Green claims in fashion: how to communicate without greenwashing
From 27 September 2026, new EU consumer rules ban vague environmental claims and unreliable labels. What changes for fashion marketing, product pages and wholesale copy.
KEY TAKEAWAYS Summary by the editors
- Directive (EU) 2024/825 on empowering consumers for the green transition applies from 27 September 2026 and adds specific greenwashing practices to the EU blacklist of unfair commercial practices.
- Generic environmental claims such as 'eco-friendly' or 'green' are banned unless the trader can demonstrate recognised excellent environmental performance.
- Sustainability labels must be based on a certification scheme or established by public authorities; self-created badges without that basis are prohibited.
- Claims that a product has a neutral or reduced climate impact based on offsetting outside the value chain are banned.
- The separate Green Claims Directive proposal stalled in 2025, but the consumer rules apply regardless of its fate.
'Conscious', 'responsible', 'eco', 'planet-friendly': fashion has built a whole vocabulary of sustainability marketing. From 27 September 2026, much of that vocabulary becomes legally risky in the EU. The rules apply to product pages, hang tags, campaign copy and the descriptions brands share with retailers, so they concern merchandising and wholesale teams as much as marketing.
Which EU rules apply to green claims?
The key instrument is Directive (EU) 2024/825 on empowering consumers for the green transition. It amends the Unfair Commercial Practices Directive and the Consumer Rights Directive. Member states had to transpose it by 27 March 2026, and the rules apply from 27 September 2026.
A second proposal, the Green Claims Directive, was intended to set detailed rules on how explicit environmental claims are substantiated and verified. In June 2025 the Commission signalled an intention to withdraw it and the final negotiation round was cancelled. As of autumn 2026 its future remains uncertain. The consumer rules in Directive 2024/825 apply regardless, and general rules against misleading practices already applied before.
Enforcement sits with national consumer protection authorities, and in some countries competitors and consumer organisations can also bring actions. Because the directive is transposed into national law, the precise wording, sanctions and enforcement practice can vary between member states. Brands selling across Europe should therefore check the transposing legislation and any guidance issued in their key markets.
What is now banned?
The directive adds specific practices to the list of commercial practices considered unfair in all circumstances. Those most relevant to fashion include:
- Generic environmental claims such as 'eco-friendly', 'green' or 'environmentally friendly', unless the trader can demonstrate recognised excellent environmental performance relevant to the claim, for example through the EU Ecolabel or an officially recognised ecolabel.
- Sustainability labels that are not based on a certification scheme or established by public authorities.
- Whole-product claims when the environmental benefit concerns only one aspect of the product.
- Offsetting-based claims that a product has a neutral, reduced or positive impact on the climate because of greenhouse gas offsetting.
- Presenting legal requirements as a distinctive feature, such as advertising compliance with chemical restrictions that apply to all products.
The directive also sets conditions for claims about future environmental performance, such as a commitment to reach a target by a certain year. These must be backed by clear, verifiable commitments and an implementation plan with regular independent verification.
How do the rules change typical fashion claims?
| Risky formulation | Why it is a problem | Lower-risk direction |
|---|---|---|
| 'Eco-friendly collection' | Generic claim without recognised excellent performance | State the specific attribute, e.g. the share of certified organic cotton, and how it is verified |
| 'Sustainable denim' | Vague and covers the whole product | Describe the specific process change and its scope |
| Own-brand 'Conscious' badge | Self-created label without a certification scheme | Use recognised certification labels, or explain attributes in plain text |
| 'Climate-neutral T-shirt' | Neutrality based on offsetting is banned | Report emission reductions in your own value chain, with method and scope |
| 'Free from banned chemicals' | Presents a legal requirement as distinctive | Remove, or explain voluntary measures that go beyond the law |
What does this mean for wholesale and retail partners?
Retailers that publish brand-supplied copy are themselves traders making claims to consumers. Many will tighten the rules for sustainability attributes they accept from brands, ask for evidence and remove filter tags such as 'sustainable' that cannot be substantiated. Brands should expect more questions in onboarding and product data templates and should be able to supply certificates, scope and validity dates per product.
Sales teams are also exposed. Showroom presentations, line sheets and conversations with buyers often repeat marketing language, and buyers may copy it into their own channels. Giving sales teams an approved list of specific, evidenced claims per product, and removing generic wording from sales materials, reduces the chance that an unsupported claim travels from a showroom to a retailer's website.
How should brands review their claims?
- Inventory every environmental claim in use: websites, labels, packaging, line sheets, retailer feeds and social media.
- Classify each as generic, specific, label-based or future-performance.
- Remove or rewrite generic claims and own badges without a certification basis.
- For specific claims, document the evidence, scope and validity, and keep it with the product data.
- Brief marketing, sales and retail partners on approved wording and update templates.
The safest communication is concrete and modest: what the product is made of, how that is verified and what it does not yet achieve. National authorities enforce the rules, and interpretations will develop. This article is general information, not legal advice; companies should seek legal advice for their specific case.
Frequently asked questions
Can fashion brands still say a product is made with organic cotton?
Specific, accurate claims remain possible if they can be substantiated, for example stating the share of certified organic cotton and the certification used. What is banned are vague, generic claims without recognised excellent environmental performance.
Is the Green Claims Directive in force?
No. As of autumn 2026, the Green Claims Directive proposal has not been adopted after negotiations stalled in 2025. Directive 2024/825 on empowering consumers for the green transition applies from 27 September 2026 independently.
Do the rules apply to B2B communication?
The directive amends consumer protection law, so it targets claims made to consumers. However, copy supplied to retailers usually ends up in front of consumers, so brands should apply the same standards to wholesale materials.
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