As of 27 September 2026, the new provisions introduced by Directive (EU) 2024/825 are applicable. The Directive aims to strengthen consumer protection in the context of the green transition and to combat misleading environmental commercial practices.
On 22 September 2026, the European Commission published a Questions & Answers document on the Directive, providing guidance on the application of the new rules concerning green claims, climate-related claims, sustainability labels and products already placed on the market.
The FAQs represent guidance provided by the Commission services and do not constitute a legally binding interpretation of the legislation.
One of the most relevant aspects concerns environmental claims used in commercial communications.
Terms such as “green”, “eco-friendly”, “climate friendly”, “biodegradable” or “carbon friendly” may qualify as generic environmental claims. Their use is subject to the conditions established by the new regulatory framework and, in particular, to the possibility of demonstrating recognised superior environmental performance.
The assessment does not concern solely the wording displayed on product packaging or used in advertising.
Images, colours, symbols, leaves, water drops and other graphic elements may also convey an environmental message to consumers, depending on the context and the overall perception of the communication.
For companies, this means that it is important to assess not only individual claims, but the overall environmental message associated with a product.
Particular attention is given to claims concerning climate neutrality and greenhouse gas emissions.
The FAQs clarify the prohibition of certain product-related claims, such as “climate neutral”, “carbon neutral” or “carbon compensated”, where the claim is based on the offsetting of greenhouse gas emissions outside the product’s value chain.
Subject to the conditions established by the legislation, communications based on actual and verifiable emission reductions and on the environmental impact of the product throughout its life cycle may instead be used.
The new regulatory framework also addresses claims concerning future environmental performance.
Where a company communicates environmental objectives that are to be achieved in the future, such commitments must be clear, objective, publicly available and verifiable and must be incorporated into a detailed and realistic implementation plan.
The legislation also provides for regular monitoring by an independent third-party expert, under the conditions established by the applicable regulatory framework.
The new provisions also address sustainability labels and certification schemes.Sustainability labels that are not established by a public authority must be based on a certification scheme compliant with the requirements set out in the Directive. It is therefore particularly important for companies to verify the legal and certification basis of any environmental label, mark or symbol used in the commercial communication of a product.
An important clarification for companies concerns products and packaging that have already been manufactured.
According to the Commission’s FAQs, the new provisions apply from 27 September 2026 also to products that have already been manufactured, ordered, distributed or are already on retail shelves, where the associated environmental communications are not compliant with the new requirements.
Depending on the specific circumstances, possible corrective measures may include the use of adhesive labels to correct or cover non-compliant statements, or the provision of additional information at the point of sale.
The European Consumer Protection Cooperation (CPC) network has also addressed the issue of products already on the market, establishing a common approach to “old stock” situations and providing for a proportionate assessment of the transitional difficulties actually encountered by businesses.
In Italy, the Ministry of Enterprises and Made in Italy (MIMIT), through its Circular of 27 August 2026, provided guidance on the implementation of the Directive through Legislative Decree No. 30 of 20 February 2026. The guidance indicates an indicative six-month sell-through period for products already on the market, to be assessed according to the specific product category and the circumstances of each case.
Directive (EU) 2024/825 does not concern environmental claims alone.The Commission’s FAQs also address the new provisions relating to durability, reparability and guarantees, including the repairability score and harmonised information tools intended for consumers. As of 27 September 2026, the harmonised notice concerning the legal guarantee of conformity is also relevant and must be displayed prominently, including through online sales channels.
What should companies verify?
In light of the new requirements, companies should carry out a coordinated review of:
The objective is to ensure that environmental claims are accurate, substantiated and consistent with the actual characteristics of the product, while reducing the risk that commercial communications may be considered misleading or otherwise constitute unfair commercial practices.
Source:
https://eur-lex.europa.eu/legal-content/IT/ALL/?uri=celex%3A32024L0825&utm_source=chatgpt.com.