboard” clearly identifies the element to which the claim relates.

Precision as to the scope of the claim is therefore essential. Greenwashing memo

2.3.Future environmental performance

Forward-looking environmental claims (for example, commitments to become climate neutral by 2030) are also subject to enhanced scrutiny.

Such claims should be supported by clear, objective, publicly available and verifiable commitments contained in a detailed and realistic implementation plan. The plan should include measurable and time-bound targets, relevant implementation elements and appropriate resources, and should be subject to regular verification by an independent third-party expert, whose findings are made available to consumers. Greenwashing memo

Broad aspirational statements unsupported by a credible implementation framework are therefore increasingly difficult to sustain.

2.4.Legal requirements cannot be marketed as a special benefit

A trader may not present compliance with a legal requirement applicable to all products in the relevant category as though it were a distinctive advantage of its own product.

A claim such as “REACH compliant”, for example, may be problematic where compliance with REACH is already legally required for all relevant products.

The underlying principle is straightforward: businesses should not create a competitive marketing advantage from merely complying with obligations already imposed on everyone operating in the market. Greenwashing memo

3.       Sustainability labels: certification matters

The rules on sustainability labels are particularly important for retailers and private-label businesses.

Displaying a sustainability label which is neither based on an appropriate certification scheme nor established by a public authority is now included in the list of commercial practices prohibited in all circumstances.

Self-created “green” labels developed solely by a company’s marketing department therefore require immediate review.

Private certification schemes may continue to be used where they meet the Directive’s requirements, including requirements concerning independent third-party verification, transparent and publicly accessible criteria, independent monitoring and fair conditions for participation.

Accordingly, businesses should not assume that the mere fact that a label is widely recognised or privately certified automatically resolves the issue. The characteristics of the specific certification scheme must be assessed. Greenwashing memo

3.1.Environmental and social comparisons

Where a trader compares products on the basis of environmental or social characteristics, consumers must be given appropriate information concerning:

• the method of comparison;
• the products and suppliers being compared; and
• the measures used to keep the information up to date.

Statements such as “the greenest product on the market” therefore carry a substantial evidentiary burden.

The revised framework also strengthens protection against misleading claims relating to social characteristics, including working conditions, human rights, equal treatment, equal opportunities and certain social or ethical commitments. Greenwashing memo Greenwashing memo

3.2.Durability, software updates and planned obsolescence

Directive 2024/825 goes beyond greenwashing. It also introduces new rules aimed at commercial practices associated with premature obsolescence. These are particularly relevant to retailers of electronics, smart devices and other products containing digital elements.

The new rules address, among other matters:

• withholding information that a software update will negatively affect a product’s functionality;
• presenting a software update as necessary where it merely enhances functionality;
• marketing goods containing features designed to limit durability where the trader has relevant information about those features;
• making false claims about durability;
• falsely claiming that a product is repairable;
• encouraging consumers to replace consumables earlier than technically necessary; and
• withholding or misrepresenting information concerning the effect of third-party consumables, spare parts or accessories on functionality. Greenwashing memo

3.3.New pre-contractual information requirements

The new framework also expands the information that may have to be provided to consumers before they enter into a contract.

Depending on the product and transaction, this may concern:

• the legal guarantee of conformity;
• commercial guarantees of durability;
• the period during which software updates will be provided;
• repairability information;
• availability and estimated cost of spare parts;
• repair and maintenance instructions; and
• repair restrictions.

Repairability scores are relevant where harmonised EU requirements have been introduced for the relevant product category. They should therefore not be regarded as a general requirement applicable to every consumer product. Greenwashing memo

For distance sales, traders should also review their checkout process and the pre-contractual information provided through their online interfaces.

3.4.The harmonised EU notice and durability label

The European Commission has adopted Implementing Regulation (EU) 2025/1960, setting out the design and content of the harmonised notice concerning the legal guarantee of conformity and the harmonised label relating to a commercial guarantee of durability. The Regulation applies from 27 September 2026.

The harmonised notice is designed to remind consumers of their legal guarantee rights and includes a QR code directing them to further information.

