27 September 2026: the EU anti-greenwashing rules start to apply
Officially known as the Empowering Consumers for the Green Transition (ECGT) Directive, a new European law starts applying on 27 September 2026 and changes how brands may talk about their environmental impact. The aim of the directive is simple: sustainability claims need solid proof, those that cannot be backed should be taken down. The rules apply to products already on the market, with no transition period. National consumer authorities can order content withdrawn, impose corrective publications and fine (at least 4% of turnover in cross-border cases). In practice the faster cost is visibility: marketplaces will suppress non-compliant listings long before any authority looks at them. Yet this aggressive cleanup creates a powerful opportunity: by clearing away unsubstantiated claims, the directive gives brands with legitimate, verifiable claims a clear stage to win consumer trust and lead the market.
Who is concerned by this?
Any company selling to consumers in the EU, whatever the size of the company or the location of the headquarters. The new directive covers every consumer-facing message: websites, product pages, marketplace listings, product feeds to Google, Amazon and Meta, paid ads, social posts, packaging and even product or range names. The Commission’s Q&A is explicit that product and brand names can constitute claims if they create an environmental association for the average consumer, and a trademark does not protect them.
What does this mean in practice?
A few things are banned outright:
- Generic claims: words such as “eco-friendly”, “green”, “sustainable”, “biodegradable”, “climate-friendly” or “energy efficient” may no longer be used on their own. They are allowed only if the product holds one of three recognised marks (the EU Ecolabel, an officially recognised national ecolabel such as Blue Angel or Nordic Swan, or top performance under EU law such as the highest energy classes).
- Unverified labels: any label that is not backed by an independent, third-party certification scheme or established by public authorities. Home-made “responsible choice” or “eco-designed” badges fall into this category.
- Carbon-neutral or climate-compensated claims: any claim based on buying offsets, including “carbon neutral delivery” at checkout, in shipping options and in order emails.
What is a “generic claim”?
A generic claim is a claim that does not address the following three questions in specific enough terms on the same medium where it appears:
- On what exactly is the claim being made? Specifying the exact scope of the environmental claims being made (e.g. recycled content of the bottle, energy consumption in use) rather than the product as a whole
- How is it being measured? Specifying the exact method and boundaries within which the claim is made (e.g. carbon footprint per unit being calculated under ISO14067 and covering cradle to gate).
- Proven by what? The evidence behind the claim, available and current: a certificate, a registration (for instance EPREL for the energy label), a test report or an audited assessment. Independent third-party verification is mandatory for sustainability labels and for future commitments, not for every product fact, but the proof must exist and be producible on request.
A claim that can answer these three questions on the same screen is a specific claim. Generally speaking, if the medium has no room for the claim to be backed, then the Directive states that the claim should not be made.
What if my company has invested for years in its sustainability strategy?
Then this is your moment, provided the investment can be shown at product level. The directive does not remove environmental claims from the market; it removes vague and unproven ones, and it forces every competitor to be precise. That favours companies that have something precise to say. Years of work only become a visible advantage, though, once they are translated into facts a consumer can see: a company-level report, certification or net-zero plan does not, on its own, allow a product to call itself “eco-friendly”. For these companies the priority is a content strategy built on three levers: a precise vocabulary handed from the sustainability team to marketing, so that every claim carries its aspect, its measure and its proof; product pages and A+ modules that carry the detailed, substantiated claims the short formats cannot; and feeds enriched with the environmental attributes and recognised certifications the platforms can display, so that proof travels into the places consumers actually see.
What are the immediate implications for advertisers?
- Market place listings, starting with Amazon: Amazon has formalized its requirements for European marketplaces: the company requires the removal of all generic environmental claims (“eco-friendly”, “green”, “sustainable”) from titles, bullet points, and visuals, and flags non-compliant content directly in sellers’ Account Health dashboards. On a marketplace, a non-compliant title or bullet point leads to listing suppression. During Q4 peak activity, this operational block by the algorithm poses an immediate financial risk.
- Product feeds and product pages: Product feeds are directly exposed. Titles, descriptions, bullets, highlights and images pushed to Google, Amazon, Meta, ChatGPT Shopping and marketplaces are B2C commercial communication. The Commission requires the justification of a claim to appear on the same medium, hence a truncated title or product card cannot carry it. Feeds are also the least reviewed channel (PIM content, translations, AI enrichment, duplicated across thousands of SKUs), and we expect platforms to tighten moderation on environmental wording right before Q4, with item disapprovals and listing suppressions. This is our assessment, not a platform announcement.
- Websites and social channels: Company claims and commitments on sustainability need to be reviewed to ensure that every communicated claim has an independently verified plan behind them.
- Paid Search: Paid search deserves particular attention. Bidding on a query such as “green beauty products” is not in itself a claim, but the ad that answers it can be. The risk is compounded by automation: automatically created assets and AI-generated headlines are built from advertisers’ landing pages and existing copy, and can reproduce a “green” or “eco” from a page heading as a new headline in a live ad. Google’s terms updated on 1 July 2026 make the point explicitly: the advertiser remains responsible for reviewing, approving or removing automatically generated assets. In practice this means negative-word controls in asset generation, scheduling a review of automatically created assets already running, and having landing pages cleaned so the machine has nothing generic to learn from.
How can Cosmo5 help?
We have developed technology to help brands move from scan to proof across every digital channel.
- Scanning: a rapid, multilingual scan of feeds, listings, paid media and product pages, including product and range names, flags high-risk claims in days.
- Claim-evidence register: we classify claims by risk, and work with your sustainability teams to map certifications and new mandatory information into the platforms’ structured fields.
- Content enrichment: Once your sustainability and legal teams validate the facts; we make sure they travel intact to every screen.