Europe’s new consumer rules are about to make some very familiar environmental claims considerably more difficult to use
Most of us have probably noticed that the humble leaf has had quite a career in marketing.
Once confined largely to trees, it eventually discovered packaging design and has never looked back. It now lives on shampoo bottles, hotel websites, trainers, electricity tariffs, washing liquid, clothing collections, food-delivery services and an impressive assortment of products whose relationship with photosynthesis is, at best, indirect. Sometimes it appears alone. Sometimes it is accompanied by a water droplet, a tiny planet, an earnest hand cradling a seedling, or that particular shade of muted green that seems to say: this purchase has already discussed the matter with nature.
Around the leaf grew an equally successful vocabulary. Products became green, eco-friendly, natural, responsible, conscious, climate friendly and, most majestically of all, sustainable. These words do rather more than describe. They reassure. They distinguish. They allow an ordinary purchase to acquire a small moral biography. The detergent is no longer merely going to clean your socks; it is apparently participating in the transition to a better civilisation.
From 27 September 2026, some of that language becomes considerably harder to use casually in the European Union. Directive (EU) 2024/825, usually referred to as the Empowering Consumers for the Green Transition Directive, starts applying across the EU after Member States were required to transpose it by 27 March this year. It strengthens existing consumer law against misleading environmental claims, unreliable sustainability labels, misleading carbon-neutrality claims and several other practices associated with greenwashing.
The interesting part is not that Brussels has suddenly developed an aversion to the colour green. It is that European consumer law is beginning to ask a deceptively difficult question about the environmental language surrounding everyday products: what, exactly, is this sentence asking the consumer to believe?
That question turns out to take us somewhere much more interesting than packaging.
The problem with buying something you cannot inspect
When you buy a chair, you can sit on it. When you buy a peach, you can eventually discover whether it tastes like a peach or like a small damp disappointment. But many environmental qualities cannot be verified by the person buying the product, even after using it.
Economists describe characteristics like these as credence attributes. Whether a product was made under particular environmental conditions, whether its supply chain really has lower emissions, whether a material comes from the source claimed, or whether a production process genuinely reduces ecological harm is largely invisible to the buyer. Consumers therefore depend on signals supplied by producers, labels, certifiers and retailers to bridge an information gap they cannot realistically investigate themselves. Research on sustainability certification has long identified exactly this problem: environmental qualities are unusually dependent on trust because the consumer often cannot independently verify them through either inspection or experience.
This makes environmental communication commercially powerful. A sustainability claim does not merely transmit information; it can influence how the entire product is perceived.
Psychologists and consumer researchers call one version of this the halo effect. Once something is marked as environmentally preferable, people may unconsciously attribute other positive qualities to it as well. A wonderfully strange series of experiments published in Food Quality and Preference found that an eco-label could even make fruit seem to taste better and influence assessments extending beyond environmental performance. More recent research continues to find similar effects: a 2024 study involving 1,010 German consumers found that an environmental score affected not only perceived environmental friendliness but, under some conditions, expectations about healthiness and taste.
So when regulators worry about a vague green claim, they are not being pedantic about adjectives. They are dealing with an information signal capable of changing how people value the thing being sold.
The problem becomes sharper when almost anybody can manufacture the signal.
The European Commission’s own work found that 53% of green claims examined provided vague, misleading or unfounded information, while 40% had no supporting evidence. It also counted 230 sustainability labels and 100 green-energy labels in the EU, with widely varying levels of transparency, and found that around half of green labels offered weak or non-existent verification.
At that point, the humble leaf starts looking less like decoration and more like an unregulated unit of credibility.
A market in adjectives
This is why the new rules make more sense if we stop thinking about them as environmental legislation and start thinking about them as market legislation.
Imagine two companies selling comparable products. Company A spends several years redesigning production, changing suppliers, measuring impacts, improving materials and paying for independent certification. Company B keeps roughly the same product but introduces a new package featuring a tasteful forest, the words planet conscious and, naturally, our old friend the leaf.
If consumers cannot distinguish the underlying environmental performance, Company A has a problem. It has invested in environmental improvement while Company B has invested in environmental atmosphere.
