From September 27, 'Eco' Needs Evidence in the EU

What changes, and when?

The law behind it is Directive (EU) 2024/825, known as Empowering Consumers for the Green Transition (ECGT). It entered into force on March 27, 2024, member states were to transpose it into national law by March 27, 2026, and the new rules apply from September 27, 2026. The core of it: generic environmental wording that praises a product in broad terms—environmentally friendly, eco-friendly, green, ecological, climate friendly—cannot be used unless it is backed by recognized excellent environmental performance. Words like 'eco,' 'green' and 'sustainable' are likewise not permitted unless specific, accessible substantiation appears in the same medium as the claim. That medium includes not only packaging but websites, technical data sheets and marketing materials.

This is a Directive rather than a Regulation, so each member state transposes and enforces it through national law. The same phrase may therefore be challenged to different degrees in different countries, and enforcement may move at different speeds. What is certain today is the application date and the nature of what is prohibited; how any individual phrase will actually be judged will only emerge as cases accumulate. Some coverage has forecast that more than half of the environmental labeling in loose circulation will disappear or change, but that is a forecast, not a tally.

1. What is blocked is not the word but the word without evidence

Reading this as 'stop saying eco' sends the response in the wrong direction. What the rule asks for is that the evidence behind the claim be verifiable by the consumer in the very place the claim appears. If the basis for a phrase on the front of a carton exists only in internal company files, it can be treated as though it were not there at all.

So the review starts with a list, not with deletions. Pull every environment-related phrase used on the product, then write beside each one what the evidence is and where that evidence is published. The items worth defending and the items worth dropping separate themselves.

• A full inventory of environmental wording on carton, container and product page
• The supporting evidence for each phrase and where it is published
• Whether there is room in the same medium to display that evidence
• Phrases that cannot be substantiated, and the design revisions their removal requires

2. A self-made mark is not a certification

Eco logos a brand designed itself, or in-house vegan marks—anything not grounded in a public authority or third-party verification—are not permitted. What is accepted is certification based on a transparent, publicly accessible third-party verification system.

This distinction matters at the packaging design stage because a self-made mark usually enters as a design element first. Emptying that space often destabilizes the whole front panel, so it is safer to decide which certification you will actually obtain before the design is fixed.

3. It covers images and names, not only words

The scope includes visual, graphic and symbolic expressions as well as text, and can extend to product, brand and company names that convey or imply an environmental benefit. A leaf graphic or a globe symbol is read against the same standard as a sentence.

In cosmetics this point carries real weight. Wording can be corrected in the next print run; a product name and a brand name cannot. For a line that treats Europe as a principal market, the question of whether to use a word with environmental connotations has to be settled at the naming stage.

4. Familiar Korean wording does not travel unchanged

Phrases common on Korean cartons—'clean beauty,' 'eco,' 'naturally derived'—and self-made vegan marks have been flagged as falling foul of these rules. Because they circulate domestically without much friction, they are exactly the items where awareness of the problem tends to arrive late.

Wording that can be converted into a number, such as 'naturally derived,' needs its form of evidence decided first. Without knowing on what basis the percentage was calculated and in which document that calculation is recorded, only the phrase remains. Conversely, once the calculation basis is clear, there is room to replace broad praise with a verifiable fact.

5. Count carbon wording and printed stock separately

If you use carbon-neutral or climate-related wording, verify its basis separately. Labels resting on carbon offsetting have been singled out as a particularly exposed category under these rules.

And deciding to change wording is a different schedule from getting the revised carton onto the line. Print materials are usually secured in lots ahead of time, so stock can remain after the application date has passed. What needs counting now is not the number of phrases but how much printed stock carries the wording being revised, and by when it will be used up.

The first question for the brief

Write this one line into the brief: of the environmental phrases on this product, how many let a consumer check the evidence in the same place? If the answer is zero, removing the wording comes first; if there is an answer, the next task is deciding where and how that evidence gets published. September 27 is less a deadline for writing new claims than a deadline for clearing out the ones you cannot support.