The EU green claims ban from 27 September 2026: what changes for Shopify stores
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Short answer
Directive (EU) 2024/825 (ECGT) adds new practices to the EU "blacklist" of unfair commercial practices in Annex I to Directive 2005/29/EC. Practices on this list are prohibited in all circumstances, with no case-by-case test. From 27 September 2026, national laws in EU Member States must ban generic claims such as "eco-friendly" unless you can show recognised excellent environmental performance. They must also ban "climate neutral" claims based on carbon offsets, self-made sustainability labels and claims about a whole product when only part of it qualifies. For a Shopify store, this covers every text a shopper sees: product descriptions, collections, pages, blog posts, theme texts, translations and image alt text. The dates depend on each country's law. In Poland, the implementing act passed by parliament in September 2026 enters into force on 27 September 2027 (Article 3 of the act). On 10 October 2026 it had not yet been published in the Journal of Laws (Dziennik Ustaw).
What does Directive (EU) 2024/825 change?
The directive amends the Unfair Commercial Practices Directive 2005/29/EC (UCPD) and the Consumer Rights Directive 2011/83/EU. For green claims, the changes are in the UCPD:
- New definitions (Article 2, points (o) to (s) UCPD). An "environmental claim" is any non-mandatory message that states or implies a positive or zero environmental impact, less damage than other products, brands or traders, or an improvement over time. It includes text, images, symbols, labels, brand names and product names. A "generic environmental claim" is one where "the specification of the claim is not provided in clear and prominent terms on the same medium".
- New blacklist points in Annex I UCPD:
- Point 2a: displaying a sustainability label that is not based on a certification scheme and not established by public authorities.
- Point 4a: making a generic environmental claim when the trader cannot demonstrate recognised excellent environmental performance relevant to the claim.
- Point 4b: making an environmental claim about the entire product or the trader's entire business when it concerns only a certain aspect or activity.
- Point 4c: claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.
- Also added: point 10a (presenting legal requirements as a distinctive feature of your offer) and points 23d–23j (durability, repair, software updates and consumables).
- Future performance claims (new Article 6(2)(d) UCPD). A claim about future environmental performance, such as "net zero by 2030", is misleading without "clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan". The plan must be regularly verified by an independent third-party expert, and the findings must be available to consumers.
"Recognised excellent environmental performance" means performance in line with the EU Ecolabel (Regulation (EC) No 66/2010), with an officially recognised EN ISO 14024 type I ecolabel, or top performance under other EU law (Article 2(s) UCPD). Recital 10 gives an example: an "energy efficient" claim can rest on class A under the EU energy label.
Which dates apply?
| Date | What happens | Source |
|---|---|---|
| 6 March 2024 | Directive (EU) 2024/825 published in the Official Journal | EUR-Lex |
| 26 March 2024 | Directive enters into force (20th day after publication, Article 5) | EUR-Lex |
| 27 March 2026 | Deadline for Member States to adopt and publish national rules (Article 4(1)) | EUR-Lex |
| 27 September 2026 | Member States must apply the national rules from this date (Article 4(1)) | EUR-Lex |
| 4 and 24 September 2026 | Poland: the Sejm passes the implementing act (4 September); the Senate makes no amendments and the act is sent to the President for signature (24 September) | Sejm, print 2799 |
| 27 September 2027 | Poland: the implementing act enters into force (Article 3 of the act as passed; not yet published in Dziennik Ustaw on 10 October 2026) | Sejm, text of the act as passed |
According to the European Commission's Questions & Answers (September 2026), from 27 September 2026 the rules also cover existing products and "old stock", and for sustainability labels the directive provides no transition period beyond that date. A directive works through national law, so check the law and its date in each country you sell to.
What wording is risky, and what is more specific?
Recital 9 of the directive lists 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" and "biobased". Recital 12 lists offset-based claims: "climate neutral", "CO2 neutral certified", "carbon positive", "climate net zero", "climate compensated", "reduced climate impact" and "limited CO2 footprint".
A claim is not generic when its specification is clear and prominent on the same medium, which for a Shopify store is the product page. The directive's own example: "climate-friendly packaging" is generic, while "100% of energy used to produce this packaging comes from renewable sources" is specific. A specific claim must still be true and not misleading under the rest of the UCPD.
| Riskier (generic or offset-based) | More specific (must still be true and evidenced) |
|---|---|
| "Eco-friendly T-shirt" | "T-shirt made from 100% organic cotton, certified to [named standard]" |
| "Sustainable packaging" | "Mailer box made from 80% recycled cardboard" |
| "Climate neutral delivery" (via offsets) | Describe the actual measure, such as the transport type. Do not claim neutrality based on offsets. |
| "Made with recycled materials" (only the packaging is recycled) | "Packaging made from recycled paper; the product itself is not" |
| "Our own Green Choice badge" | Use only labels from a certification scheme or a public authority (for example, the EU Ecolabel) |
| "Net zero by 2030" with no published plan | Link to a detailed plan with targets that an independent expert regularly verifies |
Separately, for food, feed and other agricultural products, terms such as "organic", "bio" and "eco" (and their equivalents, such as "ekologiczne" in Polish) are reserved for products that meet the EU organic rules (Regulation (EU) 2018/848, Article 30 and Annex IV).