This is partly what the EU is trying to correct. The Directive itself explicitly connects reliable environmental claims with fair competition: if consumers can distinguish products with genuinely better performance, businesses making substantive environmental improvements are less likely to compete on equal terms with businesses making substantively better graphics.
There is a democratic dimension here too. The green transition relies heavily on consumer choice, but consumer choice only works as a policy instrument when the information entering that choice is reasonably trustworthy. Asking citizens to “vote with their wallets” while allowing the ballot paper to be written by the marketing department has certain structural weaknesses.
And this is where Europe has arrived at the slightly surreal but entirely logical business of regulating adjectives.
So, can you still call something “green”?
Yes. But not quite in the carefree way the word has sometimes been used.
The Directive identifies generic environmental claims such as environmentally friendly, eco-friendly, green, ecological, climate friendly, carbon friendly, energy efficient, biodegradable and similar expressions. From September, such broad claims cannot simply be made unless the trader can demonstrate recognised excellent environmental performance relevant to the claim.
There is, however, an important distinction between something generic and something specific. The Directive itself contrasts a phrase such as “climate-friendly packaging” with a statement explaining that 100% of the energy used to produce the packaging comes from renewable sources. The latter tells the consumer what the environmental advantage actually consists of, rather than asking two words and a hopeful colour palette to carry the entire burden.
That distinction may sound linguistic, but it changes the logic of sustainability communication.
For years, marketing has often done exactly what good marketing is trained to do: compress complexity. Supply chains, energy sources, material composition, lifecycle impacts and production methods become a memorable phrase because nobody has ever stood in a supermarket thinking, I wish this yoghurt label contained a methodological annex.
The new law does not reverse that completely. Nor should it. But it does begin to set a limit on how much environmental complexity can be compressed before information becomes impression.
The problem is not brevity. It is what disappears during compression.
“Sustainable” may be an even more ambitious word than we thought
One of the more fascinating details in the legislation concerns words such as sustainable, responsible and conscious.
Those words can imply more than environmental performance. Sustainability may also carry social meanings: working conditions, fairness, animal welfare, human rights and other aspects of how a product or organisation behaves. The Directive therefore warns that excellent environmental performance alone cannot automatically justify sweeping generic claims such as sustainable or responsible.
This is important because sustainable has spent years behaving rather like a very ambitious umbrella.
A recycled package becomes a sustainable product. An efficiency improvement becomes a sustainable service. A lower-emission process becomes a sustainable business. One better-performing characteristic quietly expands until it appears to describe the moral condition of the whole organisation.
The Directive tackles that tendency directly as well. It prohibits environmental claims about an entire product or business when the claim really concerns only one aspect of the product or one unrepresentative part of the company’s activities. Its own example is wonderfully ordinary: if only the packaging is made from recycled material, marketing the whole product in a way that gives the impression that the product itself is made from recycled material can be misleading.
This may eventually become one of the most important habits the new rules encourage: the scale of the claim should resemble the scale of the evidence.
A small improvement is still an improvement. It does not need to be promoted to sainthood.
Zalando and the curious legal life of a leaf
We already have a useful glimpse of what this new approach looks like in practice.
The European Commission and national consumer authorities began a coordinated action involving Zalando after concerns about the platform’s sustainability claims. The resulting commitments are unusually revealing because they were not only about words. Zalando agreed to remove its sustainability flag, stop using misleading environmental icons including leaves and trees, and replace broad sustainability terminology in relevant product filtering with more specific information about product standards and attributes, including percentage figures where appropriate.
There is something quietly significant about this case.
Consumer protection law is entering the territory of semiotics: not only what a company literally says, but how colour, symbols, labels, positioning and language combine to create meaning. The Directive itself recognises that environmental claims can arise through the overall presentation of a product and that words combined with images or colours can create a generic environmental message.
Which means the leaf is not prohibited.
It simply no longer has diplomatic immunity.
And researchers suggest regulators are right to care about visual cues. A 2026 study of more than 2,100 German consumers found that unregulated sustainability-related claims could significantly raise perceptions of environmental friendliness and, strikingly, often produced impressions comparable to those generated by the regulated EU organic label. Consumers did not always distinguish clearly between rigorous certification and much looser environmental signals.
