“Climate-neutral”, “sustainable”, “eco-friendly” – which advertising terms are banned from 2026

From the cut-off date, making generic environmental claims whose recognised excellent environmental performance cannot be demonstrated is banned (new point 4a of the “blacklist”). The directive’s recitals name as examples of such terms, among others:

• •“climate-neutral” – as a generic product claim, especially where it rests solely on carbon offsetting
• •“eco-friendly” / “environmentally friendly”
• •“sustainable”
• •“green”
• •“eco” / “ecological”
• •“biodegradable”
• •“climate-positive”

No term is as central to enforcement as “climate-neutral”. The German Federal Court of Justice (BGH) has already ruled (judgment of 27 June 2024 – I ZR 98/23) that the ambiguous term may only be used in advertising if it is clearly explained in the advertising itself. And the most prominent case comes from Germany: Apple was banned at first instance from advertising the Apple Watch as “carbon neutral” (Frankfurt Regional Court, August 2025; not final) – on Reddit one of the most-discussed greenwashing threads of all.

The background is offsetting scepticism: carbon offsets are not a scam per se, but they are under heavy criticism because their actual climate impact is often hard to measure and sometimes overstated. This is exactly why EmpCo draws its clearest line here – from 2026, offsetting alone no longer suffices as the basis of a climate-neutrality claim. Which fines apply for violations is shown by the Shein and Apple cases.

EmpCo does not ban environmental communication – it bans the unsubstantiated generic claim. Whoever gets specific and secures the evidence beforehand may continue to advertise environmental properties. The overview:

The term bans do not come out of nowhere: the EmpCo Directive has been in force since March 2024 and amends the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU). Its core is the burden-of-proof logic – whoever advertises environmental benefits to consumers must be able to prove them before the claim becomes public.

A common source of confusion: for the Green Claims Directive, the separate and much more detailed proposal with mandatory ex-ante verification of every green claim, the European Commission announced its withdrawal in June 2025; the procedure has been on hold since. That changes nothing about the term bans – they arrive via EmpCo, not via the Green Claims Directive.

And the Reddit question “Is ‘biodegradable’ even regulated?” can now be answered precisely: from 27 September 2026, yes – “biodegradable” is explicitly on the list of claims that are impermissible without proof.

How widespread generic environmental terms are is shown by the consumer discussion – the threads are also a preview of which industries are particularly in focus:

• •Packaging: in r/sustainability, a thread mocks individually plastic-wrapped socks with sustainability branding (70+ comments) – the classic gap between message and product.
• •Textiles: in r/knitting, over 170 commenters are annoyed about the “greenwashing around bamboo yarn” – a material generically marketed as eco.
• •Beauty: in r/BeautyGuruChatter, “clean” is the textbook example of a nice-sounding, previously unregulated term.
• •Fashion: “Is this greenwashing?” posts with product photos are a recurring format in r/ethicalfashion – consumers have long been checking claims themselves.

For planning campaigns, packaging and website relaunches this means: everything produced now that is still public on 27 September 2026 must already comply with the new rules.

• •Since March 2024: the EmpCo Directive (EU 2024/825) is in force.
• •By 27 March 2026: deadline for EU member states to transpose it into national law.
• •19 February 2026: Germany publishes the Third Act Amending the UWG in the Federal Law Gazette (BGBl. 2026 I No. 43).
• •From 27 September 2026: the new rules apply bindingly – with no transition period for products or claims already on the market.
• •Already today: unsubstantiated environmental claims are actionable as misleading under Section 5 UWG – through competitors and associations.

• •Inventory: record all environmental claims on the website, packaging, in the shop and in running campaigns.
• •Rewrite instead of delete: replace generic claims with specific, substantiated statements – with the permitted-vs.-banned examples as a template.
• •Clean up labels: remove non-certified own labels.
• •Check the existing content systematically: go through the entire website for green claims – automated in hours instead of manually in weeks.
• •Establish an approval process: have every green claim jointly approved by marketing, legal and sustainability before publication.

Is “climate-neutral” still allowed from 2026?

Yes, but only under strict conditions. From 27 September 2026, the generic product claim “climate-neutral” is banned if it rests solely on carbon offsetting. Claims based on actual emission reductions in the value chain that are verifiably substantiated remain permitted. The German Federal Court of Justice (BGH) has already ruled that “climate-neutral” may only be used in advertising if the term is clearly explained in the advertising itself.

Which advertising terms are specifically banned from 2026?

Banned are generic, unsubstantiated environmental claims such as “climate-neutral”, “green”, “sustainable”, “eco-friendly”, “eco” or “biodegradable” where no recognised, verifiable proof exists. Also banned: self-invented sustainability labels without independent certification and misleading claims about durability (planned obsolescence).

What happens to sustainability labels and own labels?

From 2026, sustainability labels are only permissible if they are based on a recognised certification scheme or were established by a public authority. Self-designed “trust” or “eco” labels without independent third-party verification are no longer allowed.

Is there a transition period for existing products?

No, there is no transition period. From 27 September 2026, all environmental claims – on packaging, websites, in advertising and in online shops – must meet the new requirements. Companies should review stock and communication materials in good time.

Was the Green Claims Directive withdrawn – what applies now?

This is often confused. For the Green Claims Directive (the separate proposal with an ex-ante verification system) the European Commission announced its withdrawal in June 2025; the procedure has been on hold since. The EmpCo Directive (EU 2024/825) is unaffected, already adopted, and applies from 27 September 2026. The greenwashing ban is coming – just via EmpCo instead of the Green Claims Directive.