Choose a country, see what the retained source record says, then use that context in your claim or company review.
Source dates and limits
The Directive gives the EU starting point. A country record shows the national source or proposal found, the dates established by that source and the important questions still open.
It cannot decide whether a particular claim can be used. That depends on the exact wording, product or service, audience, date and supporting evidence.
Legal status, source-review readiness and notification evidence are separate. An identified or notified measure does not establish complete transposition or how a rule applies to a claim.
Scroll horizontally to see adoption, publication, commencement, application and source-check details.
Published national EmpCo reference, with unresolved dates stated explicitly
The signed Federal Law Gazette PDF of BGBl. I Nr. 58/2026 (issued 28 July 2026) amends the UWG 1984 and lists CELEX 32024L0825. § 44(16) as amended sets 27 September 2026 for §§ 1, 2, 7a and the new annex items on claims, and limits civil claims about goods for three years to goods placed on the market after 27 September 2026. No new legal event was found; the full signed PDF, unavailable on 10 September, was read in this check, so the older-goods arrangement in § 44(16) is now confirmed from the official text.
This check did not look for amendments after BGBl. I Nr. 58/2026. The meaning of the three-year civil-claims limit for a particular product is not determined by this source check.
The EU national-measure index records a FOD Economie law transposing Directive (EU) 2024/825, Belgian Official Gazette C-2026/005912 of 4 August 2026, pages 41689-41694, with entry into force 27 September 2026.
The Gazette PDF was not read in this check either. The exact older-goods exception therefore still rests on the August dossier.
Enacted instrument identifiedAct amending and supplementing the Consumer Protection Act, State Gazette No. 87/2026
2026-09-10
2026-09-24
Not established by this check
2026-09-27
Official text examinedEvidence and limits
The Act amending and supplementing the Consumer Protection Act was adopted by the 52nd National Assembly on 10 September 2026. It was promulgated by Presidential Decree No. 305 of 17 September 2026 and published in Държавен вестник issue 87 of 24 September 2026 (extraordinary). § 73(4) adds Directive (EU) 2024/825 to the transposed directives. § 83 brings the act into force on publication, except listed provisions (including §§ 1–2, § 6, §§ 16–19 and § 73 items 56–66), which take effect on 27 September 2026. Since 10 September the bill has been adopted at second reading, promulgated and published in the State Gazette, with a stated 27 September 2026 start for the listed provisions.
The provisions still need expert review to map each listed paragraph (for example §§ 16–19 and the new definitions in § 73) to the Directive's articles. This check does not decide how the law applies to any particular claim.
Bulgaria: parliamentary bill record 52-602-01-12 — Plenary second reading 2026-09-10; L_Act_dv_iss 87, L_Act_dv_year 2026; final title 'Закон за изменение и допълнение на Закона за защита на потребителите'
Bulgaria: published act text in State Gazette — Decree No. 305 of 17.09.2026; issue 87 of 24.9.2026, p. 2; § 73(4) (new § 13a item 15 citing Directive 2024/825); § 83 (27 September 2026)
Enacted instrument identifiedConsumer Protection Act amendment, NN 59/2026-728
Not established by this check
2026-06-09
Not established by this check
2026-09-27
Official text examinedEvidence and limits
Croatia's amendment to the Consumer Protection Act (NN 59/2026, published 9 June 2026) expressly lists Directive (EU) 2024/825 in Article 1. Article 66 sets 27 September 2026 as the start date for Articles 16–18 and certain other listed provisions, separate from the law's general start date.
This settles the date stated in the published amendment. It does not determine whether a particular report statement is a consumer-facing commercial claim or how the law applies to it.
The EU national-measure index records Law N.122(I)/2026, the Consumer Protection (Amendment) (No. 3) Law of 2026, in Cyprus Gazette issue 5093 of 17 July 2026, pages 562-568, with entry into force 27 September 2026. This matches the retained Articles 10 and 11 findings. No legal change since 10 September, but the status moves from 'Source evidence incomplete' to 'Review required': the official EU record now confirms the law's identity, Gazette issue and 27 September 2026 date.
The Cyprus Gazette record still could not be opened (access blocked), so the provision text rests on the August document. No check for later amendments was possible.