This is the deeper difficulty in what researchers sometimes call the label jungle. Consumers do not arrive at a shelf carrying a comparative database of certification methodologies. They use shortcuts. A logo looks official. Green looks environmental. A technical phrase sounds measured. A badge surrounded by enough circles begins to look as though somebody somewhere must have audited it.
Sometimes somebody has.
Sometimes the graphic designer had a productive afternoon.
Europe would now like to know who gave you that badge
The Directive therefore places much stricter conditions on sustainability labels.
A sustainability label displayed in consumer-facing marketing generally needs to be either established by a public authority or based on a certification scheme meeting transparency and credibility requirements, including objective third-party monitoring. The goal is to stop organisations from creating private trust marks that visually resemble meaningful certification without having comparable verification behind them.
Again, this is not an obscure concern. The Commission’s count of hundreds of sustainability and green-energy labels illustrates how difficult the landscape has become for ordinary consumers. The problem is not simply that there are many labels. It is that the visual grammar of certification is extremely easy to imitate. Put some text around a circle, insert a leaf, perhaps add the word verified, and the object begins to acquire institutional authority before anyone has asked who the institution is.
Certification, at its best, solves an information problem by putting a credible third party between seller and buyer. A self-created sustainability badge can do the opposite: it borrows the visual language of independent verification while returning all the authority to the seller.
Europe has decided that this distinction should be easier to see.
The bottle that was 100% recycled, except for the bits that were not
Another enforcement case shows how small the difference between clarity and impression can be.
After a complaint concerning environmental claims on plastic bottles, Coca-Cola and Nestlé Waters entered discussions with the European Commission and national consumer authorities. Among the resulting commitments was a rather precise piece of language: claims such as “This bottle is 100% recycled” would need an adjacent clarification making clear when the cap and label were excluded, presented with appropriate prominence.
This sounds almost comically minor. Surely nobody’s understanding of the European Green Deal depends on the bottle cap.
But the example gets to the heart of the regulatory shift. 100% is not a mood. It is a number. If the thing being described is not actually 100%, the missing scope matters.
The same principle becomes far more consequential when the subject is not a bottle but a company, a product lifecycle or a climate claim.
Environmental communication often becomes misleading not because every individual fact is false, but because a true fragment is allowed to imply a larger truth.
A factory runs on renewable electricity, therefore the product is green. A package contains recycled plastic, therefore the product is sustainable. A company buys carbon credits, therefore the service is climate neutral.
Each step contains information.
The trouble is the distance between the information and the conclusion.
The particularly awkward case of the climate-neutral flight
Aviation offers perhaps the clearest illustration.
In March 2024, the District Court of Amsterdam ruled that several past KLM advertisements had been misleading. The court found that broad environmental statements and overly optimistic presentation of measures such as sustainable aviation fuels and reforestation could give consumers an excessively positive picture of the environmental consequences of flying. KLM remained free to communicate about its environmental ambitions, the court emphasised, but those communications needed to be honest and concrete.
The issue did not stop with one airline. A coordinated European consumer-protection action eventually involved 21 airlines, which committed to changes concerning misleading environmental claims. Among the points addressed were claims suggesting that the emissions of a specific flight could be neutralised through a contribution or payment, use of vague green terminology and imagery, claims involving sustainable aviation fuels, and inadequately substantiated future environmental targets.
The new Directive gives this issue a firm legal boundary. Product- or service-level claims such as climate neutral, CO₂ neutral, carbon positive, climate compensated or reduced climate impact cannot be based on greenhouse-gas offsetting outside the product’s own value chain. Companies can still tell consumers that they finance reforestation, carbon-credit projects or other environmental initiatives, provided the communication is not misleading. What they cannot do is transform the existence of that separate activity into the claim that the purchased product itself has become climate neutral.
That distinction sounds technical, but it is philosophically rather neat.
Funding a forest may be a good thing.
It does not retroactively remove an aircraft’s exhaust from the sky.
Consumers do not necessarily hear “offset” when businesses say “neutral”
Research suggests the distinction matters because consumers may interpret climate language far more broadly than marketers intend—or, occasionally, far more broadly than marketers would mind.
