Updated 24 September 2026 The first version of this article said that the directive applied directly to businesses from 27 September, and that carbon neutrality based on offsetting could no longer be claimed. That is inaccurate in France at this date. A directive is addressed to Member States, and France has only partly transposed it; French law still allows the claim “carbon neutral” in advertising, under conditions. The article has been corrected and now separates what the directive provides from what already applies in France.
The short version
- 27 September 2026 is the date from which Member States must apply Directive 2024/825, which provides for no transition period. They had to transpose it by 27 March 2026 at the latest.
- France has only partly transposed it: it notified the Commission of three existing legal provisions, and on 28 May 2026 the Commission asked France to transpose the directive in full.
- Part of the subject is already law in France: the words “biodegradable” and “environmentally friendly” have been banned on a product or its packaging since 2022, and a false or misleading claim about a product’s environmental impact is a misleading commercial practice.
- The rest sits in the directive and awaits full transposition: the ban on generic claims without recognised excellent environmental performance, on uncertified sustainability labels, and on neutrality based on offsetting.
This article comes out three days before the date set by the directive, and that is not an accident of the editorial calendar: it is the moment when the inventory is still comfortable to run. The “empowering consumers for the green transition” directive amends the European directive on unfair commercial practices. In French law, those practices fall under the Consumer Code, notably its article L. 121-2, the same article that already covers misleading price reductions. In other words, these are not recommendations: this is the regime of misleading commercial practices.
What “27 September” means The directive ends with a sentence that says it all: “This Directive is addressed to the Member States.” Its article 4 requires Member States to adopt the necessary national provisions and to apply them from 27 September: it is through national law that the rules reach businesses. Until the French transposition is complete, not all of the new prohibitions are in French law. That does not make the work optional: part of the rules already applies, and the rest will have to be transposed.
What changes, in shop language
| On your pages today | What the directive provides | What already applies in France |
|---|---|---|
| “Eco-friendly product”, “kind to the planet”, “green” | Banned in all circumstances: a generic environmental claim for which you cannot demonstrate recognised excellent environmental performance relevant to the claim | “Biodegradable”, “environmentally friendly” or any equivalent wording have been banned on a product or its packaging since 1 January 2022. A false or misleading claim about environmental impact is a misleading commercial practice |
| An in-house green-leaf “eco” pictogram, a label invented by the brand | Banned: displaying a sustainability label that is not based on a certification scheme or not established by public authorities | A label that misleads about the product’s characteristics or environmental impact falls under misleading commercial practices |
| “Carbon-neutral delivery”, “climate-neutral product” through offsetting | Banned: claiming, based on the offsetting of emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions | Allowed in advertising, provided you make public an emissions assessment of the product, the approach that avoids, then reduces, then offsets them with quantified annual targets, and the offsetting arrangements |
| “Sustainable” as a headline over the whole collection | Banned: making an environmental claim about the entire product when it only concerns one of its aspects | A claim likely to mislead about the product’s essential characteristics is a misleading commercial practice |
The mistake that costs the most Believing this is a job for the legal team rather than for marketing. Claims live in product pages, banners, emails, ads, social posts and packaging: all places written by marketing, often copied from year to year until nobody remembers where the sentence came from. The inventory is a content job, and it can be measured: search your catalogue for “eco”, “green”, “sustainable”, “natural”, “responsible”, and count.
Why this is an opportunity for brands that mean it
Greenwashing created an inflation of words: when everyone is “eco-responsible”, actually being so no longer shows. The directive goes after that inflation. A brand with real facts, recycled material, relocated manufacturing, genuine repairability, keeps the right to talk about them, precisely, while vague wording becomes indefensible.
The compliance work is therefore the same as the differentiation work: replace each adjective with the fact that justified it, or delete it if there was none. “Dyed without heavy metals, certified” is information; “eco-friendly” is a slogan.
The method, in four passes
- Take inventory by word search. Across the catalogue, brand pages, email templates and running campaigns: “eco”, “eco-friendly”, “green”, “sustainable”, “natural”, “responsible”, “neutral”, “biodegradable”, “recyclable”. The list of occurrences is your scope. Start with what appears on products and packaging: that is where French law already bans some wording.
- Sort into three piles: provable as it stands, with a file to back it up; true but vague, to rewrite as a precise fact; unverifiable, to delete. The second pile is often the largest, and it is the one that pays.