Where do eco claims hide in a Shopify store?
Claims are rarely in one place. Check:
- Products: title, description, SEO title and meta description, and text metafields (for example "Materials" or "Care" fields).
- Collections: names and descriptions such as "Eco collection" or "Green living".
- Pages and blog posts: About, Sustainability, FAQ and older campaign posts.
- Theme texts: announcement bar, footer, badges, banners and locale strings.
- Translations: each published language separately. A neutral English text can become "umweltfreundlich" or "ekologiczny" after translation.
- Images: leaf icons, badges and alt text. Recital 9 notes that text combined with colours or images can form a generic claim.
- Brand and product names: the Commission's Q&A says brand and product names can be environmental claims if they create an environmental association, decided case by case.
What is the status of the Green Claims Directive?
The Green Claims Directive is a separate proposal, COM(2023) 166, on substantiating explicit environmental claims. It is not law. According to the European Parliament's Legislative Train (updated 20 September 2026, checked 10 October 2026), the Commission announced on 20 June 2025 that it intends to withdraw the proposal, and the trilogue planned for 23 June 2025 was cancelled. The proposal is marked "Blocked" (Council) and is listed as pending in the Commission's 2026 work programme. The ECGT rules above apply whatever happens to it.
What to check in your store
- List every country you sell to and check its national law and date of application.
- Search products, collections, pages, blog posts and theme texts for generic terms.
- Repeat the search in each published translation.
- Remove or replace "climate neutral" style claims that rely on offsets.
- Keep only sustainability labels from a certification scheme or a public authority.
- For claims about part of a product, say which part.
- For future targets, link to a published plan with independent verification, or remove the claim.
- Keep evidence for every claim you keep, and ask your legal advisor to confirm the final wording.
How Lektoro helps (and what it doesn't do)
Lektoro: Green Claims Checker is a Shopify app that reads your store and flags wording commonly considered risky under Directive (EU) 2024/825.
What it does:
- Scans product titles, descriptions, SEO fields and text metafields on every plan. Paid plans also scan collections, pages, blog posts, theme texts and translations in all published languages.
- Shows the exact wording, the rule it matches (for example Annex I point 4a or 4c) and a more specific alternative.
- Uses a claim library in 10 languages: English, German, French, Spanish, Italian, Dutch, Polish, Portuguese, Swedish and Danish.
- Lets you record evidence or exceptions (for example a brand name), keeps an audit log and produces a report you can share with your lawyer.
What it doesn't do:
- It never edits your store. You change the text yourself in the Shopify editor.
- It does not check whether a claim is true.
- It does not scan images, PDFs or texts added by other apps.
- It does not decide whether a claim is lawful in a given country.
Sources
- Directive (EU) 2024/825, OJ L 2024/825, 6.3.2024: Articles 1, 4 and 5, Annex, recitals 9–12 — https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng
- Directive 2005/29/EC (UCPD) — https://eur-lex.europa.eu/eli/dir/2005/29/oj/eng
- European Commission, Questions & Answers on Directive (EU) 2024/825 (September 2026) — https://commission.europa.eu/document/download/3c257883-bb2a-4dd9-a6dc-501d587bb34f_en?filename=faq-empowerting-consumers-gtd.pdf
- European Commission, Sustainable consumption — https://commission.europa.eu/live-work-travel-eu/consumer-rights-and-complaints/sustainable-consumption_en
- European Parliament, Legislative Train: Green Claims Directive (updated 20.09.2026) — https://www.europarl.europa.eu/legislative-train/theme-a-european-green-deal/file-substantiating-green-claims
- Regulation (EU) 2018/848 (organic production) — https://eur-lex.europa.eu/eli/reg/2018/848/oj/eng
- Sejm, legislative process for print no. 2799 (Polish implementing act) — https://www.sejm.gov.pl/Sejm10.nsf/PrzebiegProc.xsp?nr=2799
- Sejm, text of the Polish implementing act as passed on 4 September 2026 (ustawa o zmianie ustawy o przeciwdziałaniu nieuczciwym praktykom rynkowym oraz ustawy o prawach konsumenta), Article 3 — https://api.sejm.gov.pl/sejm/term10/processes/2799/attachment/2799_u3.pdf
Not legal advice. This guide summarises EU rules as of the date above to help you find wording to review. It does not cover every national rule or exception. Ask a qualified legal advisor about your store and your markets.