That 2026 German study of 2,109 consumers tested claims including climate neutral, CO₂ neutral, CO₂ compensated and climate positive. These labels improved perceived environmental performance for some products, while the researchers also found substantial misunderstandings about what the terms actually meant. Only a small share of respondents correctly understood that climate neutral does not necessarily mean zero emissions. When participants were instead given concrete numerical climate-footprint information, some of the exaggerated effect produced by the broad climate claim disappeared.
That result is almost a miniature explanation of the new EU approach.
Specific information may be less emotionally elegant than a grand environmental adjective.
It is also harder to misunderstand.
Brussels has even become suspicious of the future tense
Companies are still allowed to set environmental ambitions. Europe has not outlawed optimism.
But future-facing claims such as plans to become climate neutral, achieve net zero or reach other environmental targets are coming under tighter scrutiny. Under the Directive, claims about future environmental performance can be considered misleading where they are not supported by clear, objective, publicly available and verifiable commitments, set out in a realistic implementation plan with measurable and time-bound targets, resources allocated to achieving them, and regular verification by an independent third-party expert.
This is quite an intervention in a familiar genre of corporate communication.
A target set for 2040 has certain rhetorical advantages. It is close enough to suggest seriousness, distant enough to avoid bumping into next Thursday’s procurement meeting, and extremely unlikely to interrupt the current chief executive’s lunch.
The new logic asks what connects today to that future date.
What changes?
Who is responsible?
What resources exist?
What milestones should already be visible five years from now?
In other words, a future environmental promise increasingly needs something more substantial behind it than a future tense.
Greenwashing is not only about deceiving the environmentally conscious
There is a tendency to imagine greenwashing as a niche consumer issue affecting a particular type of earnest shopper comparing oat milks.
The evidence suggests something larger is happening.
Environmental cues can spill over into judgments that have nothing to do with the environmental characteristic itself. Research has found sustainability labels influencing perceptions of healthiness, safety, taste, quality and purchase intention. One recent study even found that consumers could treat environmental labels on food as signals of food safety, creating willingness to pay for a characteristic the environmental label was never intended to certify.
That is why the word halo is so appropriate.
A claim illuminates the attribute beside it and, before long, the glow reaches the rest of the product.
This is also why the new legislation is about more than catching dishonest companies. Many misleading claims do not begin with somebody in a boardroom deciding to deceive the public. They can emerge much more mundanely. A sustainability team reports a real improvement. A communications team simplifies it. A designer makes the presentation attractive. A slogan loses a qualification. A product page survives three redesigns. Someone adds eco-friendly because the new packaging contains 30% less plastic. Nobody is necessarily twirling a moustache.
By publication, however, the sentence may be promising considerably more than the evidence ever did.
Greenwashing can be organisational drift.
That makes it harder to solve than simply telling marketers to behave themselves.
A small Brussels trap: this is not actually the Green Claims Directive
There is one piece of housekeeping worth doing because European legislation has managed to create a branding problem inside legislation intended partly to fix branding problems.
The rules applying on 27 September come from the Empowering Consumers for the Green Transition Directive, not the separate proposal commonly called the Green Claims Directive.
The latter was proposed in 2023 to create additional rules for substantiating and communicating explicit environmental claims. Its legislative journey became politically complicated: the Commission announced an intention to withdraw the proposal in June 2025, trilogue negotiations were cancelled, yet the proposal remained listed as pending in the 2026 Commission Work Programme. The European Parliament’s Legislative Observatory currently records the procedure as awaiting the Council’s first-reading position.
So if you have read that “the Green Claims Directive starts in September”, Europe has supplied us with a very appropriate example of why precision in claims is useful.
The legislation that is becoming applicable is already substantial enough.
This is also not a ban on sustainability language everywhere
The scope matters.
These are consumer-protection rules governing commercial practices between traders and consumers. They do not transform every environmental sentence uttered by every organisation into a consumer-law claim. A university research paper, an NGO’s project report and a mandatory corporate disclosure do not suddenly become product advertising because they contain the word sustainability.