- Deal with labels and pictograms. Every logo with an environmental connotation must be able to point to a certification scheme or a public authority, as the directive requires. The in-house pictogram goes, or becomes an illustration that no longer claims to be a label.
- Lock down the source. Claims come back through supplier sheets and translations: add the check to your new-listing review, alongside safety information. It is the same product-data job as the product safety regulation, one more pass over the same fields.
A ten-minute self-diagnosis: search “eco” and “sustainable” in your product admin and count the occurrences. Then pick five at random and ask: what precise, documented fact justifies this word? The share of empty answers sizes your project.
The options, and what they are worth
| Approach | What you get | Who it suits |
|---|---|---|
| Rewrite as precise facts | Compliant under both regimes, and more informative for the buyer: the precise fact is the only form that holds up | Any brand with real efforts to tell |
| Delete unverifiable claims | Quick and safe. A text without a vague promise beats a promise you have to defend | The stock of inherited adjectives, everywhere |
| Certify what deserves it | Keeps the right to a label, at a cost and with a lead time: a product-by-product decision, not a blanket reflex | Flagship products where the label weighs on the purchase |
| Wait for full transposition | Part of the rules already applies in France, and the Commission requires the rest to be transposed: waiting means rewriting later, in a hurry | No one |
Tooling
There is no tool to sell you here: the job is editorial, a word search, a sort, a rewrite. If your product information is already stored in structured fields rather than free text, the inventory takes hours instead of weeks: that is the dividend of the data work demanded by product safety and, soon, by the digital product passport. A brand that has done it can sweep its catalogue with a single query.
The bigger picture
This is not the first time European law has imposed the same discipline under different names: say it precisely, prove it, date it. The reference price did it for discounts, product safety for listings, the green transition does it for promises. Each time, the constraint penalises the vague and favours the factual.
Our reading, consistent across our strategy expertise: these texts do not change what a good brand should have been doing, they make costly what others were doing in its place. The 27 September date is in our compliance calendar, along with the ones that follow.
Sources
The verifiable claims in this article link to their primary source, consulted on 12 August 2026 and checked again on 24 September 2026. We do not cite a source we have not read.
- Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition, article 4 (transposition and application), article 6 (addressees), recital 12 and annex (points 2a, 4a, 4b and 4c). View
- EUR-Lex, national transposition measures for Directive (EU) 2024/825, three measures notified by France. View
- European Commission, Representation in France, notice asking France to transpose the directive on empowering consumers for the green transition, 28 May 2026 (in French). View
- French Consumer Code, article L. 121-2, misleading commercial practices, version in force since 28 May 2022 (in French). View
- French Environment Code, article L. 541-9-1, in force since 1 January 2022 (in French). View
- French Environment Code, article L. 229-68, carbon neutrality claims in advertising, in force since 25 August 2021 (in French). View
FAQ
Can I still say “recyclable packaging”?
If it is true, precise and verifiable for the packaging in question, the factual statement remains possible. The risk starts when the word outgrows its fact: “recyclable product” for a product where only the cardboard is, which is exactly the whole-product claim the directive targets. Say what is recyclable, and keep the proof.
My in-house label has been around for years, do I really have to drop it?
If it looks like a sustainability label with no certification scheme or public authority behind it, the directive bans it, and it provides for no transition period. In France, the general rule on misleading practices already applies: a label that misleads is at issue today. Turning it into a graphic element that no longer claims to be a label settles both cases.
What about my archives, old blog posts, old campaigns?
The risk is concentrated on what sells today: product pages, live pages, running campaigns, packaging. Deal with those first. Dated, clearly archived content is a second circle, to revisit over time.
Has carbon offsetting become illegal?
No. Offsetting is not banned. In France today, claiming in advertising that a product is carbon neutral remains possible, provided you make public an emissions assessment, a quantified reduction trajectory and the offsetting arrangements. The directive goes further: it bans claiming that a product is neutral or has a reduced impact on the basis of offsetting, while still allowing you to publicise your investments in projects, including carbon credit projects, without deriving product neutrality from them.
Can Dotsland help?
Yes. An inventory of claims across catalogue, campaigns and templates, a three-pile sort, a rewrite into precise facts, and a locked-down review of new listings. It is part of our strategy expertise. Let’s talk, or start by counting the “eco” and “sustainable” in your catalogue.