Voidless

EU Packaging Regulation 2025/40

The green claims your product pages can no longer make

From 27 September 2026 the Empowering Consumers Directive bans generic environmental wording, offset-based carbon neutrality and self-awarded eco labels. Most catalogues are full of all three.

What changes on 27 September 2026

Directive (EU) 2024/825, usually shortened to EmpCo, amends the Unfair Commercial Practices Directive by adding a set of environmental claims to the blacklist of practices that are banned outright. Blacklisted means there is no balancing test: the claim is unfair by definition, and no argument about context saves it.

Member states had to transpose it by 27 March 2026 and the rules apply from 27 September 2026. Because it works through national consumer law, enforcement comes from consumer protection authorities and, in several countries, from competitors and consumer associations who can act directly.

The wording that becomes illegal

Generic environmental claims go first. Words like environmentally friendly, eco-friendly, green, sustainable, natural and biodegradable are banned when used on their own, without demonstrating recognised excellent environmental performance relevant to the claim. The problem is not the words themselves but using them as a badge with nothing behind them.

Carbon neutrality based on offsetting is banned outright. Claiming a product is carbon neutral, climate neutral or net zero because emissions were offset elsewhere is now a blacklisted practice, regardless of how genuine the offset scheme is.

Claims about the whole product when only part of it qualifies are out, as are claims about a legal requirement presented as a distinctive feature. Forward-looking claims such as a 2030 net zero target survive only with a public, realistic implementation plan and independent verification the consumer can reach.

Which labels survive

Sustainability labels are only allowed where they come from a third-party certification scheme with public, transparent criteria, or where a public authority established them. The EU Ecolabel is the obvious example of one that holds up.

What does not survive is the self-awarded badge: the green leaf icon a brand designed for its own product pages, or a seal from a scheme with no independent verification. If your theme renders a sustainability icon that nobody outside your company audits, it has to go.

Durability, repairability and the guarantee notice

Alongside the bans, EmpCo adds positive information duties. Consumers must be told about durability and repairability at the point of sale, and practices that hide or induce early obsolescence become unfair.

Where a producer offers a commercial guarantee of durability longer than the two-year legal guarantee, that has to be communicated through a harmonised notice rather than in the seller's own words. The point is comparability: a shopper should be able to read the same signal across different shops.

Why this is a catalogue problem, not a copywriting one

Fixing one product description is trivial. The difficulty is that a shop with a few hundred products has banned wording scattered through descriptions, collection pages, badges, alt text and theme snippets accumulated over years, and nobody remembers where.

It is the same shape of problem as empty space in a parcel: the rule is simple, but the audit across a whole catalogue is not. Start by searching your product copy for the specific banned terms, then work through what each one was actually trying to say — usually there is a precise, substantiated claim underneath that is still perfectly legal to make.