Self-made eco-labels are banned: what counts, and what to do

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.

The exact rule

Directive (EU) 2024/825 adds Annex I point 2a to the Unfair Commercial Practices Directive (2005/29/EC), banning:

“Displaying a sustainability label that is not based on a certification scheme or not established by public authorities.”

This sits in the list of practices that are unfair in all circumstances, so there is no case-by-case defence. The point is to stop brands minting their own official-looking green seals that a shopper can’t distinguish from a real, independent certification.

What counts as a “self-made” label

A sustainability label caught by the ban is essentially any badge, seal, logo or mark suggesting environmental credentials that is not:

• based on a third-party certification scheme (an independent scheme that assesses against published criteria), or
• established by public authorities (an official label such as the EU Ecolabel).

So these are the danger signs it’s a self-made label:

• You created the badge and its criteria in-house.
• Nobody independent certifies against it.
• It looks like a seal or a mark of approval, not just a plain sentence.

What to do about your badge

1. Audit every mark on your packaging and site. List each badge, seal and logo and ask: is it from an independent scheme or a public authority? If neither, it’s exposed.
2. Replace it with a certification you genuinely hold. If your product qualifies for a recognised scheme (EU Ecolabel, an ISO 14024 Type I ecolabel, a credible independent standard relevant to the claim), use that mark instead, and only where you actually hold it.
3. Or remove it and state the fact plainly. You can still say, in words, what you actually do (“packaging made with 80% recycled content”), you just can’t wrap it in a home-made seal that mimics certification.

One nuance: a plain textual statement of a real, provable fact is different from a label or seal. The ban targets the label form, the badge that implies independent approval. Substantiated words about what you do are governed by the substantiation rules, not this outright ban.