Context matters, however. The same piece of environmental information can move from reporting into marketing. A company may describe emissions data in a formal report and later reuse a simplified version in advertising. A social enterprise may publish an impact report and also sell consumer services. Organisations increasingly communicate across blurred boundaries, where institutional reputation, product marketing, ESG information and public storytelling overlap.
The useful lesson is therefore not to develop a nervous tic every time somebody types the word green. It is to ask what role the statement is performing. Is it informing? Is it promoting? Is it comparing? Is it encouraging a consumer to choose one product over another because of an environmental advantage?
Consumer law has always cared about context.
Greenwashing simply gives the context more foliage.
What changes after 27 September is partly the burden of imagination
There is a larger cultural shift here that interests us at REDefine.
For years, much sustainability communication has depended on consumers completing the sentence themselves.
A leaf appears and we infer environmental care. A conscious collection appears and we infer a better supply chain. A climate-neutral delivery appears and we infer that somehow the delivery no longer contributes meaningfully to climate change. A sustainable choice badge appears and we assume somebody with a spreadsheet has checked.
The new rules push back against this technique of outsourcing the claim to the consumer’s imagination.
If a communication creates an environmental impression, the fact that the company never wrote the exact conclusion in twelve-point Helvetica may not make the impression irrelevant. Words, colours, images and context can work together. Consumer law increasingly looks at what the ordinary person is likely to understand, not simply at whether a lawyer can isolate one technically defensible phrase from the artwork around it.
This is a fascinating development because it brings regulation closer to how communication actually works.
Human beings do not consume advertisements as legal documents.
We interpret them.
And that may be good news for companies that are genuinely doing the work
Anti-greenwashing rules are often presented as another compliance headache for business. There will certainly be work involved, particularly for companies that have accumulated environmental claims across packaging, websites, product catalogues, advertisements, labels and old stock.
The Commission and national Consumer Protection Cooperation authorities have already had to address the treatment of goods and packaging produced or distributed before the September application date. Their June 2026 common approach emphasises good-faith, timely efforts to bring consumer-facing practices into compliance rather than pretending that warehouses cease to exist when legislation changes.
But there is another side to the story.
Companies that genuinely invest in environmental improvement have something to gain from a market in which environmental credibility becomes harder to manufacture cheaply. If certification, measurement, cleaner production, repairability, materials research or supply-chain reform costs money, then allowing competitors to achieve a similar consumer impression with an invented badge and a forest photograph undermines the commercial value of doing the difficult work.
Better rules can make credibility itself less vulnerable to counterfeiting.
That may ultimately be the most important market effect of the Directive.
Perhaps the adjective was carrying too much
The environmental systems behind a product can be staggeringly complicated: extraction, energy, transport, labour, manufacturing, chemicals, water, packaging, waste, emissions, biodiversity, repair, disposal and an international supply chain capable of giving an Excel workbook existential anxiety.
Then, at the very end, we try to compress the entire thing into green.
Perhaps it was always too much work for one adjective.
The direction of European policy is increasingly towards claims that tell us which environmental characteristic improved, compared with what, across which scope, on what evidence and under whose verification. This does not mean consumer communication must become unreadable. It means clarity will have to come increasingly from precision rather than vagueness.
And there is something almost refreshing about that.
A company might have to say that its packaging contains a particular proportion of recycled material instead of declaring the product sustainable. An airline can describe investments in lower-emission technologies without pretending the passenger has purchased a climate-neutral flight. A retailer can explain the specific certification or material standard a product satisfies instead of attaching a mysterious leaf and inviting the imagination to finish the job.
Perhaps the result will be slightly less poetic packaging.
But we may gain something more useful: information.
From 27 September 2026, the green transition will therefore acquire a small but important linguistic transition of its own. Environmental ambition can still be communicated. Improvements can still be celebrated. Companies can still tell compelling stories about becoming better.
They will simply have to become more careful about the distance between what they have done and what they imply that they have done.
Europe is not banning businesses from talking about sustainability. It is beginning to make environmental adjectives more expensive, because an adjective capable of creating trust, influencing purchasing decisions and conferring commercial value is not merely decoration.
And after its extraordinary career, the leaf may finally need supporting documentation.
