What does the Empowering Consumers Directive (EU) 2024/825 change?
It adds several environmental claims to the EU blacklist of unfair commercial practices, and it sets conditions for promises about future performance. Directive (EU) 2024/825 of 28 February 2024, published in the Official Journal on 6 March 2024 and in force since 26 March 2024, amends Directive 2005/29/EC on unfair business-to-consumer commercial practices and Directive 2011/83/EU on consumer rights. Member States had to transpose it by 27 March 2026; their laws have applied since 27 September 2026.
Two mechanisms work side by side. Practices added to Annex I are unfair in all circumstances: the authority does not have to prove that a consumer was misled. Promises about future performance fall under Article 6 and are judged case by case.
Claim | Allowed? | Condition |
|---|---|---|
“Eco-friendly”, “green”, “biodegradable”, with no specification | No, unless excellence is recognised | Recognised excellent environmental performance: EU Ecolabel (Regulation (EC) No 66/2010), an officially recognised type I ecolabel in a Member State, or top performance under Union law (point 4a) |
“100% of the energy used to produce this packaging comes from renewable sources” | Yes | Specific, accurate, evidenced claim, spelled out on the same medium |
“Made with recycled material” when only the packaging is recycled | No | A claim about the whole product or business must hold for the whole (point 4b) |
A sustainability logo created by the company | No | The label must rest on a third-party certification scheme or be established by public authorities (point 2a) |
“Carbon neutral” on a product, thanks to carbon credits | No, in all circumstances | Banned once the claim relies on offsetting (point 4c); only the product’s actual life-cycle impact can support such a claim (recital 12) |
“Net zero by 2040” | Yes, under conditions | Detailed and realistic implementation plan, measurable and time-bound targets, regular verification by an independent third-party expert (Article 6(2)(d) of Directive 2005/29/EC) |
“We fund a reforestation project” | Yes | Accurate information, without implying the product has a neutral impact (recital 12) |
“Free from” a substance already banned for the whole category | No | A legal requirement common to all products is not a distinctive feature (point 10a) |
Who is affected, and what does “business-to-consumer” mean for a supplier?
Traders that address EU consumers are covered directly; a supplier selling to businesses is covered through the claims that reach the end consumer. Directive 2005/29/EC covers advertising, packaging, labels, online product pages and brand names, and its definition of “trader” includes anyone acting in the trader’s name or on its behalf.
Directive (EU) 2024/825 is addressed to the Member States. Morocco, like any non-EU country, has nothing to transpose: the rule applies, through the national laws of the Member States, to anyone marketing products to EU consumers.
Moroccan, African and international exporters
- You sell online to EU consumers: you are the trader for those communications, and your product pages and packs must respect the bans.
- You manufacture under an EU customer’s brand: the claim printed in Morocco becomes your customer’s claim. A packaging maker in Kenitra that prints “eco-friendly packaging” for a European retailer exposes that retailer, which will ask for evidence or have the wording removed. The same goes for a tea packer in Kenya or a cocoa processor in Ghana supplying an EU private label.
- You sell a material or component to an EU manufacturer: that relationship is not a consumer practice, but your technical sheets feed your customer’s claims. An olive oil exporter in Meknes that advertises a “carbon neutral” product based on purchased credits hands its buyer a claim the buyer cannot use.
Expect questionnaires, requests for evidence and contract clauses on who approves wording before printing.
Are future climate promises still allowed?
Yes, if a verifiable plan backs them. Article 6(2)(d) of Directive 2005/29/EC, added by Directive (EU) 2024/825, treats a claim about future environmental performance as misleading when it lacks clear, public and verifiable commitments set out in a detailed, realistic plan with measurable, time-bound targets and allocated resources. An independent third-party expert must check the plan regularly, and consumers must be able to see the findings.
For a manufacturer, that means an emissions inventory, a costed reduction plan lever by lever and a verifier independent of the company: the purpose of a decarbonisation strategy. A reduced-impact claim on a product must rest on that product’s actual life-cycle impact, which is why you need the carbon footprint of your products.
ISO 14068:2026 (formerly ISO 14068-1:2023) frames a carbon neutrality approach that starts with reduction; it does not allow you to tell EU consumers that a product is neutral thanks to offsetting (see our ISO 14068 carbon neutrality guide). A self-declared claim under ISO 14021:2026 (formerly ISO 14021:2016) helps you word a precise claim, but it is not a certified label.
What should you do now about your claims?
- This week: take stock. List every environmental statement: packaging, labels, technical sheets, website, social media, logos.
- Within two weeks: sort. Place each statement in the table above.
- Without delay: remove. The rules have applied since 27 September 2026: drop neutrality claims based on offsetting and uncertified logos.
- This month: document. For each claim you keep, build a dated evidence file: data, method, scope.
- Before any future promise: plan. Write the plan and appoint an independent third-party expert before announcing the target.
- With every contract: agree. Settle with your EU customer who approves wording, on what evidence, and before which print run.
- Every quarter: monitor. Follow the Green Claims procedure and the transposition laws of your markets.
Checklist: review your claims before selling in the EU
What is the status of the Green Claims Directive?
It has not been adopted. On 22 March 2023 the Commission published proposal COM(2023) 166 on the substantiation and communication of explicit environmental claims (procedure 2023/0085(COD)). The European Parliament adopted its first-reading position on 12 March 2024, and the opening of interinstitutional negotiations was announced in plenary on 16 December 2024.
On 11 November 2026 the European Parliament’s Legislative Observatory showed the stage “awaiting Council’s 1st reading position” and EUR-Lex an “ongoing” procedure, with no mention of adoption or withdrawal. Do not wait for that text: the bans in force are those described above.