Key takeaways
  • Directive (EU) 2024/825 has applied in all EU countries since September 27, 2026, and covers sellers based outside the EU who market to EU consumers.
  • Generic claims such as eco-friendly, green or climate friendly are banned unless the seller can prove recognised excellent environmental performance, for example through the EU Ecolabel, that relates to the claim.
  • Product claims of carbon or climate neutrality based on offsetting are banned in all circumstances.
  • Sustainability labels must come from a qualifying third-party certification scheme or an EU public authority, so self-made badges on listing images must go.
  • Sellers must show the EU legal guarantee notice and, where a producer offers a free durability guarantee of more than two years, the harmonised GARAN label.
  • The separate Green Claims Directive proposal has not been adopted and is listed by the European Commission as pending.

What changed for Amazon sellers on September 27, 2026?

From September 27, 2026, national laws implementing Directive (EU) 2024/825 apply across the EU. Vague green wording such as "eco-friendly," carbon neutral claims that rely on offsets, and home-made sustainability badges are now banned in consumer marketing. Sellers must also show new guarantee and durability information. Amazon listings in EU stores are covered.

Known as the ECGT or EmpCo directive, this law works by editing older legislation rather than standing alone. It amends two existing EU laws: the Unfair Commercial Practices Directive, which polices misleading marketing, and the Consumer Rights Directive, which sets what information a seller must give before purchase. The official text on EUR-Lex adds new entries to the UCPD's "blacklist," the list of practices banned in all circumstances with no case-by-case test.

DateWhat happened
February 28, 2024Directive (EU) 2024/825 adopted
March 26, 2024Directive entered into force
September 25, 2025Commission adopts Implementing Regulation (EU) 2025/1960 with the guarantee notice and durability label designs
March 27, 2026Deadline for EU countries to pass national laws
Mid-August 2026Amazon begins sending "Action Required" notices on flagged ASINs (reported by Amalytix, not published by Amazon)
September 22, 2026Commission publishes its Questions and Answers on the directive
September 27, 2026New rules apply in every EU country

On the Amazon side, the German tool provider Amalytix reported that from mid-August 2026 Amazon sent "Action Required" notices, often with an attached ASIN list. It described two consequences: Amazon may strip the section containing a flagged claim 15 days after the first notice, and may deactivate a listing if a non-compliant claim was still live on September 27. That account cites a Vendor Central help page we could not access, so treat the exact mechanics as secondary reporting and check the Product compliance page in your own account.

Which sellers and Amazon marketplaces are affected?

Anyone selling to consumers on amazon.de, .fr, .it, .es, .nl, .se, .pl or another EU Amazon store is covered, wherever the business is based. A US brand on Pan-European FBA follows the same rules as a German company. Listings shown only on amazon.co.uk or amazon.com fall outside this directive.

The Commission's Q&A is explicit that the unfair practices rules apply to every commercial practice aimed at EU consumers, regardless of whether the trader or the product comes from inside or outside the EU. What counts is the audience, not the seller's address.

  • In scope: titles, bullets, descriptions, images, videos, A+ content, Brand Stores, Sponsored Brands headlines and packaging, whenever they reach EU consumers.
  • Each marketplace separately: your German, French and Polish detail pages are separate pieces of copy in separate languages. Fixing amazon.de does nothing for amazon.it.
  • Mostly out of scope: pure business-to-business sales. The UCPD covers business-to-consumer practices only, although the Commission notes that individual countries may extend protection to business buyers.
  • UK listings: the UK is not bound by the directive. Green claims on amazon.co.uk are judged under UK consumer law and the CMA's Green Claims Code, which has its own expectations about accuracy and evidence.
  • US listings: unaffected by this law, but many brands share images and A+ content across stores. If your EU and US listings reuse the same infographic, the EU version sets the standard.

National laws are where enforcement happens, and they were not all on time. AX Holding Group reports that on May 28, 2026 the Commission sent formal notices to 20 EU countries that had not notified full transposition, so wording and penalties can differ by country.

