EU green-claims rules for fashion and textile brands: what you can and can’t say

Published 9 July 2026 · Directive (EU) 2024/825 · General information, not legal advice

This is general information to help you screen your own copy — not legal advice. A flag here is a well-founded warning, not a ruling. Only the Court of Justice of the European Union (CJEU) can interpret the directive with binding force, and the European Commission’s guidance on it is non-binding. Where money or reputation is at stake, take the cited provision to qualified counsel before you act.

Why fashion is squarely in scope

Two reasons. First, apparel marketing depends on mood words — a rail labelled “conscious”, a “responsible” capsule, a hang-tag that says “kinder to the planet”. Those are generic environmental claims with nothing behind them, and generic claims are the exact target of the new rules. Second, the sector already draws regulator attention. National consumer authorities across the EU have run coordinated sweeps of clothing websites; the Netherlands’ ACM published sustainability-claim guidance and pushed brands to drop unqualified terms; the UK’s CMA opened cases against named fashion retailers under its Green Claims Code. The directive turns much of that case-by-case pressure into a bright-line ban.

Directive (EU) 2024/825 — the “Empowering Consumers for the Green Transition” directive — amends the Unfair Commercial Practices Directive (2005/29/EC). It adds new entries to Annex I of the UCPD, the list of practices considered unfair in all circumstances, and tightens the general misleading-actions rules in Article 6. It entered into force on 26 March 2024, member states must transpose it by 27 March 2026, and it applies from 27 September 2026. There is no old-stock exemption, so swing tickets, care labels and product pages already printed are in scope.

Trap 1: blanket words on hang-tags and product pages

very likely banned A single word doing all the work — “sustainable”, “eco”, “green”, “conscious”, “responsible”, “planet-friendly” — with no product-level evidence next to it. Under Directive (EU) 2024/825 this is a generic environmental claim, and making one without demonstrated, recognised excellent environmental performance is added to Annex I as banned outright (the site tracks this as Annex I point 4a). It does not matter that the garment is genuinely better than average. If the word is vague and the proof isn’t there and accessible, it’s the practice the rule names. Filter names on a PDP (“Shop sustainable”), a collection title (“The Conscious Edit”), and hang-tag copy all count as claims.

Trap 2: “made from recycled materials” with no share or scope

substantiate it “Recycled” is not a banned word. But “made from recycled materials” on a garment that is mostly virgin fibre, or where only the lining or the trims are recycled, is a half-truth — a true fact used to give a misleading overall impression. That is caught by Article 6 of the UCPD (misleading actions). The fix is specifics: state the material, the percentage, and what it covers. “Outer shell: 60% recycled polyester” is a claim you can stand behind; “made with recycled materials” splashed across a product mostly made of something else is not. Hold the evidence — supplier certification, a bill of materials — and put the qualification on the same medium as the claim, not buried in a footnote three clicks away.

Trap 3: self-invented sustainability labels and scores

very likely banned The in-house eco-badge is out. Displaying a sustainability label or scoring that isn’t based on a recognised certification scheme and isn’t set by a public authority is added to Annex I as banned in all circumstances (the site tracks this as Annex I point 2a). For fashion that means a brand’s own leaf-rating, a “sustainability index” out of 100, a self-designed “eco-score” on the swing ticket, or a made-up seal that looks like a certification but is really just your own marketing. A genuine third-party certification you actually hold — and can evidence — is different. Your own logo dressed up as a standard is the thing the rule kills.

Trap 4: “carbon neutral” garments built on offsets

banned if it rests on offsets A “carbon neutral”, “climate positive” or “CO₂-compensated” T-shirt whose basis is buying carbon credits is banned in all circumstances from 27 September 2026 (the site tracks this as Annex I point 4c) — the quality of the credits gives no defence. This one trips up brands who genuinely fund good projects. You can keep funding offsetting and report it honestly and separately. What you can’t do is put “carbon neutral” on the product on the strength of it. A claim about a real, measured cut in your own emissions is a different thing and stays claimable with proof.

What a compliant claim looks like instead

The pattern is the same every time: swap the vague virtue word for a specific, evidenced, product-level statement.

• Not “sustainable dress” → “Made with 100% GOTS-certified organic cotton” — a named, held certification tied to the actual material.
• Not “eco-friendly jacket” → “Shell woven from 60% recycled polyester (post-consumer)” — the share and the scope, both stated.
• Not “our conscious collection” → name the specific attribute each item actually has, per product, rather than a mood label across a rail.
• Not “carbon neutral tee” → “28% lower emissions per garment than our 2021 baseline, independently verified” — a dated, evidenced reduction, with offsetting reported separately if you do it.

The test for any line of copy: is it specific (a named attribute, not a vibe), is it true and provable (you hold the evidence), and is the qualification on the same medium as the claim? Blanket words fail the first test on their own. That’s why the whole industry’s go-to vocabulary needs a rewrite before the deadline, not a light edit.

How this sits alongside the wider fashion-greenwashing work

Directive (EU) 2024/825 is the adopted, in-force instrument with the 27 September 2026 date — it’s what binds you. Around it sits a separate strand of work: the proposed Green Claims Directive, which would add ex-ante verification of explicit environmental claims, is a distinct proposal and, as of 9 July 2026, is not in force — don’t plan around a date it doesn’t have. Textile-specific rules are also coming through the Ecodesign for Sustainable Products Regulation and Digital Product Passport work, and national regulators (ACM, CMA and others) continue to police fashion claims under existing consumer law. For copy you’re shipping now, the one that matters is 2024/825 and its September 2026 application.