The short answer
Since 27 September 2026, Directive (EU) 2024/825 bans generic environmental claims such as 'eco-friendly' or 'green' without recognised excellent environmental performance, sustainability labels not based on a certification scheme or set by a public authority, and 'carbon neutral' claims based on offsetting. It also bans misleading statements about software updates.
Key takeaways
- Directive (EU) 2024/825 amends the Unfair Commercial Practices Directive. Member states had to transpose it by 27 March 2026, and it applies from 27 September 2026.
- Banned: generic claims like 'eco-friendly' and 'green' without recognised excellent environmental performance.
- Banned: sustainability labels that are not based on a certification scheme or established by public authorities, and whole-product or whole-business claims that only cover one aspect.
- Banned: claiming a product has a neutral, reduced or positive climate impact when that rests on offsetting emissions.
- Also banned: presenting a functionality-only update as necessary for security, and hiding that an update will reduce what the product can do.
- Widespread infringements of the Unfair Commercial Practices Directive can be fined up to 4% of turnover.
On this page
01
Which environmental claims are banned in the EU now?
The directive adds new items to the blacklist in Annex I of the Unfair Commercial Practices Directive, so a claim of this type is unfair without any case-by-case test. It applies to every trader marketing to EU consumers, including software and online services, not only physical goods. Directive (EU) 2024/825 is the source.
| Claim type | Example on a site or app | Safer approach |
|---|---|---|
| Generic environmental claim without recognised excellent performance (Annex I pt 4a) | 'Eco-friendly', 'green', 'climate friendly' | Say exactly what is true and measured, for example 'hosted in a data centre powered by X, certified under Y' |
| Sustainability label not based on a certification scheme or set by public authorities (pt 2a) | A leaf badge you designed yourself | Use a recognised scheme's label, or drop the badge |
| Claim about the whole product or business that covers one aspect (pt 4b) | 'Sustainable app' because the logo files are recycled | Name the aspect: 'Our servers use renewable electricity' |
| Climate-impact claim based on offsetting (pt 4c) | 'Carbon neutral' or 'climate positive' via credits | Report your own emissions and reductions instead |
Specific, true claims are still allowed. A statement like 'we cut our hosting emissions by switching to a certified renewable provider' is a factual claim you can substantiate, which is different from a broad label.
02
What does the directive say about software updates?
Two practices are now on the blacklist: presenting an update as necessary for security when it only changes functionality (Annex I pt 23e), and not telling users that an update will negatively affect the use of the product or service (pt 23d). Both matter for any app or software with a consumer update flow.
- Do not label a feature release as a 'security update' to push people to install it.
- If an update removes or limits something users rely on, say so in the release notes and the update prompt.
- Check app store 'What's new' texts for the same wording.
03
How do I check my website and app store listing?
- 01
Search for the words
Search your pages, emails, ads and store listings for eco, green, sustainable, climate, planet-friendly and carbon neutral.
- 02
Ask what stands behind each one
For every hit, write down the evidence: a recognised certification, a public body, or your own measured figures.
- 03
Replace or remove what you cannot back
Swap generic words for specific facts, drop home-made badges and remove offset-based neutrality lines.
- 04
Review update wording
Read your changelog and in-app update prompts for the two update practices above.
SafeLaunch's rulebook includes both the green-claims and the software-update rules under the Unfair Commercial Practices Directive for the EU, Germany and France, one of 142 laws across 58 markets. The AI-assisted analysis in a paid report reads your page copy for such claims; start with a free scan, and see the briefing.
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Sources and further reading
This article is general information, not legal advice. SafeLaunch is automated software, not a law firm; a report records what was checked on one version and is not a certificate of compliance. Read the disclaimer.
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