Who is the "trader" also matters. For a third-party seller, you are the trader and carry the information duties. For a Vendor Central brand, Amazon is the seller to the consumer, but you still create the content and Amazon's notices reportedly reached vendors first. If you are planning EU growth, our international expansion guide covers the wider compliance stack.

Which green claims are now banned outright?

Six practices are now on the EU blacklist: generic environmental claims without recognised top performance, claims about a whole product when only part qualifies, offset-based climate claims, unofficial sustainability labels, selling legal requirements as a unique feature, and several false durability or repair statements. Blacklisted means banned, with no case-by-case defense.

Blacklist pointWhat it bansTypical Amazon wording at risk
2aDisplaying a trust mark that neither a qualifying certification scheme nor a public body stands behindA green "Eco Choice" badge your designer drew for image 4
4aGeneric environmental claims without recognised excellent environmental performance"Eco-friendly yoga mat," "green cleaning," "planet friendly"
4bA claim about the entire product or business when it only concerns one part"Sustainable bottle" when only the label paper is recycled
4cProduct claims of neutral, reduced or positive climate impact based on offsetting"Climate neutral shipping," "CO2 neutral product"
10aPresenting what the law already requires of every product in the category as a selling pointHighlighting a substance as absent when EU law already bans it in that product type
23d to 23jFalse durability claims, calling a product repairable when it is not, misleading software update messages, pushing early replacement of consumables"Lasts 10 years" with no test basis

The directive's recitals give a list of generic terms that fall under point 4a, among them eco-friendly, green, ecological, biodegradable, biobased, energy efficient, climate friendly, carbon friendly and nature's friend. Words like "sustainable" are not on that list by name, but the Commission's test is whether a phrase suggests excellent environmental performance, and Amazon's own examples reportedly include "sustainable materials."

Two more changes work on a case-by-case basis rather than as outright bans. Claims about future performance, such as "net zero by 2030," now need a detailed public plan with measurable targets, allocated resources and regular checks by an independent expert whose findings consumers can see. Advertising benefits that are irrelevant or do not come from any real feature of the product is also treated as misleading.

Images and brand names count

The definition of an environmental claim covers pictures, symbols, brand names and product names. The Commission's Q&A warns that green leaves, water drops and green backgrounds next to sustainability wording can be read as an implied claim or even as a label. A brand name built on "Eco" is not exempt just because it is a registered trademark; it is judged on what it tells the shopper.

Can I still say carbon neutral or climate neutral?

Not for a product if the claim rests on buying offsets; point 4c bans that in every case. A neutrality claim is only possible when it reflects the product's own lifecycle emissions in its value chain, and as a generic phrase it also needs recognised excellent environmental performance. For most listings, remove it.

The directive's recitals give examples of offset-based wording that is caught, such as climate neutral, carbon positive, climate compensated, limited CO2 footprint and climate net zero. The Commission's Q&A explains that these mislead because shoppers assume the claim describes the product itself, when the offsets are outside its supply chain.

What remains possible:

  • Company-level investment statements. The recitals say businesses can still talk about funding environmental projects, including carbon credit projects, provided the message is accurate and does not imply the product has no impact. "We fund verified reforestation projects" on a brand page is very different from "carbon neutral" in a title.
  • Measured reductions with specifics. "Packaging weight cut from 120 g to 85 g in 2025" is specific and verifiable. Keep the evidence on file.
  • Future targets with a real plan. Only with the published plan, targets and independent verification described above. Without that, leave dated pledges out of listings.

If your product carries an offset-based certification mark on the packaging, read the label section below before printing your next run.

What happens to sustainability labels and Climate Pledge Friendly?

You may only show a sustainability label from a third-party certification scheme that meets the directive's tests, or from an EU public authority. Amazon displays the Climate Pledge Friendly badge itself and has not said publicly how the directive affects it. Your own copy and images remain your responsibility.

