Green Claims and Changes to Consumer Protection Legislation

Did you know that the Empowering Consumers for the Green Transition Directive will be implemented in March 2026, and that the national provisions adopted under it must already be applied from 27 September 2026 onwards*?

Now is the time to act and ensure that your company’s communication meets the requirements of what is often referred to as the “anti-greenwashing” regulation.

“The directive aims in particular to promote the circular economy and a clean, green economy in the EU by enabling consumers to make informed purchasing decisions and thereby contribute to more sustainable consumption. It also addresses unfair commercial practices that mislead consumers and prevent them from making sustainable consumption choices.”**

In this article, I have compiled an informal overview of the information currently available from various sources. I examine the implications of the legislative changes, for example from the perspective of companies in the textile and fashion industry, which is why more technical aspects related to devices and software are not covered here.The purpose of this article is to describe the spirit of the law and highlight key points to consider. At the time of writing, the legislation has not yet been fully implemented, so the final wording is not yet known. However, it is clear that the regulation will leave less room for vague “green” impressions and will increase requirements for verifiability and precision in communication.

What Kind of Content Does the Regulation Cover?

The regulation does not apply only to marketing slogans and advertisements. In practice, it covers all communication and marketing, including websites, social media, in-store communication, and product packaging. This also includes marketing names, company names, and product names.More specific rules are also expected for e-coomerce, for example regarding environmentally preferable delivery options.It is important to note that non-compliance may result in fines linked to turnover.

Precision of Green Claims

The regulation will restrict the use of terms such as environmentally friendly, ecological, responsible, and green unless these claims can be convincingly substantiated and put into context relative to comparable activities. These expressions are considered too vague, and communication will now be expected to be more precise and concrete.

This is not entirely new, although the requirements are becoming stricter and more specific. Already in 2024, the Finnish Competition and Consumer Authority stated, for example:

“Even if a product is sustainable in one respect, it cannot be called sustainble if it does not meet the full meaning of the claim, including economic, social, and environmental aspects. The more general, unspecified, and vague an expression is, the more precisely its meaning must be explained.”

Companies can, and should continue to communicate about sustainability. However, they must carefully consider how to do so in a more concrete, precise, and non-misleading way.

In some cases, it may be enough to replace or remove individual words. However, rather than focusing narrowly on a list of prohibited terms, it is more meaningful to review the overall narrative of communication. What exactly is meant by sustainability or environmental friendliness, and how can it now be expressed truthfully, clearly, and in a verifiable way?

It must also be clearly communicated whether a claim applies to a specific part of a product, the entire product, or the company as a whole.

Verifiability

The regulation will also apply to the verifiability of claims. Any claim made must be supported with evidence.

In practice, this is likely to be a greater challenge than wording itself. Personal belief, assumption, or general understanding is not sufficient. Claims must be backed by documentation, data, or third-party verification. Companies should address this as soon as possible and consider how key claims can be reliably substantiated.

It is also worth noting that future targets should be formulated not as abstract ambitions, but as methods and measurable indicators.

Visual Communication

Visual elements also play a role in shaping perceptions. A “green-looking” visual identity may be considered misleading if it is not directly linked to the company’s actual operations and/or products.

For example, nature imagery without a clear connection to the content may be interpreted as greenwashing. Similarly, self-created eco-labels, leaf symbols, or graphics resembling certifications are subject to increased scrutiny.

Actual Impact

Cause-and-effect relationships will be assessed more strictly. For example, claims based on the offsetting of greenhouse gas emissions will be prohibited in all circumstances.

Terms such as carbon neutral may therefore only be used if they are based on the actual lifecycle impacts of the product.

It will also be prohibited to promote benefits that are not directly linked to the product or the company’s core activities. Such could be, for example, charity initiatives with no direct relation to operations.

Repairability

Repairability will receive particular attention already at the point of sale. Information about repairability must be provided before the purchase decision.

This requirement extends across the entire distribution chain: how is this information communicated in e-commerce, physical stores, and through retailers?

*Source: Finnish Government
**Source: Ministry of Justice

Disclaimer: This article is not exhaustive or legally precise, and national legislation had not yet been fully implemented at the time of writing. You can read the full directive here.