# Directive (EU) 2024/825 (ECGT) — operative clauses for claim-checking

Source: Directive (EU) 2024/825 of 28 February 2024 amending Directives 2005/29/EC (UCPD)
and 2011/83/EU (CRD) — "Empowering consumers for the green transition."
ELI: http://data.europa.eu/eli/dir/2024/825/oj · EUR-Lex CELEX:32024L0825.
Transposition deadline 27 March 2026; **applies from 27 September 2026**.
(Verbatim excerpts; chunked for retrieval. Each chunk is a citable clause.)

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## DEFINITION — environmental claim
"'environmental claim' means any message or representation which is not mandatory under Union or
national law, in any form, including text, pictorial, graphic or symbolic representation, such as
labels, brand names, company names or product names, in the context of a commercial communication,
and which states or implies that a product, product category, brand or trader has a positive or zero
impact on the environment or is less damaging to the environment than other products … or has
improved its impact over time." (Art. 1, adding Art. 2(o) to Directive 2005/29/EC)

## DEFINITION — generic environmental claim
"'generic environmental claim' means any environmental claim made in written or oral form … that is
not included on a sustainability label and where the specification of the claim is not provided in
clear and prominent terms on the same medium." (Art. 2(p))
Recital examples of generic claims: "'environmentally friendly', 'eco-friendly', 'green', 'nature's
friend', 'ecological', 'environmentally correct', 'climate friendly', 'gentle on the environment',
'carbon friendly', 'energy efficient', 'biodegradable', 'biobased'."

## DEFINITION — recognised excellent environmental performance
"'recognised excellent environmental performance' means environmental performance compliant with
Regulation (EC) No 66/2010 [EU Ecolabel] … or with national or regional EN ISO 14024 type I
ecolabelling schemes officially recognised in the Member States, or top environmental performance
in accordance with other applicable Union law." (Art. 2(s))

## PROHIBITION — Annex I point 4a: generic claims without proof
"Making a generic environmental claim for which the trader is not able to demonstrate recognised
excellent environmental performance relevant to the claim." (Annex I, new point 4a — banned in all
circumstances.)
→ Applies to a bare "eco-friendly" / "green" / "sustainable" tag with no recognised excellent
environmental performance demonstrated.

## PROHIBITION — Annex I point 4b: partial claim presented as whole
"Making an environmental claim about the entire product or the trader's entire business when it
concerns only a certain aspect of the product or a specific … activity of the trader's business."
(Annex I, new point 4b.) Recital example: marketing a product as 'made with recycled material' giving
the impression the entire product is recycled when in fact only the packaging is.

## PROHIBITION — Annex I point 2a: unqualified sustainability labels
"Displaying a sustainability label that is not based on a certification scheme or not established by
public authorities." (Annex I, new point 2a.) A sustainability label must rest on a third-party
certification scheme with objective, independent monitoring, or be established by a public authority;
self-declared private seals are prohibited.

## PROHIBITION — Art. 6(2)(d): future/forward-looking environmental claims
"Making an environmental claim related to future environmental performance without clear, objective,
publicly available and verifiable commitments set out in a detailed and realistic implementation plan
that includes measurable and time-bound targets … regularly verified by an independent third-party
expert, whose findings are made available to consumers." (amending Art. 6(2) of Directive 2005/29/EC)

## SUBSTANTIATION principle
An environmental claim that states or implies a specific characteristic (e.g. a recycled-content
percentage) must be accurate and verifiable. Where a claim relies on a certified material attribute,
the substantiating evidence must correspond to the specific product/shipment, not merely to the
supplier's general capability.