A separate harmonised label is used where a producer offers, at no additional cost, a commercial guarantee of durability covering the entire product for a period exceeding two years and provides the relevant information to the trader.

The label itself is not the commercial guarantee; it is the standardised mechanism used to inform consumers of the existence and duration of a qualifying guarantee. Greenwashing memo

Retailers should therefore review both their physical points of sale and their online interfaces in light of the new information requirements and the applicable national rules.

3.5.Greece: the rules are now in force

Greece completed the transposition of Directive 2024/825 through Law 5317/2026. The amendments affect, among other matters, pre-contractual consumer information, misleading acts and omissions, environmental claims and the expanded list of commercial practices prohibited in all circumstances.

The relevant rules have applied since 27 September 2026.

For businesses operating in Greece, the issue is therefore no longer one of preparing for future legislation. Retailers should now review their consumer-facing practices against Greek Consumer Protection Law 2251/1994, as amended, together with the relevant EU framework.

3.6.What about existing stock?

The treatment of products already manufactured, ordered or present in the distribution chain has been one of the most important practical issues for retailers.

On 22 September 2026, the European Commission published updated Questions & Answers on the application of Directive 2024/825. The Commission also refers to a Common Understanding developed by the national authorities of the Consumer Protection Cooperation (CPC) Network concerning “old stock” situations

There is no general grandfathering rule and no blanket exemption allowing non-compliant environmental claims or sustainability labels to remain in use indefinitely simply because products were manufactured before 27 September 2026.

However, the enforcement approach may take account of genuine transitional difficulties on a case-by-case basis. Factors may include packaging cycles, existing inventory volumes, prior production orders, supply-chain dependencies, product lifetimes and the technical feasibility of corrective measures.

Businesses are expected to demonstrate timely, good-faith, reasonable and proportionate compliance efforts. Depending on the circumstances, corrective measures may include covering or correcting claims, adding appropriate information or withdrawing problematic marketing material.

This makes documenting compliance efforts particularly important for businesses managing significant legacy stock. Greenwashing memo

4.       Practical steps for retailers

Retailers should consider taking the following steps without delay:

1. Audit environmental and sustainability claims.

Review websites, product pages, social media, advertising, packaging, private-label products, in-store materials and oral sales practices.

2. Review sustainability labels.

Identify self-created labels and confirm that any certification schemes being relied upon satisfy the applicable requirements.

3. Reassess climate claims.

Pay particular attention to “carbon neutral”, “climate neutral” and similar product-level claims relying on carbon offsetting.

4. Engage with suppliers.

Create processes for obtaining the information and substantiation required for environmental claims, software-update periods, repairability and spare parts.

5. Update supplier agreements.

Consider contractual provisions requiring suppliers to provide accurate information and supporting evidence and allocating responsibility for non-compliant claims.

6. Train customer-facing staff.

Environmental claims made orally by sales personnel can also create legal exposure.

7. Review e-commerce interfaces.

Ensure that required pre-contractual information, guarantees and other consumer information are displayed in the appropriate manner.

8. Create substantiation files.

Businesses should be in a position to demonstrate the factual basis for each environmental claim.

9. Document old-stock remediation.

Maintain records of existing inventory, production and order dates, supplier communications and corrective measures considered or implemented. Greenwashing memo

5.       A compliance challenge and a strategic opportunity

The new rules significantly raise the standard for environmental marketing in the EU.

For retailers, compliance will require closer cooperation between legal, marketing, procurement, sustainability, e-commerce and supply-chain teams. Generic sustainability messaging will increasingly need to give way to precise, verifiable and appropriately scoped claims.

At the same time, businesses that develop robust substantiation processes and transparent consumer communications may strengthen consumer trust and differentiate themselves in a market in which environmental claims are increasingly subject to regulatory and public scrutiny.

The immediate priority is clear: environmental claims, sustainability labels, consumer information and legacy stock should now be reviewed against the new framework, and businesses should be able to document not only what they claim, but why they are entitled to make the claim.