"Eco-friendly." "Green." "Sustainable." "Climate neutral." These words built billion-dollar marketing campaigns. Now, under EU regulation, many of them are effectively banned — or at least heavily restricted — when used without specific, verifiable substantiation.
The EU Green Claims Directive and the Empowering Consumers Directive (2024/825) together create the strictest regime for environmental marketing language anywhere in the world. Here's exactly what you can't say anymore, what you can say instead, and how to stay on the right side of the law.
Outright Banned Terms and Practices
The Empowering Consumers Directive, which member states must transpose by March 2026, explicitly bans certain practices regardless of context:
Generic Environmental Claims Without Substantiation
You cannot use any of these terms as standalone claims unless accompanied by specific, verifiable environmental performance data recognized under official certification schemes or set by public authorities:
- "Environmentally friendly" / "Eco-friendly"
- "Green" (in environmental context)
- "Nature's friend"
- "Ecological"
- "Environmentally correct"
- "Climate friendly"
- "Gentle on the environment"
- "Energy conscious"
- "Biodegradable" (without qualification)
- "Bio-based" (without percentage and certification)
The key phrase is "as standalone claims." Writing "eco-friendly" on your product label with nothing else? Banned. Writing "This product's packaging is made from 90% post-consumer recycled material, reducing its carbon footprint by 45% compared to virgin plastic (verified by [certifier])"? That's substantiated and specific — potentially compliant.
Unqualified Carbon Neutrality Claims
This is the big one that's catching companies off guard. You cannot claim:
- "Carbon neutral"
- "Carbon positive"
- "Climate neutral"
- "Climate positive"
- "Net zero" (for products)
- "CO2 reduced" (without baseline and methodology)
- "Carbon compensated"
...when these claims are based exclusively or primarily on carbon offsetting. The regulation doesn't ban offsets entirely — it bans using offsets as the primary basis for neutrality claims. Actual emission reductions must come first. See our detailed breakdown of carbon neutral claim rules.
Sustainability Labels Without Certification
Self-awarded eco-labels and sustainability badges are banned. Specifically prohibited:
- Environmental labels not based on third-party certification or established by public authorities
- New national environmental labelling schemes (unless approved at EU level)
- Labels that don't meet minimum transparency and governance standards
Restricted Terms: Allowed With Conditions
Many terms aren't outright banned but come with strict conditions. Use them wrong and you're in violation.
"Recycled" / "Recyclable"
Conditions:
- "Recycled" must specify the percentage and source (pre-consumer vs. post-consumer)
- "Recyclable" must mean the product is actually collected and recycled in practice — not just theoretically recyclable. If local recycling infrastructure doesn't handle it, you can't call it recyclable for consumers in that market
- Must not use the Möbius loop (recycling symbol) in a way that implies the entire product is recyclable when only part of it is
"Biodegradable" / "Compostable"
Conditions:
- Must specify the conditions under which biodegradation occurs (industrial composting, home composting, marine environment, etc.)
- Must specify the timeframe
- "Compostable" must comply with EN 13432 or equivalent standards
- Must not create the impression that littering is acceptable
"Natural" / "Organic"
Conditions:
- "Organic" for food must comply with EU Organic Regulation (2018/848)
- "Natural" must not imply environmental benefit unless substantiated — a product being "natural" doesn't automatically mean it's better for the environment
- "Made with natural ingredients" must specify which ingredients and what percentage
"Sustainable"
Conditions:
- Must relate to specific, measurable aspects of sustainability
- Must not suggest overall sustainability when only one dimension is addressed
- Must be substantiated with life-cycle data
- "Sustainable" as a standalone brand descriptor is essentially unusable without comprehensive substantiation across environmental, social, and economic dimensions
"Reduced [environmental impact]"
Conditions:
- Must specify the baseline (reduced compared to what?)
- Must specify the reduction amount and methodology
- Must use comparable data and methods
- Must be recent — comparing to a 10-year-old baseline is misleading if industry standards have moved
Terms That Are Still Safe — With Best Practices
Not everything is restricted. These approaches remain viable:
Specific Certified Claims
- "EU Ecolabel certified" — backed by official EU scheme
- "FSC certified" — recognized third-party forestry certification
- "Fairtrade certified" — established certification with clear standards
- "Energy Star rated" — government-backed energy efficiency label
The pattern: if a recognized, independently governed certification body backs your claim, you're on solid ground.
Quantified Environmental Statements
- "This product's manufacturing uses 30% less water than our 2023 baseline, measured by [methodology]"
- "Packaging contains 75% post-consumer recycled content, certified by [certifier]"
- "Our operations reduced Scope 1 and 2 emissions by 22% between 2023 and 2025, verified by [auditor]"
Specificity is your friend. Numbers, methodologies, third-party verification, and clear scope make claims defensible.
Industry-Specific Restrictions
Fashion and Textiles
Additional scrutiny applies to the fashion industry given its track record. Terms like "conscious collection," "responsible fashion," and "sustainable style" are effectively unusable without comprehensive life-cycle substantiation. The fashion greenwashing guide covers this in detail.
Food and Beverages
"Natural," "organic," and "farm-fresh" are heavily regulated under existing food labelling law on top of the ECGT. See food industry green claims for the full breakdown.
Packaging
Packaging claims are under particular scrutiny because they're visible at point of sale. "Sustainable packaging" as a standalone claim is banned; specific material and recycling claims need substantiation. Our packaging claims guide details the rules.
How to Transition Your Marketing Language
The Specificity Framework
For every environmental claim, apply this formula:
[Specific metric] + [Methodology/standard] + [Verification] + [Scope]
Before: "Our products are eco-friendly."
After: "This product's packaging is made from 85% post-consumer recycled ocean-bound plastic, reducing packaging carbon emissions by 40% compared to virgin HDPE (verified by [certifier], 2025 LCA)."
Before: "Climate neutral company."
After: "Our operations (Scope 1 & 2) reduced absolute emissions by 35% vs. 2020 baseline. Remaining emissions addressed through [specific offset program with quality standard]. Full methodology at [URL]."
Quick-Reference Decision Tree
- Is the claim generic ("green," "eco-friendly")? → Remove or replace with specific language
- Does it rely on offsets for neutrality? → Restructure to lead with actual reductions
- Can you point to a specific, recent data source? → If no, remove
- Has it been third-party verified? → If no, pursue verification before publishing
- Does it cover the full life cycle or just one aspect? → If partial, clearly state the scope
Enforcement Timeline and What Happens Next
The Empowering Consumers Directive requires transposition by March 2026. The ECGT's transposition period follows. But don't wait for the deadline — regulators in France, the Netherlands, Germany, and Denmark are already enforcing against greenwashing using existing consumer protection law.
Run a scan of your website with GreenClaims Scanner to identify every banned or restricted term in your current marketing. You might be surprised how many you find. Most companies discover 20-50 problematic terms across their web presence — and that's before checking packaging, social media, and advertising.
The shift from vague green marketing to substantiated environmental communication is the biggest change in marketing regulation in decades. Companies that adapt their language now will build genuine credibility. Those that don't will build legal bills.
Need a structured approach? Start with our 2026 green marketing compliance checklist.