The Chamber's history for print 53 (amendment to Act 634/1992 on consumer protection and to the Civil Code), with status as at 15 October 2026, records that the third reading took place on 14 October 2026 at the 34th sitting. It records that the bill was passed by resolution no. 304. The page says the passed text is still being prepared for publication and for the next legislative steps. Since 10 September the Chamber of Deputies has passed the bill on third reading (14 October 2026). The Senate, presidential and Collection of Laws stages remain.
Resolution 304 and the passed wording are not yet published on psp.cz. The record does not establish Senate consideration, signature, publication in the Sbírka zákonů or a national start date.
Czechia: print 53 history — Third reading 14 October 2026, 34th sitting, passed (resolution no. 304); page status 15 October 2026
Law No. 558 of 27 May 2025 (Lovtidende A, published 28 May 2025) amends the Marketing Practices Act and related acts to implement Directive (EU) 2024/825. Section 4(1) sets 1 July 2025 for the law in general, and Section 4(2) sets 27 September 2026 for Sections 1 and 2.
The published amendment has been examined. This check does not set out the full amended Marketing Practices Act or how it applies to a particular communication.
Enacted instrument identifiedConsumer Protection Act amendment, RT I, 03.07.2026, 19
Not established by this check
Not established by this check
Not established by this check
Not established by this check
Official text examinedEvidence and limits
The Act amending the Consumer Protection Act and the Explosive Substances Act (RT I, 03.07.2026, 19) adds the claim definitions and practices to §§ 2 and 16 and names Directive (EU) 2024/825. Under § 3, § 1 points 1–8, 15 and 16 enter into force on 27 September 2026. New § 77² allows a clear correction mark for one year from that date on goods and packaging produced before it, if the mark is not misleading. No new legal event was found; the official text, not retrievable on 10 September, was obtained from Riigi Teataja's own data service, so the correction-mark arrangement is now confirmed from the official text.
The Riigi Teataja web page renders only with JavaScript; the text was read from the same register's XML endpoint. This check did not look for later amendments or set out how § 77² applies to particular goods.
Enacted instrument identifiedDecree 664/2026 and retained related measures
Not established by this check
Not established by this check
Not established by this check
Not established by this check
Official text examinedEvidence and limits
Government Decree 664/2026 on unfair commercial practices towards consumers (issued 2 July 2026, published 6 July 2026) sets out the new claim and label practices in § 2(1), items 4 and 29–31. Under § 4 it enters into force on 27 September 2026, while items 4, 29 and 30 apply only from 27 March 2027 to marketing on goods or packaging placed on the market before that date. No new legal event was found; the decree's full text, unavailable on 10 September, was read through Finlex open data, so the older-goods arrangement is now confirmed from the official text. It covers items 4, 29 and 30 and does not cover the offset-based claim in item 31.
This check read the decree only and did not check for a separate amending act to the Consumer Protection Act or any correction notice. Application to a particular claim is not determined here.
Proposal identifiedParliamentary proposal recorded in the Senate and National Assembly dossiers
Not established by this check
Not established by this check
Not established by this check
Not established by this check
Official record examinedEvidence and limits
The EU national-measure index lists only three French entries for EmpCo, notified on 17 July 2026: existing provisions (Consumer Code Article L121-2, Environment Code Articles L541-9-1 and R541-230) dating from 2020-2024. It lists no new French law. A DGCCRF page dated 23 June 2026 describes the transposing bill (projet de loi DDADUE) as not adopted, with the National Assembly to examine it in the autumn.
The Senate and National Assembly dossiers could not be opened in this check (access blocked), so the Assembly stage after 4 September is not confirmed. No JORF publication of a transposing law and no national application date were found.
The Federal Law Gazette publishes the Drittes Gesetz zur Änderung des Gesetzes gegen den unlauteren Wettbewerb of 12 February 2026 (BGBl. 2026 I Nr. 43, issued 19 February 2026), whose footnote names Directive (EU) 2024/825. Article 2(1) sets 27 September 2026 as the start date, and Article 2(2) gives Article 1 No. 2(c) alone a start date of 19 June 2026.
The official consolidated UWG lists a later amendment (Article 6 of the law of 12 May 2026, BGBl. 2026 I Nr. 139), and this check did not review what it changed. How the amended UWG applies to a particular claim is not determined by this source check.
