Generic environmental claims explained
EmpCo creates the EU's first formal definition of an environmental claim and bans vague green words used without on-the-spot specifics — unless the product holds recognised excellent environmental performance.
EmpCo creates the EU's first formal definition of an "environmental claim" and bans vague green words used without on-the-spot specifics — unless the product sits at the top of a recognised environmental performance scheme.
Definition (new UCPD Article 2(o)). An environmental claim is any voluntary message — text, picture, logo, colour, or even brand/product name — that states or implies a positive or zero environmental impact, less damage than alternatives, or improvement over time. Sweeps in explicit and implicit cues: "EcoClean", green leaf icons, water drops, green/blue palettes used to suggest benefit.
Generic environmental claim (Article 2(p)). A green word with no explanation right next to it. Recital 9 calls out 13 risky terms: "environmentally friendly", "eco-friendly", "eco", "green", "nature's friend", "ecological", "environmentally correct", "climate friendly", "gentle on the environment", "carbon friendly", "energy efficient", "biodegradable", "biobased". The Commission FAQ adds "carbon neutral", "climate neutral", "natural", and "sustainable".
Two narrow paths to use them lawfully:
- Specification on the same medium — paired with a clear, prominent explanation on the same packaging/screen. A QR code is generally not enough.
- Recognised excellent environmental performance — EU Ecolabel, recognised national ISO 14024 Type I ecolabels (Nordic Swan, Blauer Engel, Austrian Ecolabel, NF Environnement), or top class of an EU label such as the Energy Label.
| Risky / non-compliant | Compliant alternative |
|---|---|
| "Eco-friendly bottle" | "Bottle made from 100% recycled PET (excluding cap and label)" |
| "Sustainable cotton T-shirt" | "Made with GOTS-certified organic cotton" + GOTS logo |
| "Green detergent" | "Awarded the EU Ecolabel" + flower logo |
| "Climate-friendly packaging" | "Packaging produced with 100% renewable electricity" |
| "Natural skincare" | "95% ingredients of natural origin (ISO 16128)" |
| "Energy efficient fridge" | "EU Energy Label class A" |
| "Biodegradable wipes" | "Certified industrially compostable to EN 13432" |
Sector exception. Under Regulation (EU) 2018/848 the words "organic", "bio" and "eco" can still be used on certified organic food because the sectoral law takes precedence (UCPD Article 3(4)).
Citations: Directive (EU) 2024/825, Article 1(1)(b) inserting UCPD Article 2(o)–(s); Annex I point 4a; Recital 9.
Recent enforcement (2024–2025). The ACM's case againstH&M's "Conscious Choice" labelling forced the brand to drop the range name and re-engineer the substantiation. Decathlon committed to remove generic "eco-design" badges from product pages absent specific evidence. The UK ASA upheld complaints against SHEIN for unqualified "evoluSHEIN" sustainability messaging (2024). Each case turned on the same point: a green word with no on-the-spot, verifiable qualifier is misleading.
Citations: ACM v. H&M, commitment decision 2022 (follow-up review 2024); ACM v. Decathlon, 2022; ASA rulings, 2024.