Companies will need to move away from communication based on storytelling alone and towards communication based on verifiable, measurable and transparent statements.
By the end of March, all EU countries must implement the European Directive 2024/825, known as the Empowering Consumers for the Green Transition Directive, into their respective sets of rules. The rules will take effect on 27 September 2026, and companies will need to review their environmental and social sustainability claims by that date.
The Directive addresses two main issues. On the one hand, it tackles greenwashing by including environmental and social claims among misleading commercial practices (amending Directive 2005/29/EC). On the other hand, it strengthens consumer protection against planned obsolescence, especially in relation to product durability, including digital products (amending Directive 2011/83/EU).
Examples of practices that will no longer be allowed, or will be significantly restricted, include:
❌ Generic environmental claims such as “environmentally friendly”, “eco-friendly”, “green”, “nature’s friend”, “ecological”, “environmentally correct”, “climate friendly”, “gentle on the environment”;
❌ The use of sustainability labels that are not based on approved certification schemes or established by public authorities;
❌ Advertising focused exclusively on carbon offsetting strategies;
❌ The promotion of goods with planned obsolescence, or communications encouraging consumers to replace consumables earlier than necessary;
❌ Communications presenting non-essential software updates as necessary.
The aim is to make environmental communication about products, services, processes and organisations clearer and more transparent, so that consumers can make more informed choices.
Green claims: what changes for companies
Companies will need to move away from communication based on storytelling alone and towards communication based on verifiable, measurable and transparent statements. In this respect, the Empowering Consumers for the Green Transition Directive amends Articles 6 and 7 and Annex I of Directive 2005/29/EC on unfair business-to-consumer commercial practices, by banning or restricting practices linked to greenwashing.
In practical terms, one key point changes for businesses: it is no longer enough to look sustainable; they must be able to prove what they say.
The main greenwashing techniques targeted by the Directive are summarised below.
A few practical examples
If we look at the “part for the whole” technique:
❌ It is prohibited to market a product marketed as “made with recycled material” giving the impression that the entire product is made of recycled material, when in fact only the packaging is made of recycled material.
❌ It is prohibited when a trader gives the impression that it is only using renewable energy sources when, in fact, several of the trader’s business facilities still use fossil fuels.
If we look at the “obviousness” technique:
❌ It is prohibited to claim that a particular brand of bottled water is gluten-free or to claim that paper sheets do not contain plastic or that a product contains no palm oil when palm oil has never been one of its ingredients.
If we look at the “vagueness” technique:
❌ It is prohibited to state only “climate-friendly packaging”;
✅ A statement such as “100 % of energy used to produce this packaging comes from renewable sources” would not be prohibited, provided it can be substantiated.
What can I do if I want to communicate my sustainability strategy?
First of all, one clarification: this Directive is not intended to prevent companies from promoting their investments in environmental initiatives, including carbon credit projects. What it does require is that these investments are communicated in a way that is not misleading.
For example, if a company supports reforestation projects but has not yet started a plan to measure and reduce its emissions, it may present that initiative as support for a place or a project, but not as evidence of climate neutrality. The issue is not the reforestation project itself; it is the improper use of that project to support absolute or misleading climate claims.
We know that greenwashing does not always stem from deliberate intent. It often comes from limited internal expertise or from speed. But even so, inaccurate communication can still create reputational, financial and legal risks, as well as possible penalties.
Here are a few steps you can follow:
- Clarify the company’s position
Define internally which environmental issues are genuinely a priority and which medium- and long-term objectives you want to achieve.
- Build a realistic strategy
Align objectives, available resources and concrete actions. Without this step, communication risks moving faster than the substance behind it.
- Measure what you do
From the outset, identify the indicators, data and reference standards you will use, such as the GHG Protocol, SBTi or TNFD.
- Communicate only what you can prove
Choose messages, channels and formats based on verifiable evidence, not on aspirational wording.
- Review text and visuals before publication
A final check on the robustness of your claims helps reduce the risk of errors, disputes and reputational damage.
For companies, this means one simple thing: environmental communication needs method, data and clear governance.
LUCAS is Etifor’s five-step approach, designed to help organisations measure, manage and communicate nature-related risks and opportunities in line with the main scientific standards and international frameworks. Find out more.