STATUS CLARIFICATION

Green Claims Directive vs. Empowering Consumers Directive: What's Actually in Force in 2026

Q: Is the EU Green Claims Directive dead?

Not formally. The European Commission announced on 20 June 2025 that it intended to withdraw the proposal, but as of the European Parliament's Legislative Observatory, checked live, the file's official status remains 'Awaiting Council's 1st reading position' — no withdrawal is recorded. The Parliament's own Legislative Train Schedule lists the file as 'Blocked,' with the Council named as the blocking institution, not as withdrawn or closed. It is stalled, not settled.

Q: Does the Empowering Consumers Directive replace the Green Claims Directive?

No — they are not substitutes for each other. The Empowering Consumers Directive bans a defined list of specific misleading practices by amending existing consumer law. The Green Claims Directive, as proposed, would have gone further: requiring upfront, often third-party-verified substantiation for essentially any voluntary environmental claim before it's made. One is a narrower blacklist already in law; the other was a broader prior-verification regime that has not been adopted.

Published 24.09.2026 · Reading time ~4 min · by Lior Gabriel Graetz · LG Fashion Labs

Two different EU laws deal with green marketing claims, and it's easy to confuse them because they cover overlapping ground. Only one is binding law today, and its rules on green claims become applicable EU-wide from 27 September 2026. The other is still just a proposal — and a lot of what's written about it online is already out of date, because its status has kept shifting.

This guide separates the two, sourced directly from EUR-Lex and the European Parliament's own trackers, checked live.

1. The two directives, one line each

The Green Claims Directive is a proposal the European Commission tabled on 22 March 2023 (COM(2023) 166). It has never been adopted. It is not law in any EU member state today.

The Empowering Consumers for the Green Transition Directive — widely shortened to "EmpCo," formally Directive (EU) 2024/825 — is already law. It was adopted on 28 February 2024, published in the Official Journal on 6 March 2024, and entered into force 20 days after that. Its substantive rules become applicable across the EU from 27 September 2026, the date set out in its own Article 4.

2. What actually changes on 27 September 2026

EmpCo amends two existing consumer-protection directives — the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU) — adding new entries to the UCPD's Annex I, the list of practices treated as automatically unfair, no case-by-case test needed. Four additions matter most for fashion brands:

Generic claims without proof. Calling a product "eco-friendly," "green" or "sustainable" is automatically unfair unless you can demonstrate recognised excellent environmental performance — EU Ecolabel-level, an officially recognised ISO 14024 Type I scheme, or top performance under other applicable EU law. A hangtag reading just "eco-friendly," with nothing to back it, falls foul of this rule.
Whole-product claims for partial improvements. Marketing an entire jacket as sustainable because its lining is recycled is automatically unfair — the claim has to match what's actually true, not the single strongest fact about the product.
Offsetting-based neutrality claims. Claiming a garment is "climate neutral" purely because its emissions were offset elsewhere is automatically unfair — offsetting a footprint is not the same as reducing it.
Unbacked sustainability labels. Displaying your own "green" seal or badge that isn't tied to a genuine third-party certification scheme, or set by a public authority, is automatically unfair.

These become enforceable under each member state's national consumer law from 27 September 2026; the transposition deadline for member states was 27 March 2026.

3. What actually happened to the Green Claims Directive

The Green Claims Directive moved through the normal legislative process for over two years, then stalled:

22 March 2023 — Commission proposal published (COM(2023) 166).
12 March 2024 — European Parliament adopts its first-reading position, 467 votes in favour.
17 June 2024 — Council adopts its own general approach, adding a simplified track for straightforward claims.
28 January 2025 and 24 April 2025 — first and second trilogues between Parliament, Council and Commission.
20 June 2025 — the Commission announces it intends to withdraw the proposal, after a dispute over exempting an estimated 30 million EU microenterprises from its scope.
23 June 2025 — the third trilogue, already scheduled for this date, is cancelled.

Since then, the file hasn't advanced — but it hasn't been formally closed either. The Commission's own 2026 Work Programme (COM(2025) 870), adopted 21 October 2025, still lists the proposal as "pending," not withdrawn. Checked live against the European Parliament's Legislative Observatory today, the procedure's official status remains "Awaiting Council's 1st reading position." The Parliament's Legislative Train Schedule, in its latest edition, records the file as "Blocked," with the Council named as the blocking institution — not withdrawn, not closed.

In short: the Green Claims Directive is not law, and — despite the Commission's own announcement on 20 June 2025 — it has not been formally withdrawn either. Treat "dead" and "already in force" claims about it with equal scepticism, and check the primary sources before relying on either.

Quick reference

Not the same directive

	Green Claims Directive	Empowering Consumers Directive (EmpCo)
Status	Proposal only. Not adopted. Recorded as "Blocked" (Council) in the European Parliament's most recent Legislative Train Schedule edition.	Adopted law. Directive (EU) 2024/825, in force since 26 March 2024.
Applies	Not applicable — no binding date exists.	From 27 September 2026.
Approach	Would have required upfront substantiation, often third-party verified, for essentially any voluntary environmental claim.	Bans a defined list of specific misleading practices, enforced after the fact under national consumer law.

4. What this means for your brand

Build your compliance work around EmpCo, not the Green Claims Directive — EmpCo is the one with a binding date. From 27 September 2026, any generic claim like "eco-friendly," "sustainable" or "green" needs backing you could show a regulator: a recognised label, a certification scheme, or documented performance data, not marketing copy alone. Audit your hangtags, labels and product pages against the four practices above before that date.

Don't build workflows around Green Claims Directive requirements — like mandatory third-party verification of every claim — that don't exist in binding law and may never take that form. Watch the file, but don't design your systems around a text that's currently blocked.

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Frequently asked questions

Is the EU Green Claims Directive dead? +

Not formally. The Commission announced on 20 June 2025 that it intended to withdraw the proposal, but as of the European Parliament's Legislative Observatory, checked live, the file's official status remains "Awaiting Council's 1st reading position" — no withdrawal is recorded. The Parliament's own Legislative Train Schedule lists the file as "Blocked," with the Council named as the blocking institution, not as withdrawn or closed. It is stalled, not settled.

When do EmpCo's green-claims rules actually start applying? +

From 27 September 2026, per Article 4 of Directive (EU) 2024/825. EU member states had until 27 March 2026 to adopt the national implementing measures; those measures then apply from 27 September 2026.

Can a fashion brand still say "eco-friendly" or "sustainable" after 27 September 2026? +

Only if the brand can demonstrate recognised excellent environmental performance for the claim — an EU Ecolabel-level result or an officially recognised ISO 14024 Type I ecolabel, for example. Otherwise, under the new Annex I point added to the Unfair Commercial Practices Directive by EmpCo, an unsubstantiated generic environmental claim is automatically treated as an unfair commercial practice.

Does EmpCo replace the Green Claims Directive? +

No — they aren't substitutes for each other. EmpCo bans a defined list of specific misleading practices by amending existing consumer law. The Green Claims Directive, as proposed, would have gone further: requiring upfront, often third-party-verified substantiation for essentially any voluntary environmental claim before it's made. One is a narrower blacklist already in law; the other was a broader prior-verification regime that hasn't been adopted.