Enacted instrument identifiedLaws 5317/2026 and 5326/2026
Not established by this check
Not established by this check
Not established by this check
Not established by this check
Official record examinedEvidence and limits
The EU national-measure index records Law 5317/2026 (ΦΕΚ Α' 108, 10 July 2026), whose title lists the incorporation of Directive (EU) 2024/825, alongside Laws 2251/1994, 4933/2022 and 5019/2023. Greece declared these notifications complete on 31 July 2026.
The Gazette text of Law 5317/2026 was not opened, so the timing provisions and any later amendment were not freshly examined.
Act XCIV of 2025 was promulgated on 16 December 2025. Section 12 inserts Section 54/A, which applies the new provisions to products manufactured or produced after 27 September 2026. Section 21(3) brings subtitle 2 and Annex 1 into force on 27 September 2026, and Section 22 links them to Directive (EU) 2024/825.
This confirms the wording of the production-date condition, not its application to services, every product category or any individual environmental claim.
Hungary: Act XCIV of 2025 — Section 12 inserting Section 54/A; Section 21(3); Section 22; promulgation note 16 December 2025
S.I. No. 124/2026, the European Union (Empowering Consumers for the Green Transition) Regulations 2026 (notice in Iris Oifigiúil of 3 April 2026), come into operation on 27 September 2026 under Regulation 1(2). Regulation 3(a) updates the Directive definition in the Consumer Protection Act 2007, Regulation 5 inserts sections 44B–44C, and Regulation 8 adds the generic-claim, whole-product, offset-based and sustainability-label practices to section 55(1). No new legal event was found; the full official text, not retrieved on 10 September, was read in this check.
This check did not review the instrument's 'Amendments' listing for later changes. The EU definitions that apply through Regulation 3, and their use for a particular claim, are not determined here.
The Gazzetta Ufficiale publishes Legislative Decree No. 30 of 20 February 2026 (Serie Generale No. 56, 9 March 2026), titled as implementing Directive (EU) 2024/825. The record states entry into force on 24 March 2026, and Article 2 states that the decree’s provisions apply from 27 September 2026. No legal change since 10 September; the official Gazzetta text, not reachable by automated retrieval, was read in this check.
The Consumer Code amendments in Article 1 have not been mapped point by point to the Directive in this check, and Italian-language editorial review remains open.
Enacted instrument identifiedAmendments recorded as OP 2025/92.3
2025-04-30
2025-05-15
2026-09-27
2026-09-27
Official text examinedEvidence and limits
The law 'Grozījumi Negodīgas komercprakses aizlieguma likumā' (adopted 30 April 2025, proclaimed 15 May 2025, Latvijas Vēstnesis No. 92, 15.05.2025, OP 2025/92.3) adds definitions of environmental claim, sustainability label and certification scheme, together with claim practices including offset-based climate claims, and names Directive (EU) 2024/825. Its closing clause states that the law enters into force on 27 September 2026. The status moved from 'Source evidence incomplete' to 'Review required' because the full signed official publication was read; the law itself has not changed since September.
This check covers the amending law as published. It does not set out the full consolidated law, the enforcement framework or any later amendment, and it adds no arrangement for older goods because none was found in this text.
Enacted instrument identifiedActs XV-577 and XV-576
2025-11-20
2025-12-01
2026-09-27
Not established by this check
Official record examinedEvidence and limits
The official legal-acts register (TAR) records Law No. XV-577 amending Articles 2, 5, 6 and 7 and the Annex of the Law on the Prohibition of Unfair Commercial Practices to Consumers (No. X-1409), adopted by the Seimas on 20 November 2025 and registered on 1 December 2025 (TAR No. 2025-20386). Its Article 6 sets entry into force on 27 September 2026.
The register showed the heading of Article 6 but not the operative text, and its EU-relation field lists no EU act. The register shows a bot-verification page to automated browsers, so the amended provisions were not read, and XV-576 was not re-checked.
