Sustainability labels
Only sustainability labels established by a public authority or based on a third-party-audited certification scheme can lawfully appear in B2C marketing. Self-made eco-badges are out.
Since 27 September 2026, only sustainability labels established by a public authority or based on a third-party-audited certification scheme can lawfully appear in B2C marketing. Self-made eco-badges are out.
The rule (Annex I, 2a). Displaying a sustainability label not based on a certification scheme or not established by public authorities is prohibited in all circumstances.
Sustainability label (UCPD Article 2(q)). Any voluntary trust mark, quality mark, seal, badge or equivalent — public or private — that sets apart a product, process or business by reference to environmental or social characteristics. Mandatory labels (EU Energy Label) are excluded.
Certification scheme (Article 2(r)) — must meet all five:
- Open under transparent, fair, non-discriminatory terms.
- Requirements developed in consultation with experts and stakeholders.
- Procedures for non-compliance with withdrawal/suspension.
- Compliance monitored by an independent third party (e.g. ISO 17065 accredited).
- Terms publicly available.
Per the Commission FAQ, the scheme owner and the trader can be the same entity, but the third-party verifier must be a separate legal entity from both. Labels established only by non-EU government authorities are NOT covered on their own.
Compliant examples: EU Ecolabel ("the flower"); Nordic Swan; Blauer Engel; Austrian Ecolabel; Dutch Milieukeur; French NF Environnement; FSC; PEFC; GOTS; Fairtrade; EU Organic logo; energy label classes.
Probably non-compliant: a retailer's own "Conscious Choice" or "Eco Edit" badge; brand-specific "Sustainability Pledge" seals with no published criteria; schemes where the verifier is a sister company of the scheme owner.
Citations: Directive (EU) 2024/825, Article 1(1)(b) inserting UCPD Article 2(q)–(r); Annex I point 2a; Recital 7.
Recent developments (2024–2026). Self-declared brand seals are being retired across the market: Adidas wound down its "Primegreen" badge in 2024 and H&M's "Conscious Choice" hangtag was dropped after the ACM commitment. Commission guidance on sustainability labels (under EmpCo Recitals 17–20), announced for Q4 2025, is meant to set the operational test for the five certification-scheme criteria. Recognised third-party schemes — EU Ecolabel, Nordic Swan, Blauer Engel, FSC, MSC, GOTS, Cradle to Cradle, Fairtrade — remain the safe harbour.
Citations: ACM commitment decision on H&M, 2022; EmpCo Recitals 17–20; Commission work programme 2025.