A qualifying certification scheme must be open to any business that meets its rules on fair terms, developed with experts and stakeholders, able to suspend or withdraw the label for non-compliance, and monitored by a third party independent of both the scheme owner and the brand. Labels created by a brand or its supplier fail that test by design.

Three practical points from the Commission's Q&A:

  • "Public authority" means EU authorities. A label issued by a non-EU government body is not automatically safe; it has to pass the certification scheme test instead. US brands using American government seals on EU images should check each one.
  • Recognised excellent performance is narrow. It means the EU Ecolabel, a type I ecolabel under ISO 14024 that an EU country officially recognizes (Nordic Swan, Blue Angel, Milieukeur and the Austrian Ecolabel are examples), or the highest performance class set by other EU legislation, like the energy label. Only that level of proof supports a generic word like "eco," and the proof must relate to the claim.
  • Organic food terms follow their own law. "Bio" and "eco" used under the EU organic regulation remain usable for certified organic food.

For Climate Pledge Friendly, our reading is this. The badge rests on certifications Amazon recognizes, and many of them, such as FSC, Fairtrade, Rainforest Alliance or the EU Ecolabel, are third-party schemes. Earning the badge does not let you add "eco-friendly" to your bullets. Where a certification is built on offsetting, do not repeat neutrality wording in your own content. Amazon's Compact by Design is Amazon's own certification; treat it as Amazon's statement, not yours. Our Climate Pledge Friendly certification guide explains how the badge is earned. How Amazon adjusts the badge in EU stores is unconfirmed, so watch Seller Central news.

What are the new durability, repair and warranty information duties?

Sellers must now remind EU shoppers of their minimum two-year legal guarantee using a standard EU notice. If the producer offers a free durability guarantee of more than two years covering the whole product, the seller must show the EU's harmonised label for it. Software update periods and repair information are also required when the producer supplies them.

The Commission set the designs in Implementing Regulation (EU) 2025/1960 of September 25, 2025. The Commission's consumer pages describe two separate items:

  • The harmonised notice is mandatory for every seller of goods and explains the legal guarantee. Online, the Commission says it can appear as a general reminder on the seller's website. On Amazon, the marketplace controls the page layout, and Amazon has not publicly described how it displays the notice for third-party sellers.
  • The GARAN label applies only when the maker gives a free durability guarantee that runs beyond two years and covers the whole item, not one component. When the producer gives that information to the seller, the seller must display the label prominently, for example next to the product picture online.

The Consumer Rights Directive changes also require, where the producer makes it available, the minimum period of software updates for connected goods, a reparability score where one exists in EU law, and otherwise details on spare parts, repair instructions and repair restrictions. A brand that sells its own products through Seller Central is both producer and seller, so it cannot claim the information was never passed on.

Do not overstate guarantees

If your listing says "lifetime warranty" or "built to last," check what the written guarantee actually covers. A durability claim without test data, or a guarantee that excludes most parts, can fall under the new blacklist points on false durability. Write the term, the coverage and how to claim it in plain words.

What green claims are still allowed on Amazon?

Specific, accurate and provable claims are still allowed. If the detail sits clearly on the same listing, such as the share of recycled content and which component it applies to, the claim is not generic. Certified labels from qualifying schemes, energy labels and EU Ecolabel status can still be shown, as long as each claim matches what the certificate covers.

The directive's own example is useful: "climate-friendly packaging" is generic and banned without top performance, while a statement that all the energy used to make the packaging comes from renewable sources is specific. The same logic works for listing copy.

Before (risky)After (specific, if true and documented)
Eco-friendly water bottleBottle body made from 50% recycled stainless steel; lid is new plastic
Sustainable packagingBox and insert are FSC certified cardboard, no plastic film
Carbon neutral deliveryRemove from the product listing; describe any project funding at brand level
Biodegradable bagsCertified compostable in industrial facilities under the named standard; not suitable for home compost
Energy efficient heaterEU energy class shown with the official label, plus measured wattage

Specific claims are not a free pass. They still must be truthful under the general misleading-practice rules, and comparisons with other products now need the comparison method, the products compared and how the data is kept current. Secondary reporting on Amazon's help page says claims such as recyclability, compostability, PFAS-free or durability can stay only if you upload supporting documents through the compliance attributes, per marketplace. Plan to keep the evidence for each claim in one folder you can send on request.