Lithuania: TAR record of Law XV-577 — Act number, adoption 20 Nov 2025, TAR No. 2025-20386 of 1 Dec 2025; Article 6 heading (entry into force 27 Sep 2026)
Enacted instrument identifiedLaw of 9 June 2026, Mémorial A 283
Not established by this check
Not established by this check
2026-09-27
2026-09-27
Official text examinedEvidence and limits
Legilux publishes the Law of 9 June 2026 amending the Consumer Code to transpose Directive (EU) 2024/825 (parliamentary document 8648). Article 6 inserts points 28) to 39) into Article L. 122-4, and Article 10 states that the law enters into force on 27 September 2026. No legal change since 10 September; the official Legilux text, not reachable by automated retrieval, was read in this check.
Each inserted point has not been mapped to the Directive’s Annex I in this check, and no later amendment was searched for.
Instrument not established by this checkHistorical incomplete-notification notice recorded; present status not inferred.
Not established by this check
Not established by this check
Not established by this check
Not established by this check
Official record examinedEvidence and limits
The EU national-measure index holds no Maltese measure for EmpCo as of its latest update (9 October 2026). The Commission's 28 May 2026 notice named Malta for incomplete notification.
Absence from the EU index shows no notification, not that Malta has no law. No Maltese Act or Legal Notice transposing the Directive was found on legislation.mt or in searches.
Enacted instrument identifiedStb. 2026, 152 and commencement decree Stb. 2026, 204
Not established by this check
2026-07-15
2026-07-16
Not established by this check
Official text examinedEvidence and limits
The Implementatiewet richtlijn betere duurzaamheidsinformatie voor consumenten (law of 27 May 2026, Stb. 2026, 152, issued 24 June 2026) leaves commencement to royal decree in Article III. The decree of 9 July 2026 (Stb. 2026, 204, issued 15 July 2026) brings it into force the day after issue, i.e. 16 July 2026.
How the national start date of 16 July relates to the EU application date of 27 September 2026 is a separate legal question that this check does not answer. This check did not look for later Staatsblad amendments.
The Sejm process record for bill 2799 shows that the Senate made no amendments on 24 September 2026 and that the act went to the President for signature the same day. The Sejm text sent to the Senate specifies 27 September 2027 in Article 3. The Dziennik Ustaw index, which lists items up to 14 October 2026, shows no publication of this act. Since 10 September the act has passed the Senate without amendments and gone to the President. It has not yet appeared in Dziennik Ustaw.
No presidential signature, referral or publication in Dziennik Ustaw was found, so there is no published national text or confirmed commencement date. The 27 September 2027 date comes from the parliamentary text, not from a promulgated law.
Instrument not established by this checkHistorical incomplete-notification notice recorded; present status not inferred.
Not established by this check
Not established by this check
Not established by this check
Not established by this check
Official record examinedEvidence and limits
The EU national-measure index holds no Portuguese measure for EmpCo. The Council of Ministers communiqué of 8 October 2026 contains no item on consumer protection or Directive (EU) 2024/825.
The Diário da República record for Decreto-Lei 57/2008 needs JavaScript and could not be read, so a recent amendment cannot be ruled out from the national gazette itself. Earlier Council of Ministers communiqués were not all reviewed.
Latest source check incomplete — the official source could not be fully retrieved. Treat this record as needing another check.
Evidence and limits
On 10 September the official portal's text of OUG 18/2026 was examined. That text contained the definitions and claim provisions, with entry into force on 27 March 2026 and Article IV(2) setting application from 27 September 2026. The portal could not be opened in this check.
legislatie.just.ro returned empty replies or protocol errors and WebFetch was blocked, so the September reading could not be re-checked. The Monitorul Oficial issue reference and any parliamentary law adopting the ordinance are still not established from an immutable official artifact.
Act No. 310/2025 Coll. amends Consumer Protection Act 108/2024. It was adopted on 21 October 2025 and promulgated on 19 November 2025. Article V gives different provisions different start dates and lists the relevant Article I points in the group taking effect on 27 September 2026.
Slov-Lex labels its HTML informational and identifies the PDF as the legally binding version. This check did not verify that PDF or decide how the law applies to a particular claim.
Proposal identifiedDraft ZVPot-1A, EVA 2024-2180-0033
Not established by this check
Not established by this check
Not established by this check
Not established by this check
Official record examinedEvidence and limits
The government page still shows draft ZVPot-1A (EVA 2024-2180-0033) at the stage 'V medresorsko usklajevanje in na SVZ', dated 3 July 2026. The government's 2026 indicative legislative plan lists ZVPot-1A as transposing Directive 2024/825, with urgent procedure, government consideration by 30 September 2026 and National Assembly adoption by 31 December 2026.
