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Red Light for EU Green Claims: What UK Brands Need to Know
Member Insight
Red Light for EU Green Claims
Selling consumer goods through EU distributors: the green claims questions UK brands need to consider.
27 September 2026 saw the coming into effect across the EU of the Green Transition Directive, which strengthens the rules against misleading environmental marketing, unreliable sustainability labels and certain forms of early obsolescence.
The rules operate through each Member State's consumer legislation. They are directed at B2C conduct, but a UK brand's own product packaging, brand advertising, online content, sales presentations and approved marketing material may all reach the consumer through its EU distributors.
For UK businesses selling consumer products into Europe, that means green claims aren't something that can simply be left to the distributor to worry about.
Why this matters for HGA members
From packaging and swing tags to catalogues, websites and retailer marketing packs, Home & Gift businesses make claims about products in lots of different places. If those materials reach consumers in the EU, it's worth understanding how the rules have changed.
What's changed?
How the EU changes from the UK position
UK consumer law already requires environmental claims to be truthful, clear, substantiated and presented fairly. The Competition and Markets Authority's Green Claims Code makes that clear.
The important difference is that the new EU rules make several practices expressly prohibited in all circumstances.
Broad environmental claims
Be particularly careful with words such as "eco-friendly", "green" and "sustainable"
Broad environmental claims such as these are vulnerable unless there is recognised excellent environmental performance relevant to the claim.
Carbon offsetting
A claim about a product's climate impact which relies on carbon offsetting outside the product's value chain is also prohibited.
Sustainability labels
So is the use of a sustainability label which is neither established by a public authority nor supported by an appropriate certification scheme.
In addition, a claim about recycled packaging must not create the impression that the whole product is recycled. A business-wide renewable-energy claim must not disguise the continued use of fossil fuels elsewhere in the business.
The words, images, colours and layout may all matter.
These are not simply issues for advertising copywriters. They concern the substance and traceability of the information supplied across the distribution chain.
Practical steps
What should a UK brand do?
The first task is to map every consumer-facing statement created or approved by the brand.
That includes:
Product labels and swing tickets
Packaging
Catalogues and product-data sheets
Image libraries
Brand websites and social-media posts
Influencer guidance
Retail display material
Training supplied to distributors
It should also include claims made by a parent company or group sustainability team which a local distributor is encouraged to use.
Follow the evidence
Match every claim to the evidence that supports it
A brand should be able to identify the product, component, factory, process or period to which the claim relates, as well as:
The methodology used
The source of the data
Any conditions or limitations
Where the evidence is incomplete, the claim should be changed or withdrawn rather than left for the distributor to qualify.
Words matter
Vague language needs particular care
"Responsible", "conscious", "better for the planet" and similar expressions can suggest a broad environmental benefit that the business may be unable to establish.
A more limited and specific statement may be possible, but only if it is accurate, clearly explained and capable of proof.
HGA Tip
Think about the whole customer journey, not just the wording on your website. Environmental messaging can appear on everything from packaging and POS material to retailer product descriptions, catalogues and social content.
Sustainability labels
Don't assume a badge means a compliant scheme
A brand should not assume that a trade-marked device, house badge or brand questionnaire creates a compliant certification scheme. The EU rules require a system with transparent criteria and independent monitoring. The position should be checked before the label is given to distributors for consumer use.
Future commitments
Ambition alone isn't enough
A statement that the business or product will be net zero, climate neutral or substantially more sustainable by a future date needs more than an aspiration.
The new rules require clear, objective and publicly available commitments and targets, a detailed and realistic implementation plan, independent third-party verification and accessible reporting of progress.
Marketing should not run ahead of the plan.
Beyond environmental language
The changes go further than green claims
The Directive is not confined to environmental language. It adds rules about durability, repairability and goods with digital elements.
A brand should ensure that its distributors receive reliable information about product lifespan, repair options, availability of spare parts and software updates.
A brand that knows that an update will adversely affect a product's functioning should not allow that information to be withheld from the consumer. Nor should it market a product with a feature designed to limit durability where it knows about that feature and its effects.
Don't forget the contract
Review the distribution agreement
A brand should consider whether its EU distribution agreement does enough to manage these risks.
An agreement should consider:
Who may make consumer claims
The use of approved and current marketing materials
Preventing unauthorised amendments
Prompt withdrawal or correction of material when required
The exchange of evidence and regulatory information
Cooperation with consumer authorities
Allocation of responsibility where one party's material or conduct causes the problem
Indemnities may be appropriate, but they are not a substitute for practical control. The brand's interest is to prevent an incorrect claim being repeated across several markets, rather than to debate financial responsibility after an investigation begins.
One EU, different markets
Remember the national laws of each EU Member State
The Directive is implemented through the national laws of each EU Member State, and the detail of enforcement, penalties and available consumer remedies can differ.
A single EU marketing pack will not necessarily work everywhere.
A brand should therefore identify its priority markets and ensure that its distributor has access to country-specific advice where necessary.
Take home point
Selling B2B doesn't necessarily remove the brand from the consumer marketing picture
UK brands should not assume that a B2B sale places consumer marketing outside their responsibility. If their environmental marketing claims shape what the EU consumer sees, the new EU rules should form part of their product marketing and distribution review.
About the author
Stephen Sidkin, Fox Williams LLP
Stephen Sidkin is a partner at Fox Williams LLP and the author of this Member Insight.
This article was provided by HGA member Fox Williams LLP. Additional HGA notes have been included to highlight some of the practical considerations for businesses across the Home & Gift industry. This article provides general information and should not be treated as legal advice.
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