How do I audit titles, bullets, A+, images and packaging?

Work marketplace by marketplace. Export every customer-facing text field, search each language for green terms, review every image and A+ module by eye, then fix, substantiate or remove each hit. Check the Product compliance page for Amazon's own flags. Packaging comes last because stickers can correct stock already printed.

  1. Check Amazon's flags first. Open the Account Health and Product compliance areas in Seller Central (or Vendor Central) for each EU store. Any ASIN list Amazon sent is a starting point, not the full scope. Our Account Health guide shows where these notices tend to appear.
  2. Export live content per marketplace. Pull titles, bullets, descriptions and attributes for amazon.de, .fr, .it, .es, .nl, .se, .pl and any other EU store you sell in, using a category listings report or flat file.
  3. Search in each language. Build a term list with a native speaker: for example umweltfreundlich, klimaneutral and nachhaltig in German; écologique and neutre en carbone in French; ecologico and sostenibile in Italian; ecológico and sostenible in Spanish; milieuvriendelijk and klimaatneutraal in Dutch; miljövänlig and klimatneutral in Swedish; ekologiczny in Polish. Note that "ecológico" and "ecologico" are also protected organic food terms, so food listings need extra care.
  4. Review images and video frame by frame. Infographics, comparison charts, badges and leaf icons on images 2 to 7 are where unofficial labels usually hide. Text inside images does not show up in a flat file search.
  5. Review A+ and Brand Story modules. Comparison tables and "our mission" banners often contain generic claims. Check every language version, since A+ content can differ by store.
  6. Sort every hit into three buckets. Remove (generic, offset-based, unofficial label); rewrite as a specific claim; or keep with evidence uploaded.
  7. Fix ad creative and Stores. Sponsored Brands headlines, custom images and Brand Store tiles are commercial communications too.
  8. Handle packaging. The Commission's Q&A says the rules cover existing stock, but stickers or corrections can bring printed packaging into line, and national authorities may weigh reasonable efforts. Online claims must be updated, so the listing cannot wait for the next print run.
  9. Update briefs and suppliers. Factory artwork often adds "eco" wording by default. Add a no-green-claims rule to supplier artwork approval.
  10. Re-check monthly. Listing contributions from other sellers and automated translations can reintroduce banned terms.

Restricted wording can also cause suppressions for other reasons; our restricted keywords guide covers how Amazon's filters behave. If you run many EU marketplaces, an account management team can run this audit as a routine task.

What are the common mistakes, and what are the penalties?

The usual mistakes are fixing only the German listing, only the text, or only the ASINs Amazon flagged. Each EU country sets penalties, and for coordinated cross-border cases national law must allow fines of at least 4% of annual turnover in the countries concerned. Amazon can also remove content or deactivate listings.

  • Translating instead of auditing. A clean English master copy does not help if a translation tool turned "durable" into a durability promise or added "ecológico."
  • Keeping a self-designed badge "because it is just a graphic." A trust mark you created is the clearest example of a banned label.
  • Swapping one vague word for another. Replacing "eco-friendly" with "conscious" or "responsible" leaves the same generic message.
  • Making whole-product claims from one component. Recycled packaging does not make the product recycled.
  • Ignoring durability language. "Indestructible" and "lasts a lifetime" are now in the same risk category as green claims if you cannot back them up.
  • Assuming the badge covers the copy. A Climate Pledge Friendly badge does not substantiate generic claims you write yourself.

On penalties, the 2019 amendments to the UCPD require that, for widespread infringements handled through coordinated enforcement, the maximum fine is at least 4% of the trader's annual turnover in the member states concerned, or at least EUR 2 million where turnover data is not available. Individual countries can go higher, and enforcement sits with national authorities and courts. In some countries competitors and consumer groups can also bring claims. This is general information, not legal advice; confirm your position with a lawyer in each country you sell to.