The plan's dates are targets, not recorded events. No government adoption, National Assembly decision or Uradni list publication was found.
Proposal identifiedPreliminary Sustainable Consumption Bill
Not established by this check
Not established by this check
Not established by this check
Not established by this check
Official record examinedEvidence and limits
The Ministry's public-information text is still the 'Anteproyecto de Ley de Consumo Sostenible', which states it transposes Directive (EU) 2024/825. The BOE consolidated Consumer Code (Real Decreto Legislativo 1/2007) was last updated on 2 March 2026, and the EU national-measure index holds no Spanish measure for EmpCo.
No Council of Ministers adoption, Cortes bill or BOE publication was found. The Ministry consultation page from the previous check could not be reopened (access blocked).
The government record for SOU 2025:124 (published 19 January 2026; consultation 2 February 2026) still lists no Council on Legislation referral and no government bill, and the inquiry's proposed start date remains 1 January 2027. A search of the Riksdag open-data register on 15 October 2026 returned no bill citing Directive (EU) 2024/825 or the sustainable-consumption proposal.
1 January 2027 is a proposed date, not an enacted one. The absence of a bill on these registers on 15 October does not exclude a referral that has not yet been indexed.
Statuses describe research readiness. They are not scores or legislative conclusions.
Netherlands
Research status: Review required
In plain English
What we found
The Implementatiewet richtlijn betere duurzaamheidsinformatie voor consumenten (law of 27 May 2026, Stb. 2026, 152, issued 24 June 2026) leaves commencement to royal decree in Article III. The decree of 9 July 2026 (Stb. 2026, 204, issued 15 July 2026) brings it into force the day after issue, i.e. 16 July 2026.
Why it matters
The recorded national start date differs from the EU application timetable, so neither should be chosen without resolving that relationship.
What to check next
How the national start date of 16 July relates to the EU application date of 27 September 2026 is a separate legal question that this check does not answer. This check did not look for later Staatsblad amendments.
Sources and check date
Checked 2026-10-15. Official text examined. The finding is limited to the cited evidence.
The implementing Act changes Book 6 of the Dutch Civil Code. Its environmental-claim definition concerns commercial communications, including words, pictures, labels and names. A statement in a sustainability report is therefore not automatically a prohibited advertisement: its use and audience matter.
Article 6:193g separates four practices: labels without a certification scheme or public-authority basis (ab); general environmental claims without relevant recognised excellent performance (ac); whole-product or whole-business claims supported only for one aspect (ad); and product climate claims based on emissions offsetting (ae). These are distinct provisions, not one blanket ban on discussing sustainability.
Future-performance claims have a separate route, Article 6:193c(2)(d): public, verifiable commitments in a realistic plan, measurable deadlines, supporting resources and regular independent verification. Article 6:193a supplies definitions. The report links these provisions for review; it does not decide that a particular statement meets their legal conditions.
The national commencement decree was published on 15 July 2026. Its sole article says the implementing Act enters into force the following day, giving 16 July. That is the date produced by the decree's wording, not a date inferred from a press report.
ACM's current guidance page separately says the new consumer-facing sustainability-claim rules apply from 27 September 2026 and identifies ACM as the responsible regulator. The national commencement document and the regulator's application guidance should both be visible; neither should silently overwrite the other.
For communications spanning those dates, preserve when the wording was used and which provision is under consideration. This report does not infer that every new prohibition was enforceable in July, or that all earlier consumer-protection rules were suspended until September.
Older packaging is a transition question, not a general exemption
ACM's 1 July 2026 explanation addresses existing stock carrying claims or labels that may not meet the new rules. It describes the European consumer-authorities' common approach: businesses are expected to work towards compliance, while authorities may take genuine transition difficulties into account when supervising and enforcing.
The explanation refers to demonstrable old stock and demonstrable efforts to comply promptly. It does not announce an unrestricted right to keep using any claim or a universal sell-through deadline. It also says the existing general rules on sustainability claims remain relevant.
For a packaging review, useful supporting material includes stock records, production or packaging dates and evidence of corrective work. These are suggested review materials—not a promise of an exemption or an exhaustive list of statutory documents.
