EU Greenwashing Rules: How Should Brands Communicate After 27 September 2026?

Imagine your child comes home with a test result and, when you ask about the grade, simply says: “Good.”

Good compared with what? Good enough to move to the next year, or merely good because it was not the worst mark in the class?

Environmental claims have a similar problem. Words such as sustainable, eco-friendly, responsible or good for the planet can sound positive while telling the consumer remarkably little about what is actually being claimed.

This is one of the problems addressed by the EU's new rules on greenwashing. From 27 September 2026, the changes introduced by Directive (EU) 2024/825 will strengthen consumer protection against misleading environmental claims and certain sustainability labels. The objective is not to stop brands from communicating environmental characteristics. It is to make those claims more specific, substantiated and relevant to the product being sold.

First: who does this apply to?

There is an important distinction here. Directive 2024/825 amends the EU framework on unfair business-to-consumer commercial practices. In practical terms, the rules are primarily relevant to traders communicating with consumers: brands, retailers and other businesses whose advertising, websites, product pages, packaging and other commercial communications are connected with promoting or selling products to consumers.

For a fashion brand selling a garment, bag or pair of shoes to consumers in the EU, this is directly relevant. A material producer selling a material purely in a B2B transaction is in a different position under this particular Directive. However, the distinction does not make the information supplied by material producers irrelevant. Their technical data, certifications and test results may become the evidence on which a brand bases its consumer-facing claims.

So the question for a brand is not simply, “What does my material producer say about this material?” It is: “What exactly am I telling my customer, and can I substantiate that particular statement?”

The basic rule: make the claim fit the evidence

This is where the Directive becomes particularly relevant to new materials.

A material may have a very specific and well-documented environmental characteristic. It may contain a defined percentage of bio-based content, use agricultural by-products, carry a particular certification, contain recycled content or demonstrate a certain level of biodegradation under defined test conditions.

Those are useful facts. The problem comes when a specific fact is expanded into a much broader environmental statement.

A material containing 70% bio-based content does not necessarily make the finished product 70% bio-based. A recycled lining does not make the whole garment recycled. A biodegradable component does not make the entire product biodegradable. And a material certification is not automatically a sustainability certificate for the finished product.

The Directive specifically addresses environmental claims about an entire product or business where the characteristic actually concerns only a particular aspect or component.

In other words, scope matters.

Three areas where brands need to be particularly careful

1. Whole-product claims

A common mistake is taking a material characteristic and allowing it to describe the entire product.

If the outer material of a bag contains a certain percentage of bio-based content, the claim needs to make clear that this is a characteristic of the outer material. The lining, thread, adhesive, reinforcement and hardware may have completely different compositions.

The same applies to claims such as “made with recycled materials”. If only one component is recycled, presenting the product as though the characteristic applies to the entire product can create a misleading impression. This is precisely the type of practice addressed by the Directive.

The solution is not complicated: say what the characteristic actually belongs to.

2. Certifications

Certification is useful because it gives a claim an evidential basis. But certification does not give a product a general environmental halo.

A certification may verify bio-based content, recycled content, organic fibre, forestry origin or a particular performance criterion. Before using the certification or its logo in consumer communication, a brand needs to understand exactly what has been certified, which material or product it applies to and what the certification actually demonstrates.

The new rules also prohibit displaying a voluntary sustainability label where it is not based on an appropriate certification scheme or established by a public authority.

So rather than asking, “Is this material certified?”, the more useful question is: “Certified for what?”

3. Bio-based is not biodegradable

These terms are frequently placed next to each other in material marketing, but they describe different things.

Bio-based refers to the biological or renewable origin of a material or part of it. Biodegradable refers to what happens to a material under particular biological conditions. One does not establish the other.

A biodegradation claim therefore needs context: what was tested, under which conditions, for how long and according to which methodology. “Biodegradable” on its own can communicate much more than the underlying test actually demonstrates.

The Directive itself lists biodegradable and biobased among examples of generic environmental claims. A specific claim can be treated differently where its relevant specification is made clear and prominent on the same medium, but the underlying claim must still comply with the wider rules against misleading commercial practices.

This is why “30% biodegradation under X conditions after X period” and “biodegradable” are not equivalent pieces of information.

So what should brands actually do?

The practical shift is fairly simple: environmental communication needs to start with the material evidence, rather than with the marketing message.

Before publishing a claim, establish what exactly the material documentation proves. Then define the scope of the claim, make the relevant conditions clear where necessary, and avoid turning one documented characteristic into a general statement about the environmental performance of the whole product.

In practice, this means that technical documentation is becoming increasingly important to marketing. Composition data, certifications, test reports, LCA information and biodegradation studies are not just files for the product-development team. They are the evidence behind what a brand can responsibly tell its customers.

The useful rule is therefore: claim, evidence, scope, conditions.

If those four things line up, communication becomes considerably easier.

And importantly, this does not mean brands should stop talking about sustainability. It means moving away from broad language that could describe almost anything and towards information that actually tells the consumer something.

Fewer green adjectives. More facts.

Case Study

To see how this works in practice, consider a real example of communication for a bag made using Desserto®.

The original copy says:

“This bag doesn’t come from an animal.
It comes from a cactus field.
Cactus leather: soft to the touch, kind to the planet, made to last.
Fashion that doesn’t cost the earth.
Would you carry it?”

There are several different types of claims packed into a few lines.

• “This bag doesn’t come from an animal” is a statement about the composition of the product and therefore needs to be true for the whole bag, not simply the material used for its outer surface.

• “It comes from a cactus field” creates a much broader impression about the origin of the finished product than the material information necessarily supports. Desserto itself states that its formulations vary by material and application, so the exact material specification matters.

• “Kind to the planet” is where the language changes character. It is a broad environmental statement without telling the consumer what environmental characteristic is being claimed or what evidence supports that overall conclusion.

• “Made to last” is also a performance claim. If the brand wants to make it, it should be supported by appropriate durability evidence rather than simply attached to the sustainability narrative. ISO tests and certifications would a good way to go about it.

• “Fashion that doesn’t cost the earth” takes the broadest possible position: it creates an overall environmental impression about the finished product. That is precisely the sort of language that becomes difficult to defend when the underlying evidence relates to one particular material or characteristic.

The interesting point is that none of this requires the brand to abandon the story. It simply requires the story to become more precise.

For example:

“Our bag’s outer material is Desserto®, a vegan leather alternative made using cactus industry by-products. Soft to the touch and designed for everyday use. Would you carry it?”

That version tells the consumer what the material is, where the relevant feedstock comes from and which part of the product the statement refers to. It does not ask one material to carry the environmental credentials of the entire bag.

The exact wording would still need to be checked against the specific Desserto® formulation, the finished product and the evidence available to the brand. But this is the general direction the new rules encourage: specific claims attached to specific evidence, rather than a broad environmental conclusion attached to a green-looking story.

This is where Substanz comes in

At Substanz, we mainly work with brands developing and selling garments, bags and accessories made with bio-based and other innovative materials.

Our communication compliance consulting helps brands review environmental and material claims against the technical information available from the material producer — including composition, certifications, performance testing, biodegradation data and other relevant documentation — and translate that information into clear, defensible product communication.

We can review your product descriptions or overall brand and corporate communications and make your life easier!

Discover our Consulting Services

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