The EU's green claims rules are now in force. Here's what changes for climate and circular startups.

Since 27 September, a new set of EU rules applies to what companies can say about the environmental performance of their products. The rules come from Directive 2024/825, often called the Empowering Consumers Directive. They apply to every business selling to consumers in the EU, from a food startup with one product to an energy scale-up with a million customers. There's no transition period, no small business exemption, and no "we're a climate company, we're the good guys" exemption either.

We spend a lot of our time reading the environmental claims on startup websites. Most of them are made in good faith by founders who believe in what they're doing. That's exactly why we think this is worth a plain language summary. Not because anyone is about to get fined, but because the habits that used to be normal now carry a risk, and the fix is usually easy.

01What the directive actually does

It adds a handful of practices to the EU's list of misleading commercial practices. Four of them matter most for a startup, whatever it sells.

Generic claims without proof

Words like "sustainable", "eco-friendly", "green", "climate friendly" and "biodegradable", used on their own, are no longer allowed unless you can show recognised excellent environmental performance. In practice, for a small brand, that means: don't use them as a tagline.

Claims about the whole product that only cover one part

If your packaging is compostable, you can say your packaging is compostable. You can't say the product is.

Carbon neutral claims based on offsetting

Saying a product is carbon neutral, climate positive or has a reduced impact because you bought offsets is now on the banned list. You can still talk about offsetting. You can't use it to describe the product itself.

Sustainability labels and future promises

A badge or label has to come from a certification scheme or a public authority; a logo you designed yourself doesn't count. And a promise like "net zero by 2030" needs a detailed, public plan with measurable targets and independent monitoring behind it.

From the Commission's own FAQ, September 2026

A QR code doesn't rescue a generic claim. The specification that makes "eco-friendly" mean something has to sit next to the claim, on the same label or page. And if there's no room to specify it, the Commission's answer is simple: then don't make the claim.

02Who it reaches, and it's not only brands with a shelf

The examples people use for this directive are usually packaging: a jar, a tray, a box. That's where the claims are easiest to photograph. But the rules are about the claim, not the product category, and we see the same patterns on the websites of mobility apps, energy startups, building material companies, food tech and software platforms.

If you sell to consumers

Directly covered. Apps, subscriptions, energy contracts, rental and swap platforms, repair services, a web shop, a market stall: if a consumer can buy it, the directive applies to how you describe it.

If you're B2B

Not directly covered: the directive sits inside EU consumer law. But your customers are. A consumer brand that puts your ingredient, material or software on its label is liable for the claim, so it will ask you for the evidence. B2B claims also fall under the EU's misleading advertising rules, enforced through the courts rather than the consumer authority.

If you're bigger than a startup

Same rules, more exposure. Enforcement follows visibility, investors and corporate buyers now ask for substantiation as standard, and a scale-up's homepage is read by far more people than a market stall's sign.

Six claims from outside the supermarket

Lightly disguised, all from sectors we work in or see at accelerator programmes. Same test every time: generic, or specific and sourced?

Mobility app

"Climate neutral rides"

"X g CO₂e per km, measured over [period]. We also buy carbon credits, reported separately."

Energy

"100% green energy"

"Electricity from Dutch wind and solar, backed by guarantees of origin, matched [yearly / hourly]."

Built environment

"Circular façade panels"

"Panels made from X% recovered steel, designed for disassembly, with a take-back contract."

Food tech, B2B

"Our protein cuts emissions by 80%"

"80% lower CO₂e per kg of protein than [reference], cradle to gate, [method], [year]."

Fashion platform

"Every swap saves the planet"

"Average avoided emissions per swap, by category, with the projection kept separate from what's been achieved."

Software

"A carbon negative company"

"Scope 1 to 3 measured for [year], reduction targets published, removals bought and reported separately."

Try it

Allowed or not? Six claims we've seen on real websites, lightly disguised.

Tap your answer. The rule behind each one is explained after you choose.

"Eco-friendly packaging"

Not allowed as it stands. "Eco-friendly" is on the directive's own list of generic claims. Say what the packaging is made of instead.

"Our panels contain 72% recovered steel, verified by [scheme], [year]."

Allowed, if it's true. Specific, about one property, with a named verifier and a date. Works on a building site as well as on a shelf.

"Carbon neutral delivery, thanks to our offsetting partner"

Not allowed. A neutral or reduced impact claim based on offsetting is now a banned practice. You can still mention the offsets, in a separate sentence, as what they are.

"Net zero by 2030" on the homepage, and nothing else

Not allowed without the plan. A future claim needs public, measurable commitments, an implementation plan and independent monitoring. The promise alone doesn't count.

"Sustainable" on the pack, with a QR code to the sustainability page

Not allowed. The Commission's FAQ is explicit: the specification has to be next to the claim, on the same medium. The QR code can hold the evidence, not the meaning.

"0.59 kg CO₂e avoided per kg of rescued bread. ADEME factors, screening level, method on request."

Allowed. A measured number, a named source, a stated boundary. This is what a claim looks like after September.

03What didn't change

This is the part that gets lost. Specific, measured and sourced claims are still fine. "Made from 80% rescued bread" is fine, if it's true. The sentence below is also fine, and it says more than "sustainable" ever did:

0.59 kg CO₂e avoided per kg of bread we rescue · ADEME emission factors · screening level

One thing to check before you believe it

The directive does not require third party verification of your claims before you publish them. That requirement was part of a separate proposal, the Green Claims Directive, which has not been adopted. Negotiations on it stalled in 2025 and its future is unclear.

If someone tells you that you now need a certified verification of every number, check what they're selling.

04Five patterns, shown on things you can hold

After reviewing the public claims of a few dozen circular and climate startups this year, the same things keep showing up. None of them are lies. All of them are now a problem. We've put them on consumer products because they're easiest to see there; the same five appear on B2B decks and SaaS landing pages.