ACM: explanation concerning old stock — 1 July 2026; paragraphs on transition difficulties, demonstrated stock and enforcement. Source checked: 2026-09-10.
Who acts, and what a consumer complaint can lead to
ACM is the Netherlands Authority for Consumers and Markets. Its consumer-sales explanation distinguishes misleading information, aggressive selling and other unfair practices. Information can mislead because it is incorrect, because its presentation gives the wrong impression, or because important facts are hidden. Sustainability wording is not outside this general framework.
ACM explains that unfair practices can lead to fines and that consumers may seek to undo an affected contract and claim damages. Those possibilities are not an automatic outcome for every disputed environmental statement; this report does not assign a fine, compensation amount or legal liability.
ACM ConsuWijzer explains the consumer route: retain evidence of the misleading sale, approach the seller and seek resolution. Its guidance distinguishes undoing a purchase because of misleading conduct from ordinary cooling-off rights. Reporting a concern, proving misleading conduct and obtaining an individual remedy are different steps.
Reading a coffee-company report alongside Dutch consumer material
ACM announced increased attention to sustainability claims in coffee and cocoa on 14 August 2025. Its explanation notes that wording can mix environmental and social meanings, making it unclear which benefit is being claimed. This is sector context, not a finding about Nespresso or the supplied report.
For the Nespresso demonstration, the review question is how an exact report statement connects to an actual consumer communication. A report extract alone does not establish the packaging wording, Dutch webpage, audience or sales context. Keep the original passage and page reference alongside any separately supplied consumer-facing example.
Separate the claimed benefit from the evidence supporting it: which product or activity, which period and which environmental or social aspect? Record any gap as missing case information, not proof that the business lacks evidence. The demonstration currently supplies retained review context; selecting Netherlands does not activate a national compliance decision.
ACM warns that its published sustainability-claims guide reflects the position in 2023 and may now be outdated. Its practical themes remain a useful reading aid: precise wording, factual support, fair comparisons, measurable ambitions and intelligible labels. They must not replace the new legislation.
This chapter set brings together the published implementing Act, its commencement decree and regulator explanations accessed on 10 September 2026. It covers the named sources and dates rather than a complete consolidation of Dutch law. The chapter sources show which document supports each subject and which checks remain open.
August research archive — this detail records the earlier evidence and review position. The dated source finding above takes precedence only for the points it expressly confirms.
Retained country research date: . This is a record date, not a fresh verification date.
National instrument and research position
Retained chain: Staatsblad 2026, 152 and commencement instrument 2026, 204. Both official PDFs and hashes are recorded.
Recorded provisions and claim coverage
Stb. 2026, 152 Article I(D) supplies BW 6:193g(ac), generic claims, and BW 6:193g(ae), offset-based product-GHG claims.
Dates and transition questions
Stb. 2026, 204 commences the Act the day after its 15 July issue date: mechanically 16 July 2026.
The relationship between that national commencement and the Directive's 27 September application instruction remains a legal-review hold. Neither is automatically an admitted rule date.
Country-specific distinctions
A mechanically calculated date is metadata, not resolution of the national/EU timing issue.
Evidence to gather for review — not a statement of legal duties
For a later claim review: retain the exact wording, full presentation, intended audience, communication date and product or business scope. These are review inputs, not a statement that the report alone proves compliance.
Retain both artifacts and the exact claim locator; obtain the reviewed timing interpretation before assigning national application.
Unresolved evidence and review gates
Dutch editorial/legal timing review remains held. A raw consolidated Whc artifact and hash are separately required before penalty metadata is used.
Current consolidated text, source-language editorial review and claim-specific scope remain separate checks. Country rules, penalties and enforcement outcomes require a claim-specific review.
Shared EU framework · not a national compliance result
Consumer-protection checks explained
This chapter explains the EU framework behind the country research. It is included once in the complete report; it does not mean each country's implementing law has been verified for every issue.
This concerns consumer-facing commercial communications. Sustainability reporting is not automatically covered; reusing report statements in consumer advertising can change that.
The explanations describe the shared EU framework, not verified national implementation or a decision on a particular claim. Commission-services explanations are non-binding.
