EU GREEN CLAIMS DIRECTIVE · EMPOWERING CONSUMERS DIRECTIVE
EU Green Claims Directive compliance guide
From 27 September 2026, green claims are judged by how the average consumer reads them — not by what lawyers think they mean. This guide explains the new rules, the average-consumer standard, and a practical checklist for sustainability managers.
What changes on 27 September 2026
The EU Empowering Consumers Directive (EmpCo) applies across member states from 27 September 2026. It bans green claims that mislead the average consumer and introduces specific prohibitions that go well beyond existing advertising rules.
Generic claims banned
Terms like 'green', 'eco-friendly', 'climate friendly', or 'sustainable' are banned unless you can prove excellence against a recognised standard.
Carbon neutral claims banned
Offset-based 'climate neutral' or 'carbon neutral' claims are prohibited outright. You cannot buy your way out of real emissions with wording.
Fines up to 4% of turnover
Member states must apply penalties that are effective and dissuasive. The directive points to fines of up to 4% of annual turnover for the worst infringements.
Not a legal question. An empirical one.
The central test in the new rules is whether a claim misleads the average consumer. That is not a question lawyers can answer from a desk. It is a question about real people in your market: what do they understand, what do they believe, and what would change their behaviour?
Lawyers can tell you what is banned. They cannot tell you how consumers actually read your claim — and that is the standard that will be applied.
THE AVERAGE-CONSUMER TEST
Would a typical consumer in the target audience be likely to be deceived by this claim — about what the product is, what it does, or the environmental impact behind it?
• It depends on the audience (B2C, not expert).
• It depends on the context (packaging, ad, website).
• It depends on the evidence (what consumers actually think).
What counts as a misleading green claim
A claim is misleading when the average consumer takes away a meaning the evidence does not support. Common risk areas include vague language, hidden trade-offs, selective evidence, and claims about future performance without a credible plan.
Vague superlatives
'Eco-friendly', 'green', 'sustainable', 'natural' without proof.
Implied certification
Logos, leaves, or colours that suggest third-party approval that does not exist.
Carbon offset framing
'Climate neutral' based on offsets rather than real emissions reduction.
Cherry-picked lifecycle data
Highlighting one green attribute while ignoring a larger negative impact.
Unqualified future claims
'Net zero by 2030' without a published, credible transition plan.
Comparative claims without a baseline
'30% less plastic' — less than what, and over what period?
Compliance checklist for sustainability managers
Use this checklist to audit your existing claims and set up a workflow for new ones before the 2026 deadline. Tick each item off with your legal, marketing, and sustainability teams.
Remove or substantiate generic claims like 'green', 'eco-friendly', or 'sustainable'.
Replace offset-based 'climate neutral' claims with verified, science-backed wording.
Test each claim against how the average consumer in your market actually reads it.
Document the evidence behind every environmental claim in your marketing.
Review comparative claims for clarity, relevance, and verifiable proof.
Identify which claims need legal review versus consumer evidence.
Set up a pre-screening workflow for new claims before they go live.
Monitor competitor claims and regulatory guidance in your key markets.
Screen claims before the market and regulator do
SBI Claims Check combines fast synthetic-consumer screening with real fieldwork. The Silicon Panel flags how different consumer segments react to your wording — and routes uncertain cases to the evidence file only real consumers can provide.
Claims Screen
Up to 10 claims through the Silicon Panel. Acceptance, rejection, greenwashing-risk flags, and repositioning advice. 1–2 weeks. €4,900.
Claims Test
Your exact wordings tested with ~1,000 real consumers per market. Comprehension, trust, and misleading-ness documented for the average-consumer standard. €9,900 / market.
Claims Monitor
Standing panel access to pre-screen claims year-round, one fieldwork wave per year, and credibility tracking in your industry. €15,000 / year.
Silicon screens. Humans substantiate.
The panel flags what the data cannot answer — and routes it to real fieldwork. Only real consumers can form the evidence the average-consumer standard demands.
Send us your three most important claims
We will show you — free, in 30 minutes — how they sit in your industry's data today and which ones risk failing the average-consumer test.