Is this the same as the EU Green Claims Directive?

No. The Green Claims Directive is another, still unadopted proposal from March 2023 that would require companies to prove explicit environmental claims with approved methods and independent verification before use. As of October 2026, the European Commission's green claims page lists the proposal's status as "Pending."

Many articles mix the two up, partly because the ECGT rules are often described as a "green claims ban." The difference matters for planning:

  • ECGT (Directive (EU) 2024/825) is law and applies from September 27, 2026. It bans specific practices and adds information duties.
  • The Green Claims Directive proposal would add pre-verification of claims and rules for labelling schemes. In June 2025 the Commission announced it intended to withdraw the proposal, mainly over its reach to micro-enterprises. Taylor Wessing reported that this position was walked back within days because the Commissioners had not agreed. It has not been adopted since, and the Commission still lists it as pending.

For an Amazon seller, the takeaway is simple. Do not wait for the Green Claims Directive before acting. The ECGT rules already apply, and they are enough to require a full clean-up of listing copy, images and packaging in EU stores.

Sources and data notes

Facts in this article were checked against the sources below on October 24, 2026. Amazon changes programs and dates often, so confirm details in Seller Central or the Amazon Ads console before you act.

Frequently Asked Questions

When do the EU green claims rules apply to Amazon listings?

They have applied since September 27, 2026. EU countries had until March 27, 2026 to pass national laws implementing Directive (EU) 2024/825, and those laws took effect on September 27. From that date, listings, images, A+ content and packaging aimed at EU consumers must meet the new rules, including for products already in stock.

Can I still use the word eco-friendly on amazon.de?

Only if you can show recognised excellent environmental performance that relates to the claim, for example an EU Ecolabel award or a nationally recognised type I ecolabel such as Blue Angel. Otherwise, replace it with a specific, provable statement, for example the percentage of recycled material and which part of the product it applies to.

Do the EU green claims rules apply to UK and US sellers?

Yes, when they sell to consumers in the EU. The rules apply to any commercial practice aimed at EU consumers, whatever the seller's location. A UK or US brand listing on amazon.fr or amazon.de must follow them. Listings shown only on amazon.co.uk or amazon.com are governed by UK or US law instead.

Is carbon neutral allowed on Amazon EU listings?

Not when the claim depends on offsetting emissions outside the product's value chain. That is banned in all circumstances. Companies can still describe investments in climate projects at brand level if the message is accurate and does not imply the product itself has no impact. Most sellers should remove carbon neutral wording from titles, bullets and images.

What is the GARAN label?

GARAN is the EU harmonised label for a producer's commercial guarantee of durability. It is used when the maker promises, free of charge, that the entire product will stay durable for longer than two years. When the producer shares that information, the seller must display the label prominently, for example next to the product image online.

Is the Green Claims Directive in force?

No. The Green Claims Directive was proposed in March 2023 but has not been adopted. The Commission signaled in June 2025 that it intended to withdraw it, reportedly reversed course within days, and its website still lists the proposal as pending. The rules in force are those of Directive (EU) 2024/825.

Does Climate Pledge Friendly make my green claims compliant in the EU?

No. The badge is displayed by Amazon based on recognized certifications, but it does not substantiate generic wording you add yourself. You can describe a specific certification accurately, but words like eco-friendly still need recognised excellent environmental performance. Amazon has not publicly explained how it applies the directive to the badge in EU stores.

What happens if Amazon flags my listing under the ECGT directive?

According to secondary reporting on Amazon's notices, Amazon may remove the section containing the claim after 15 days and may deactivate listings that still carried non-compliant claims on September 27, 2026. Remove or rewrite the claim, or upload supporting documents if it is a claim that can be substantiated, in each EU marketplace.

Want a second check on your EU listings?

SellerVine can audit your EU titles, bullets, images and A+ content for green and durability claims and help you rewrite them as specific, provable statements.

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