EU Directive 2024/825: What changes for sustainability claims and labels
Today, consumers are paying increasing attention to the impact of their purchasing decisions. Transparency, authenticity and responsibility have become essential criteria, and consumers no longer wish to be misled by vague or misleading sustainability claims. Companies that communicate their environmental commitments must now go beyond slogans and demonstrate their actions in a concrete and objective manner.
It is in this context that the European Union adopted Directive (EU) 2024/825, which focuses on strengthening consumer rights in support of sustainable consumption. Its full title is “Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and better information.”
Why this directive?
The directive aims to ensure that consumers receive clear, reliable and comparable information at the point of sale regarding the durability and reparability of goods, as well as their rights relating to legal guarantees. It also strengthens consumer protection rules against greenwashing and planned obsolescence.
More broadly, the directive seeks to protect consumers from misleading communications relating to the environmental, social, or circular aspects of a product, whether goods or services.
The directive amends two existing pieces of EU consumer law: the Consumer Rights Directive (2011/83/EU) and the Unfair Commercial Practices Directive (2005/29/EC). Its objective is to adapt the EU’s horizontal consumer law framework to the requirements of the green transition and to encourage changes in purchasing behaviour that contribute to the climate and environmental objectives of the European Green Deal.
As such, the directive targets unfair commercial practices that mislead consumers and prevent them from making informed and genuinely sustainable choices. These include common practices such as:
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- premature product obsolescence
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- misleading environmental claims (“greenwashing”)
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- non-transparent or non-credible sustainability labels
Implementation timeline
By 27 September 2025 at the latest, the European Commission will adopt implementing acts defining the design and content of the harmonised label relating to commercial durability guarantees offered by producers, as well as the harmonised notice relating to the legal guarantee.
By 27 March 2026 at the latest, Member States must transpose the directive into their national law.
The directive will apply from 27 September 2026.
This date represents a key milestone for companies, which will be required to fully comply with these new obligations.
Failure to comply with may result in sanctions, including financial penalties, reputational damage and, depending on national transposition measures, potential impacts on eligibility for certain public procurement procedures or calls for tender.
Key new provisions
Among the most significant changes introduced by the directive, the following practices will be added to the list of prohibited commercial practices, which companies will be required to avoid:
- practices relating to premature obsolescence, meaning misleading consumers about the durability of a product that has been deliberately designed to become obsolete prematurely;
- the use of “generic” environmental claims such as “environmentally friendly”, “eco-friendly” or “biodegradable” where these claims are not substantiated by robust evidence;
- the display of sustainability labels that are not based on an independent certification scheme or established by a public authority;
- claims relating to the future environmental performance of a product where they are not supported by a credible and verifiable implementation plan;
- the promotion of irrelevant product characteristics in order to mislead consumers into believing that a product is more sustainable than others on the market;
- claims of carbon neutrality based on the purchase of carbon credits or the offsetting of emissions outside the value chain;
- environmental claims that merely reflect compliance with legal requirements already in force;
- environmental claims made about a product or a company as a whole, when they only apply to a specific aspect of the product or to certain activities. [1]
In addition, Article 2 of the directive inserts a new Article 22a into Directive 2011/83/EU, creating two new instruments: a harmonised notice and a harmonised European label, intended to ensure consistent and easily understandable information for consumers across the EU.
Expected impact
The prohibition of these practices imposes new positive obligations on companies, requiring them to provide consumers with more accurate, verifiable and comparable information on the sustainability and environmental impact of their products.
For example, if a company announces its intention to achieve carbon neutrality by a certain date, it will now be required to publish a detailed implementation plan setting out clear, measurable, publicly accessible and verifiable commitments and objectives, subject to verification by an independent third party.
Similarly, where comparisons are made based on social characteristics or aspects related to product circularity, the directive requires companies to publish detailed information explaining the basis for such comparisons. In order to enable consumers to make informed decisions, companies must apply objective standards when making these comparisons, relating for example to product durability, reparability or recyclability.
Overall, the directive will require companies to operate with a significantly higher level of transparency, particularly with regard to environmental claims, in order to create a fairer and more trustworthy market for consumers.
In summary, the directive will have an impact across three key areas:
- Consumers: greater transparency and increased trust in environmental claims;
- Companies: an obligation to adapt communications, apply rigorous standards and consider the use of credible labels;
- The market: a shift towards genuine sustainability positioning, rather than superficial green marketing.
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Link with B Corp
The European directive reshapes the conditions under which sustainability labels may be used. It requires such labels to be based on clear rules of transparency and credibility, with external oversight carried out by a genuinely independent body.
Until now, B Corp certification has been based on a model in which B Lab, the organisation behind the standard, carried out the assessment and verification itself, an approach that no longer fully meets the new European requirements regarding independence.
In response to this new regulatory context, B Lab has initiated an evolution of its model. The recently published B Corp standards incorporate these principles, notably through the progressive introduction of verification by an independent third-party body.
Beyond certification itself, it is above all the environmental claims used in corporate communications that will be subject to increased scrutiny. Whether general (“sustainable”, “green”, “eco-friendly”) or product-specific, such claims will need to be justified, precise and supported by robust evidence.
In practice, this means that companies will need to thoroughly review their marketing messages, assess the robustness of the claims they use and, where necessary, adapt them. Transparency and precision are no longer simply good practice, they are becoming regulatory obligations. [2]
If you would like to learn more about the new B Corp standards and their alignment with the Empowering Consumers for the Green Transition framework, please contact us.
References:
[1] https://earth.org/all-you-need-to-know-about-the-eus-new-greenwashing-directive/
Edwige Filot