5 steps on how to prepare for the EU Greenwashing Directive: A Practical Guide for 2026

The European Commission has released a detailed Q&A guidance document on how to interpret and apply the Greenwashing Directive’s rules on environmental claims and circular economy practices. EU Member States will be required to enforce these rules from 27 September 2026.

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What is greenwashing?

Greenwashing is the practice of giving a false impression of the environmental impact or benefits of a product, which can mislead consumers. More specifically, greenwashing is when a company exaggerates or misrepresents how environmentally friendly it is. This can happen through vague claims (“eco‑friendly”), leaving out important lifecycle impacts, or making statements that can’t be verified. In 2025, UK regulators (CMA, FCA, ASA) are actively cracking down on this.

To ensure clearer and more reliable sustainability information, the EU will ban:

• broad environmental claims that cannot be verified
• claims of neutral, reduced, or positive environmental impact when they rely on offsetting rather than actual reductions
• sustainability labels that are not based on approved certification systems or created by public authorities

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The New Green Claims Guidance

The Guidance sheds light on several core aspects of the new requirements, including the types of business communications that fall under the greenwashing rules, the implications for brand names and trademarks, and how the rules should be applied to existing products and claims. Although it does not carry legal force—and some Member States may interpret parts differently—it will likely serve as an important reference point for national authorities when implementing and enforcing the rules.

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What steps to take with the new green claims? 

Before diving into the specific actions, it’s important for companies to understand that the new EU green claims rules will affect multiple parts of their business — from marketing and packaging to branding, sustainability messaging, and long‑term environmental commitments. The Guidance makes it clear that compliance isn’t just about avoiding obvious false claims; it’s about ensuring that every environmental message is accurate, verifiable, and presented in a way that does not mislead consumers. The steps below outline what businesses should start doing now to prepare for full enforcement in September 2026.

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1. Update your current marketing materials and product packaging.  

The Guidance explains that after 27 September 2026 there will be no extra transition period. This means that even products already in stores or in the supply chain must meet the new rules.

The Guidance says companies can still fix existing packaging by:

• covering or correcting claims with stickers
• adding extra information at the point of sale

It also notes that national authorities will focus their enforcement on the most serious issues.

Companies should therefore review all environmental claims on current packaging and marketing now, and make updates where needed.

Read more about communication about sustainability here.

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2. Think carefully about which communications fall under the rules

Not every corporate message is covered by the green claims rules, but companies should still check which of their communications might be reviewed by national authorities.

There are two types of practices under the Greenwashing Directive:

• Blacklisted practices: These are always banned. For example, claiming a product is “carbon neutral” based on offsets instead of real emission reductions. Authorities do not need to prove that consumers were misled.
• Case‑by‑case practices: Other claims may be misleading depending on the context. Authorities must assess whether the claim could influence an average consumer’s decision.

The rules apply only to business‑to‑consumer (B2C) communications — anything directly linked to promoting or selling a product to consumers. Business‑to‑business (B2B) communications are generally outside scope.

Importantly, corporate sustainability reporting (including CSRD reports) is usually not covered, because it is aimed at investors. But if a company uses information from its sustainability report in consumer‑facing marketing, then it does fall under the rules.

A recent Spanish case (Iberdrola v. Repsol) shows that the boundary is not always clear. Even statements published on an investor‑focused website may still influence consumers and therefore be assessed under consumer protection rules.

Finally, even in B2B contexts, environmental claims are not risk‑free. Member States may extend the new rules to B2B practices, and misleading environmental claims are already prohibited under existing advertising laws.

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3. Check all parts of your branding for hidden green claims

The Guidance explains that environmental claims are not only made through words — they can also be implicit. Images, colours, symbols, and the overall look of your branding can give consumers the impression that a product is environmentally friendly. These implicit claims are also regulated.

Some visuals can even trigger stricter rules. For example, using a green leaf or water drop next to sustainability‑related text may be seen as a sustainability label, which is only allowed if it comes from a public authority or an approved certification scheme.

Whether an implicit claim is misleading depends on the context. The key question is whether the overall impression of your packaging or marketing could mislead an average consumer about environmental benefits and influence their purchase decision.

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4. Make a sustainability label that is based on certification or established by public authorities

The Greenwashing Directive introduces new rules for “sustainability labels.”  These labels include any voluntary trust mark or quality mark — not already created under EU law — that promotes a product, process, or business based on its environmental or social characteristics. This means companies can only use sustainability labels if they are based on a 'Certification scheme' or established by public authorities. The Guidance explains what a valid certification scheme must look like.

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5. Make a future-focussed claim with a dependent, expert verification

The Greenwashing Directive bans future environmental claims unless they are backed by clear, objective, public, and verifiable commitments and targets. These must be described in a realistic implementation plan that explains how the company will achieve them and what resources will be used. The Guidance also says that any future‑focused claim must be checked by an independent expert with environmental experience and no conflicts of interest. Companies should review their future goals and claims, and make sure they have a public, third‑party‑verified plan—for example, from an external consultant or auditor.

Future‑focused sustainability claims are about firm commitments that you need to be able to prove. With our online tool, you gain clear insight into your CO₂ footprint, targets and progress, and turn ambitions into a concrete, verifiable plan. This helps you ensure that your future claims are realistic, measurable and ready for independent expert verification, exactly what the Greenwashing Directive requires. No complex processes, just clear steps that help you take action today and build trust with customers and regulators. Want to know if your future claims are compliant? Start with an Impact Scan at Eevery and turn sustainability into credible action.

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Do you have more questions? Contact us or book a demo to see what our platform looks like!