The questions below are suggested review inputs, not additional legal duties or a checklist that guarantees compliance. Check the selected country's evidence, applicable dates and actual communication separately.
Sustainability labels
The EU rule requires a sustainability label to rest on a qualifying certification scheme or be established by a public authority. A self-designed badge is not proof of independent certification.
Questions for the evidence review
Is this a voluntary environmental or social badge, or a legally required label?
Was it established by a public authority, or does a qualifying third-party certification scheme support it?
Are scheme rules public and access transparent, fair and non-discriminatory?
Were experts and stakeholders consulted on requirements, and are suspension or withdrawal procedures defined?
Is monitoring objective, with the verifier's competence and independence from both scheme owner and trader established?
What does the certificate actually cover?
EU pinpoint: Article 1(1)(b), Article 1(4) and Annex point (1): UCPD Article 2(q)–(r) and Annex I point 2a. Source checked 2026-09-10.
Broad environmental language
The EU blacklist restricts generic environmental claims unless the trader can demonstrate recognised excellent environmental performance relevant to the claim. A specific, prominently explained claim is different from an unexplained broad promise, but still needs truthful support.
Questions for the evidence review
What exactly does the wording promise, and is any specification clear and prominent on the same medium?
For a generic claim, is the relevant performance supported by the EU Ecolabel, an officially recognised EN ISO 14024 type I scheme, or top performance under applicable EU law?
Does that recognised performance actually cover the claimed benefit, rather than an unrelated characteristic?
EU pinpoint: Article 1(1)(b), Article 1(4) and Annex point (2): UCPD Article 2(p), 2(s) and Annex I point 4a. Source checked 2026-09-10.
A part is not the whole
The EU blacklist prohibits presenting a benefit limited to one feature or activity as a benefit of the whole product or business. Better packaging, for example, does not establish that everything about the product is environmentally better.
Questions for the evidence review
Does the evidence concern packaging, ingredients, one site or the entire business?
Is that boundary clear beside the claim?
EU pinpoint: Article 1(4) and Annex point (2): UCPD Annex I point 4b; recital 11. Source checked 2026-09-10.
Product climate claims based on offsets
The EU blacklist prohibits claiming that a product has a neutral, reduced or positive greenhouse-gas impact based on offsetting. That differs from evidence of reductions within the product's own lifecycle.
Questions for the evidence review
Is the statement about a product or an investment?
Which part of the claimed reduction comes from offsets?
EU pinpoint: Article 1(4) and Annex point (2): UCPD Annex I point 4c; recital 12. Source checked 2026-09-10.
Promises about future performance
Future environmental promises require public, verifiable commitments, measurable time-bound targets, a realistic implementation plan and independent regular verification. The misleading-practice assessment remains case-specific; ambition alone does not supply that support.
Questions for the evidence review
Is this environmental promise still future-facing on the communication date?
Are commitments clear, objective, public and verifiable in a detailed, realistic plan?
Where are measurable time-bound targets, resources and other elements needed to deliver the plan?
Who independently verifies the plan regularly, and can consumers access their findings?
Could the presentation change a consumer's purchasing decision?
Environmental, social and circularity comparison services must explain their method, products, suppliers and updating arrangements. Missing or unclear information requires a case-specific assessment of its effect on consumers' decisions.
Questions for the evidence review
Are like-for-like products and boundaries compared?
Environmental, social and circularity claims must not mislead
Environmental and social features, durability, repairability and recyclability are explicitly included among product characteristics assessed for misleading claims. False information or a deceptive overall presentation can matter even if an individual statement is literally true. This is a case-specific consumer-decision test, not an automatic ban on these subjects.
Questions for the evidence review
What would a consumer understand about the product's environmental, social or circularity performance?
Do evidence, boundaries and qualifications support that overall impression?
Could a misleading impression change a purchasing decision?
EU pinpoint: Article 1(2)(a): UCPD Article 6(1)(b), read with Article 6(1); recitals 2–3. Source checked 2026-09-10.
Does the advertised benefit actually belong to this offer?
Advertising an irrelevant benefit that comes from no feature of the product or business is subject to the case-specific misleading-practice test. A statement need not be a meaningful advantage merely because it sounds positive. Assess its context and effect on the consumer's decision.
Questions for the evidence review
Which actual product or business feature produces this benefit?
