EU Greenwashing Directive: a plain guide for fashion and textile brands
The Green Claims Directive is gone. Directive 2024/825 is what applies to environmental claims from 27 September 2026: what is banned, what you can still say, and how enforcement works.
If you are looking up the green claims directive status in 2026, the key point is that the proposed Green Claims Directive was withdrawn by the European Commission in June 2025. The rules that actually apply are in the Empowering Consumers for the Green Transition Directive (Directive (EU) 2024/825), which has applied since 27 September 2026. So while people still call it the "EU greenwashing directive" or the "green claims directive", Directive 2024/825 is the one fashion and textile brands need to work to.
- March 2023Green Claims Directive proposed
- June 2025The Commission withdraws it
- 27 March 2026Member States transpose Directive 2024/825
- 27 September 2026The rules apply
Does the EU greenwashing directive apply to you?
If you sell clothing, footwear or accessories directly to consumers in the EU, the Empowering Consumers for the Green Transition rules apply to your consumer-facing environmental claims.
It does not matter whether your company is large or small, or whether it is based inside or outside the EU. If you sell to EU consumers, your environmental marketing can fall within the rules.
This covers claims made through:
- Product pages
- Websites
- Advertising
- Packaging
- Hang tags
- Product labels
- Other consumer-facing marketing
Pure business-to-business transactions, such as selling clothing wholesale to a retailer, are outside the consumer-facing scope. However, if that retailer then makes environmental claims to its own customers, those claims are covered.
EU Member States had until 27 March 2026 to transpose the directive into national law. The rules themselves apply from 27 September 2026. Enforcement and penalties are handled at national level, so the exact consequences can vary between countries.
What is banned from 27 September 2026?
The EU greenwashing directive is often discussed as a ban on "greenwashing", but the practical rules are more specific. Four areas are particularly relevant to fashion and textile brands.
1. Generic environmental claims without proof
Broad claims such as "green", "eco-friendly" or "sustainable" are banned unless you can show recognised excellent environmental performance, for example through the EU Ecolabel or an officially recognised ecolabel. Having some evidence is not enough on its own. The issue is not the word itself. It is whether the claim gives consumers a broad impression of environmental benefit that the business cannot substantiate.
There are already real examples of regulators acting against this type of marketing.
In 2024, the UK's Competition and Markets Authority secured undertakings from Boohoo over environmental claims connected with its "Ready for the Future" range. The CMA raised concerns that consumers could be given an inaccurate impression about the environmental characteristics of products in the range.
In Italy, the competition authority AGCM fined SHEIN €1 million in August 2025 over misleading environmental claims associated with its "evoluSHEIN" collection and other sustainability communications.
These cases predate the new rules. They show that vague environmental claims were already an enforcement issue under existing consumer law.
2. Climate-neutral claims based on offsetting
The new rules also target claims that suggest a product or company has a neutral, reduced or positive climate impact when that conclusion is based on compensating emissions elsewhere.
In practical terms, buying carbon credits does not automatically make a product "climate neutral" or "carbon neutral".
There are already examples of this being challenged.
In Germany, the Federal Court of Justice ruled in 2024 on advertising using the term "klimaneutral". The court found that the claim could be misleading where the advertising did not make clear whether neutrality was achieved through actual emissions reductions or through offsetting.
In another German case, Deutsche Umwelthilfe challenged climate-neutral advertising by DWS, arguing that consumers could be misled about what the claim actually represented. The case formed part of a wider wave of challenges to offset-based environmental marketing.
The broader lesson for fashion brands is that "carbon neutral" is not a simple marketing shortcut. You need to be precise about what has actually been reduced, what has been compensated and what the claim covers.
3. Unrecognised sustainability labels
The directive also restricts sustainability labels that are not based on an appropriate certification scheme or established by public authorities.
This matters for fashion brands that use their own sustainability logos, badges or rating systems. A label can create the impression of independent environmental certification even when it has been created and assessed entirely by the company itself.
There are already relevant fashion examples.
In the Netherlands, the consumer authority ACM investigated H&M's environmental claims, including the use of "Conscious" and "Conscious Choice" labels. The regulator found that some of the claims were insufficiently clear and substantiated, and H&M subsequently changed its sustainability communications.
In Italy, AGCM also investigated environmental claims and labelling used by fashion companies, including claims presented through sustainability-related product information. These cases illustrate the wider regulatory focus on whether environmental labels give consumers an accurate and verifiable impression.
