From 27 September 2026, communicating sustainability in a vague way or without proof stops being a matter of image and becomes a legal risk. That day, the rules of Directive (EU) 2024/825, known as the directive on empowering consumers for the green transition ("Empowering Consumers"), start to apply across the EU. The practical effect: any environmental claim a company puts on a label, a website or an advert will have to be backed by data.
Terms such as "sustainable", "eco-friendly", "carbon neutral", "planet-friendly" or "green" come directly under scrutiny if they are not accompanied by objective, verifiable and accessible evidence. It is the most serious regulatory blow to date against greenwashing.
An important clarification: do not confuse it with the Green Claims Directive
It is worth clearing up a very common confusion. Two different rules are in circulation and they are easy to mix up:
- Directive (EU) 2024/825 (Empowering Consumers): approved, in force and mandatory from 27 September 2026. This is the one we analyse here.
- Proposal for a Green Claims Directive: this was a complementary rule that was going to set the procedure for prior verification of claims. The European Commission withdrew it in June 2025. It is not law and is no longer in the pipeline, so no company needs to prepare to comply with it.
The withdrawal of the Green Claims Directive does not ease the pressure: the substantive obligations on environmental claims live in Directive 2024/825, which does apply. The idea that "there is no longer any anti-greenwashing regulation" is false.
What Directive 2024/825 prohibits exactly
The directive amends the European rules on consumer protection and unfair commercial practices. Its most relevant prohibitions are:
- Generic environmental claims without proof: it is prohibited to use terms such as "ecological", "green" or "environmentally friendly" if you cannot demonstrate recognised, excellent environmental performance.
- "Carbon neutral" based on offsetting: this is the most talked-about change. It is prohibited to claim that a product has a neutral, reduced or positive impact on emissions when that claim is based on offsetting emissions outside the product's value chain. Claims such as "climate neutral", "CO₂ neutral" or "reduced climate impact" will only be admissible if the product's real life-cycle impact justifies them, not because external carbon credits were bought.
- Uncertified sustainability labels: environmental labels that are not based on a recognised certification scheme or established by a public authority are prohibited.
- Misleading durability or repairability claims and undisclosed planned obsolescence.
The real problem is not communicating well, it is being able to prove it
Here is the nuance many organisations are overlooking. The directive does not require companies to stop making environmental communications, but it requires those communications to be verifiable. The difference looks technical, but it has important operational implications.
When a company says it has cut its emissions by 30%, it needs to be able to show where that figure comes from: which methodology was applied, what data supports it, how Scopes 1, 2 and 3 were calculated, which emission factors were used and where the traceable evidence is. When it claims its product is "carbon neutral", it needs a documented life cycle assessment that supports that real impact, not an offset bought without context. How to build that story is covered in our guide to communicating a decarbonisation strategy without greenwashing.
The traceability of environmental data stops being a differentiating argument and becomes a legal requirement.
The penalties: what is at stake
The directive is built into the penalty regime of consumer protection law. For widespread cross-border infringements, the maximum fine must be at least 4% of the company's annual turnover in the affected Member States, or at least EUR 2 million where that turnover information is not available, on top of measures such as the withdrawal of campaigns or a ban on the practice. The exact amount will depend on each country's transposition, which was due to be completed by 27 March 2026.
Beyond the fine, the reputational risk is immediate: from September 2026, any consumer, regulator or competitor can challenge an environmental claim and demand the evidence behind it.
How many companies are really ready?
Few, and not for lack of will, but because for years the ecosystem of tools did not demand that level of rigour. Calculations were done in spreadsheets, reports were written by hand and marketing claims were built on data no one had put to the test. That model does not survive an external verification process.
Sustainability managers find themselves in a scenario where marketing, operations and compliance must speak the same language: the language of data.
From regulatory pressure to a competitive advantage
Some companies will see this directive as a threat, and some will read it as an opportunity. Those that already work with verifiable data, auditable reports and calculation traceability from the activity to the final report will have a real advantage: they will be able to communicate credibly in a market where most will have to temper their messaging.
At Manglai we help sustainability teams consolidate environmental data with full traceability, calculate the carbon footprint using recognised methodologies such as the GHG Protocol or ISO 14064, and generate audit-ready reports. Not as an operational luxury, but as the foundation that makes any claim a company wants to make about its impact defensible.
If you have not yet reviewed which environmental claims your company uses and whether you can back them with data, start by measuring your carbon footprint properly: it is what underpins any credible message from September onwards.
