On 27 September 2026, the ban on generic, unsubstantiated environmental claims under Directive (EU) 2024/825 — the "Empowering Consumers for the Green Transition" directive — became fully applicable across the EU. Terms like "eco-friendly," "carbon neutral," or "green" can no longer be used on packaging or marketing without the kind of recognised, verifiable backing the directive requires.
What's less widely reported is what happened a few months earlier, on 28 May 2026: the European Commission opened infringement procedures against 20 member states for incomplete transposition of the directive. Member states had until 27 March 2026 to transpose it into national law — a deadline a majority of them missed, at least partially.
That gap matters for anyone running a compliance or marketing team across several EU markets. A claim that's clearly banned under the directive's EU-wide wording may still sit in a legal grey zone in a country whose national transposition is incomplete, delayed, or diverges on enforcement detail (penalties, the specific list of restricted terms, who enforces what). Compliance isn't binary at EU scale — it's 27 overlapping timelines.
What we built to track this
We maintain greenwashing-checker.com, a scanner that checks a given page's wording against the terms the ECGT framework restricts or bans outright. The part that took longer to get right wasn't the term-matching — it's keeping the per-country transposition status current enough to be useful, rather than a snapshot from the day the directive was adopted.
In practice that means treating "is this claim compliant" as a question with two layers: the EU-wide baseline (what the directive itself prohibits, applicable since 27 September 2026) and the national layer (has this country actually transposed it, and if not, what's the practical enforcement risk in the meantime). The May infringement wave is a useful real-world marker for that second layer — it's the Commission's own signal of where transposition is lagging, sourced from its official infringement decisions rather than from guesswork.
Why this matters beyond the legal department
For marketing and product teams, the practical takeaway is that "we checked against the directive" isn't the same as "we checked against what's actually enforceable in each market we sell into." A claim can be clean under the EU text and still risky in a country where enforcement bodies are already active on national consumer-protection law, directive or no directive.
We wrote up the specific terms the directive restricts, and how we map claims against them, in our compliance guide. If you're building anything that touches green claims — product pages, ad copy, packaging text — it's worth checking where your target markets actually stand on transposition before assuming the EU-wide deadline is the only clock running.
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