Deepdive EmpCo

The amended unfair-practices blacklist adds specific prohibitions for an unqualified generic environmental claim without relevant recognised excellent environmental performance; a whole-product or whole-business claim based on only one aspect or activity; a sustainability label that is neither based on a certification scheme nor established by a public authority; and a product greenhouse-gas impact claim based on offsetting.

What this changes in practice: Review the exact words, images, label, subject and medium together. Evidence for one attribute does not support a claim about the whole product or business, and an offset certificate does not make the prohibited product-impact claim permissible.

The general misleading-practices rules expressly address future environmental-performance claims and comparisons of environmental, social or circularity features. Future claims require the specified plan and independent expert verification; comparative services must disclose the comparison method, products and suppliers, and update measures.

What this changes in practice: A target date alone is insufficient. Retain the public plan, measurable milestones, resources, verification findings and comparison method, and state what is still missing.

The Directive also adds rules about durability, early obsolescence, software updates, consumables, spare parts and repairability. These changes extend beyond environmental advertising wording.

What this changes in practice: Product, ecommerce and after-sales information need review alongside campaign copy. Statements or omissions about lifespan, updates, repair and replacement can be relevant even where no green phrase appears.

The amended Consumer Rights Directive adds pre-contract information about the legal guarantee, qualifying commercial durability guarantees, reparability scores where applicable, spare parts and repair instructions where the producer makes that information available, and software-update periods.

What this changes in practice: Map which facts the producer has supplied and where consumers see them before purchase. Do not infer a durability guarantee, reparability score, spare-parts commitment or update period when it has not been established.

Transposition 27 Mar 2026

application 27 Sep 2026

Commission FAQ (Nov 2025, updated 18 May 2026) is interpretive, non-binding

Point 4a — generic environmental claimCloseDictionary termEnvironmental ClaimA statement, symbol or representation that communicates or implies that a product, service, organisation or activity has a particular environmental characteristic, performance or effect.Read the full definition → without demonstrated recognised excellent environmental performance relevant to the claim (recital 9 examples: "environmentally friendly", "eco-friendly", "green", "nature's friend", "ecological", "climate friendly", "biodegradableCloseDictionary termBiodegradableBiodegradable means a material can be broken down by biological processes, but the claim is incomplete without conditions, timeframe and environment.Read the full definition →", "biobased", "carbon-neutral", "climate neutral", "carbon compensated", "carbon positive").

Point 4b — environmental claimCloseDictionary termEnvironmental ClaimA statement, symbol or representation that communicates or implies that a product, service, organisation or activity has a particular environmental characteristic, performance or effect.Read the full definition → about the entire product or business when it concerns only one aspect/activity.

Point 4c — claiming, based on offsetting of GHG emissions, that a product has neutral/reduced/positive environmental impact (recital 12 examples: "climate neutral", "CO2 neutral certified", "carbon positive", "climate net zeroCloseDictionary termNet zeroA state in which anthropogenic greenhouse-gas emissions are balanced by anthropogenic removals over a specified period and within a defined boundary.Read the full definition →", "climate compensated", "reduced climate impact", "limited CO2 footprint"); permitted only if based on the product's actual lifecycle impact in its own value chainCloseDictionary termValue ChainThe full sequence of activities that create and deliver value — the analytical unit for footprints, due diligence and accountability.Read the full definition →.

Point 10a — presenting legal requirements common to all products as a distinctive feature of the trader's offer.

Modernisation Directive penalties — widespread-infringement fines of at least 4% of turnover.

Harmonised label for commercial guarantees of durabilityCloseDictionary termDurabilityDurability is the extent to which a claimed climate or sustainability outcome is expected to last without being reversed, weakened or materially undermined over the relevant time horizon.Read the full definition → >2 years

pre-contractual reparability information