Environmental claims are specific and sustainability labels name their scheme
Legal references (EU)
- Dir 2005/29/EC as amended by Dir (EU) 2024/825, Annex I
Some guidelines reference legal provisions. These references identify the rules a guideline relates to. They are not legal advice, they are not a statement that any particular shop complies or does not comply, and they may not reflect the current state of national transposition. Consult qualified counsel for questions about your own compliance.
What is being checked
Whether environmental and sustainability claims made anywhere on the site are specific rather than generic, whether each sustainability label displayed identifies the certification scheme behind it, and whether claims about future environmental performance are accompanied by the commitments they rest on.
Why it matters
Generic environmental claims have been the default marketing register for a decade, and the rules changed underneath them. From the application date of the amending directive, generic claims such as describing a product as environmentally friendly without demonstrated excellence, and claims of neutrality based on offsetting, are prohibited, and sustainability labels may only be displayed where they rest on a certification scheme meeting defined requirements or are established by a public authority.
The practical exposure is concentrated in places nobody audits: a sustainability filter on a listing, a badge on a product tile, a category landing page written years ago, footer copy about the company's commitments. Responsibility for displaying a non-compliant label sits with the trader displaying it, not only with whoever issued it.
Failure signals
- Generic claims such as green, eco, environmentally friendly or climate-friendly, with no stated basis.
- Neutrality or offset-based claims presented as a property of the product.
- A sustainability label with no named scheme, or a self-created label styled as a certification.
- A category or filter labelled sustainable whose inclusion criteria are stated nowhere.
- Future-facing commitments with no stated plan or verification.
- Product-level claims that actually describe one component or one stage of production, without that scope being stated.
How to verify
- Inventory environmental and sustainability claims across the homepage, category landing pages, listing filters, product tiles, product pages and footer.
- For each, confirm the claim is specific and its basis is stated or one click away.
- For each label, confirm the scheme is named and identifiable as third-party.
- For any sustainability filter or category, confirm the inclusion criteria are published.
- Confirm no claim rests on offsetting as a property of the product.
- Confirm forward-looking commitments state what they rest on.
Timing note: the amending directive enters into application on 27 September 2026. The detail of national transposition and the precise treatment of stock already on shelves before that date should be confirmed with counsel. This guideline checks the observable properties of the claim and does not assert what any particular claim's legal status is.
Claims typically live in several places at once: CMS content, product properties and custom fields, and badges rendered by third-party widgets. That is why the inventory in step 1 matters: they are rarely all in one place.
Recommended fix
Replace generic claims with specific, scoped ones that state what is being claimed about what. Render every sustainability label with its scheme named. Publish the criteria behind any sustainability filter or category. Remove offset-based neutrality claims about products rather than rewording them.