Is the claimed absence or advantage meaningful for this type of offer?
Could the presentation influence a purchasing decision the consumer would otherwise not make?
Do not present a legal minimum as a special advantage
The EU blacklist prohibits presenting a legal requirement applying to every product in the relevant category on the EU market as a distinctive feature of your offer. This is not a blanket ban on accurately stating legal compliance. The exact category, requirement, market coverage and presentation must be established.
Questions for the evidence review
Which law requires this feature, for which product category and from what date?
Does the requirement cover all products in that category on the EU market, including imports?
Does the wording imply your offer is distinctive because it meets that requirement?
Is the communication a required disclosure, a neutral statement, or a claimed competitive advantage?
EU pinpoint: Article 1(4) and Annex point (3): UCPD Annex I point 10a; recital 15. Source checked 2026-09-10.
Explain an update's negative effects
The EU blacklist prohibits withholding that a software update will harm the functioning of goods with digital elements or the use of digital content or services. The check concerns an update's negative effect, not a ban on updating software.
Questions for the evidence review
Will this update negatively affect operation or use?
What testing establishes the effect, and how is that information communicated to consumers?
EU pinpoint: Article 1(4) and Annex point (4): UCPD Annex I point 23d; recitals 16–17. Source checked 2026-09-10.
Do not describe an optional enhancement as necessary
The EU blacklist prohibits presenting an update as necessary when it only improves functionality features. Distinguish an optional enhancement from an update needed to keep the product in conformity, including security updates.
Questions for the evidence review
Does the update only enhance features, or is it needed for conformity or security?
Do prompts and release notes make that distinction clear?
EU pinpoint: Article 1(4) and Annex point (4): UCPD Annex I point 23e; recital 18. Source checked 2026-09-10.
Check known features that limit a good's lifetime
The EU blacklist covers commercial communications about a good containing a feature introduced to limit durability when information about that feature and its effects is available to the trader. Do not replace this availability condition with proof that a particular employee personally knew. Ordinary low quality is not automatically such a feature.
Questions for the evidence review
Is there an identified feature introduced to limit durability, rather than only a general quality concern?
What information about the feature and its effects is available to the trader?
Which communications promote the affected good?
EU pinpoint: Article 1(4) and Annex point (4): UCPD Annex I point 23f; recital 19. Source checked 2026-09-10.
Support promised lifetime or usage
The EU blacklist prohibits falsely promising a particular lifetime or usage intensity for a good under normal use. Match any years, cycles or usage promise to the actual conditions and evidence; an isolated fault is not automatically proof of this practice.
Questions for the evidence review
What lifetime or usage level is claimed, and under which normal-use conditions?
Do tests and available performance information support that promise?
EU pinpoint: Article 1(4) and Annex point (4): UCPD Annex I point 23g; recital 20. Source checked 2026-09-10.
Only call a good repairable if repair is possible
The EU blacklist prohibits presenting a good as repairable when it is not. A repairability statement needs to reflect the actual ability to repair the good, not just an aspiration about circularity.
Questions for the evidence review
What repair does the statement promise?
Can that repair actually be performed, considering the good's design and restrictions?
EU pinpoint: Article 1(4) and Annex point (4): UCPD Annex I point 23h; recitals 21–22. Source checked 2026-09-10.
Do not prompt replacement before it is technically needed
The EU blacklist prohibits inducing consumers to refill or replace a consumable sooner than technical reasons require. Review prompts, indicators and instructions, not only advertising copy.
Questions for the evidence review
What technical condition justifies the refill or replacement prompt?
Does the prompt appear while the consumable can still perform its intended function?
EU pinpoint: Article 1(4) and Annex point (4): UCPD Annex I point 23i; recital 23. Source checked 2026-09-10.
Be truthful about alternative parts and consumables
The EU blacklist covers hiding functional limitations caused by using another supplier's consumables, spare parts or accessories. It also covers falsely saying those alternatives will impair the good when they will not. Both concealment and unfounded warnings need checking.
Questions for the evidence review
Will alternatives not supplied by the original producer reduce functionality, and is that disclosed?
Does evidence support any warning that alternatives will cause impairment?
EU pinpoint: Article 1(4) and Annex point (4): UCPD Annex I point 23j; recital 24. Source checked 2026-09-10.