Under the new EU rules, brands should be particularly careful with in-house badges that look like independent certification.
4. Unverified future environmental promises
Future-facing claims can also create problems.
Statements such as "climate neutral by 2030", "net zero by 2040" or "100% sustainable by 2030" make a commitment about future environmental performance.
The issue is not that companies cannot set environmental targets. It is whether there is a credible, measurable basis behind the promise.
For example, the Dutch ACM has previously challenged misleading sustainability claims by companies, including claims about future environmental improvements where consumers were not given enough information to understand what was actually being promised.
The UK CMA has also investigated environmental claims involving future commitments under existing consumer law, including claims by fashion and retail businesses.
Under the new rules, future environmental claims need to be supported by a clear and realistic implementation plan and monitoring of progress.
The safest approach is to make future claims specific: define the target, the baseline, the timeframe, and how progress will be measured.
What can you still say?
For fashion, the EU greenwashing directive does not mean you have to stop talking about sustainability. The difference is between a broad claim and a specific, evidence-based claim.
Eco-friendly cotton T-shirt
Made with 100% GOTS-certified organic cotton.
Names a specific material characteristic and a recognised certification.
This collection is climate neutral.
We reduced production emissions by 18% compared with 2025 through [specific measures]. The remaining emissions are addressed through [named scheme].
Explains what was actually measured and what action was taken.
Made with certified sustainable materials.
Made with 70% recycled polyester certified to the Global Recycled Standard (GRS).
Identifies a measurable characteristic and a recognised standard.
What should you do now?
Start with an inventory of every environmental claim currently in use across your business.
Review:
- Product pages
- Website copy
- Packaging
- Hang tags
- Product labels
- Advertising
- Social media
- Email campaigns
- Sustainability reports
For every claim, ask three questions:
- What exactly are we claiming?
- What evidence supports it?
- Does that evidence relate to the specific product or claim?
Keep the supporting evidence connected to the claim it proves. A product-level claim should ideally have product-level evidence behind it rather than relying on a general company statement.
For example, if you claim that a product contains certified recycled polyester, keep the relevant composition information and certification documentation linked to that product.
Tappr Trace collects certificates from your suppliers, connects each one to the products it covers and flags where evidence is missing, like a recycled-content claim with no GRS certificate on file.
If you claim a reduction in emissions, keep the calculation, methodology and underlying data.
If a claim cannot be substantiated, you have two options: rewrite it into something you can prove, or remove it.
Doing this now also gives teams time to update packaging and other physical materials that cannot easily be changed once production has started.
How will enforcement work?
The EU greenwashing directive is implemented and enforced through national consumer protection authorities.
The exact penalties are determined by each Member State, so fines and other enforcement measures can differ between countries. Depending on the national regime and the seriousness of the breach, consequences can include financial penalties, corrective measures and restrictions on misleading commercial practices.
Enforcement did not start from zero in September 2026.
Consumer protection authorities in countries including the Netherlands, Germany, Italy and the UK have already challenged environmental claims under existing consumer law. These cases show that regulators were looking closely at vague climate and sustainability statements before the new EU-wide rules took effect.
The directive therefore brings a more consistent EU framework to an area where enforcement is already happening.
Where does the Digital Product Passport fit?
A Digital Product Passport does not automatically make an environmental claim compliant, and it does not replace the need to substantiate marketing claims. Its value is that it can provide a structured place for the evidence behind a claim.
If a product is marketed as containing GRS-certified recycled polyester, for example, the passport can link the product's composition to the relevant certification information.
The same principle can apply to origin, recycled content, manufacturing information and other product-level environmental data. Instead of the claim sitting separately from the evidence, the passport can connect the two.
The practical takeaway
For fashion and textile brands, the EU greenwashing directive rules are less about banning sustainability marketing and more about making environmental claims specific, transparent and evidence-based.
Now that the rules apply, review the claims already in use across your products and marketing. For every claim, make sure you can answer:
What exactly are we saying, and what evidence proves it?
Find the claims you can't prove yet
The hard part is rarely understanding the rule. It is finding which claims are missing evidence, product by product. Book a demo and we'll show you how Tappr links each claim to the supplier certificates and product data behind it, so you can see the gaps before a regulator does.
This is general information, not legal advice. Member States implement and enforce Directive 2024/825 through national legislation, so specific requirements and penalties may vary by country. Consult qualified legal counsel before relying on this information for a compliance decision.
Sources
DPP updates, monthly.
Regulation changes and product news. No spam.
Bas van der Pol 
