Once you have to be specific, you find out what you can actually prove, and where the work still needs doing.
Anti-greenwashing
How to apply the ACM guidelines for sustainability claims
Five sustainability claims keep coming up
Since September 2026, some of the most familiar sustainability claims like “green”, “eco-friendly”, “climate friendly” are not allowed anymore due to the new regulation (ECGT/EMPCO).
The new rules come from EmpCo, the EU directive on Empowering Consumers for the Green Transition (you may also see it called ECGT). It adds a short list of practices that count as unfair in all circumstances. A regulator doesn’t have to prove that anyone was actually misled. In the claims checks and EmpCo trainings we run, the same five claims keep coming up. Here they are, plus what you can say instead.
1. “Green”, “eco-friendly”, “climate friendly”
Broad words that suggest your product is good for the planet are banned, unless you can show recognised excellent environmental performance. In practice that means the EU Ecolabel, an officially recognised ISO 14024 type I ecolabel, or top performance under other EU law. Few products qualify.
The catch is in the definition. A claim is generic when the specification isn’t given clearly and prominently on the same medium. A “green” pack with the explanation two clicks away on your website still counts as generic.
“Sustainable” and “responsible” are even harder. They also say something about social impact, so an ecolabel alone doesn’t cover them. Instead: say exactly what you did. “Box made from 80% recycled cardboard” tells customers more than “eco packaging” ever did.
2.”Climate neutral” thanks to offsetting
Calling a product “climate neutral”, “CO2 compensated” or “climate positive” because you offset its emissions is banned outright. How good the offset projects are doesn’t change that.
The ban covers any claim that a product has a neutral, reduced or positive climate impact when that claim rests on offsetting. The logic: buying credits elsewhere doesn’t change the footprint of the product in the customer’s hands.
Instead: talk about real reductions in your own value chain, with a number and a baseline. Still funding climate projects? You can say so. Just frame it as a contribution, not as cancelling out your footprint.
3. A sustainability label you made yourself
A badge, seal or logo you designed in-house is banned, unless it’s based on a certification scheme or set up by a public authority. Think of an “Our Green Choice” sticker or a “Planet Approved” icon on your webshop. This applies to social labels too.
A certification scheme has to tick four boxes. It’s open to every company on fair terms. Its requirements are developed with experts and stakeholders. It can withdraw the label when someone doesn’t comply. And an independent third party checks compliance. ACM puts it plainly: private labels without independent checks are no longer permitted.
Instead: use an existing label that’s independently checked. Or drop the badge and explain the specific improvement in words.
4. A whole-product claim based on one part
Presenting your whole product or business as better for the environment, when the improvement covers only one part, is banned. Think “made with recycled materials” on a shoe where only the laces are recycled.
This one sneaks in through headlines, product names and brand names. Under EmpCo, those count as claims too. The packaging is recycled, but the front of the pack reads as if the whole product is.
Instead: name the part. “Laces made from recycled polyester” is specific, true and still worth telling.
5. Selling the legal minimum as a plus
Presenting something the law requires of every product in your category as if it sets you apart is banned. Think “CFC-free” on a fridge, or “phosphate-free” on a laundry detergent sold in the EU.
It’s tempting, because it’s true. But it suggests you went the extra mile when you met the bare minimum, just like everyone else.
Instead: highlight only what goes beyond the law. If a legal requirement matters to your customers, mention it neutrally and make clear it’s the standard for all products.
So what can you still say?
Plenty. EmpCo doesn’t ban talking about sustainability. It bans being vague about it. Specific claims you can prove are still very welcome.
Before a claim goes out to consumers, run it past these questions:
- Is it specific? Does it say what, how much, and compared to what?
- Is that specification on the same medium as the claim: the same pack, ad or page?
- Does it cover the whole product, or just one part?
- Can you prove it today, with evidence you could hand over tomorrow?
- Does it go beyond what the law already requires?
- Is it about the future, like “net zero by 2040”? Then you need a detailed, realistic plan with measurable, time-bound targets, regularly checked by an independent expert.
- One more thing: there’s no transition period. Claims already on your website, packaging and shelves count too. Regulators may take demonstrably old stock into account, but only if you can show you started adjusting early.
