Why ‘eco-friendly’ packaging claims are becoming harder to make

From 27 September 2026, new EU consumer rules will make it harder for companies to use generic environmental claims such as “eco-friendly” and “green”. For packaging manufacturers and brands, the change puts greater emphasis on specificity, substantiation and credible certification.

Packaging manufacturers and brands selling into the European Union face tighter rules on how they communicate environmental credentials from 27 September 2026.

From that date, Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive, will strengthen EU consumer protection rules covering environmental claims and sustainability labels.

The rules prohibit generic environmental claims where recognised excellent environmental performance relevant to the claim cannot be demonstrated. The legislation identifies terms including “environmentally friendly”, “eco-friendly”, “green”, “ecological”, “climate friendly”, “carbon friendly”, “biodegradable” and “biobased” among examples of claims that can fall within the prohibition.

This is not a blanket ban on environmental marketing. Instead, it marks a shift away from broad green language towards specific statements that companies can substantiate.

For the packaging industry, the change is particularly relevant because environmental claims appear directly on packs, product pages, advertising and sustainability labels.

From green language to specific claims

The central issue is the difference between a broad environmental assertion and a specific, demonstrable claim.

“Eco-friendly packaging” can create a broad impression about the environmental performance of the entire pack. A statement identifying a particular characteristic is more precise. For example, a company might state that a defined proportion of the energy used to manufacture a particular packaging product comes from renewable sources.

The EU legislation recognises this distinction. Where the environmental specification of a claim is provided in clear and prominent terms on the same medium, the claim is not considered generic for the purposes of this particular prohibition. Other rules against misleading consumers still apply.

For packaging marketers, the practical lesson is straightforward: specificity matters.

A manufacturer may have lightweighted a bottle, increased the recycled content of a container or changed the energy used in production. Each may represent a genuine environmental improvement. None automatically justifies describing the entire pack as “sustainable” or “eco-friendly”.

The evidence needs to support the specific proposition being communicated.

The distinction between a component and the whole pack also matters. An environmental benefit associated with one material or component should not be presented in a way that suggests the same benefit applies to the entire packaging system.

What the rules mean for packaging claims

Packaging presents particular challenges because environmental claims can depend on more than the material itself.

Terms such as “recyclable”, “made with recycled content”, “compostable”, “biodegradable” and “plastic-free” can influence purchasing decisions. Their meaning may depend on the composition of the pack, how it should be disposed of and, in some cases, the waste-management infrastructure available to consumers.

This is already an issue in the UK.

Advertising Standards Authority guidance reflects research showing that consumers can interpret terms such as “recyclable”, “biodegradable” and “compostable” in different ways. Information about composition, disposal methods, relevant conditions and the outcome of disposal may therefore need to accompany such claims.

The Competition and Markets Authority’s Green Claims Code similarly requires environmental claims to be truthful and accurate and not to create a misleading impression through their wording or through important information being omitted.

The CMA specifically warns businesses against describing packaging as recyclable when it is not, or where only some of its components can be recycled.

For packaging companies, the implication is clear: environmental claims need to be assessed against the actual characteristics of the pack, rather than the intention behind the marketing.

Why ‘recyclable’ can be complicated

“Recyclable” is among the most important environmental claims used on packaging, but it can also be difficult to communicate without creating a misleading impression.

The question is not simply whether a material can technically be recycled. Companies also need to consider what consumers are likely to understand from the claim and whether important limitations or disposal requirements have been omitted.

For brands operating across several markets, the issue can become more complex. Collection, sorting and recycling systems vary between countries and, in some cases, between regions.

A packaging format may have an established recycling route in one market but face more limited collection or sorting infrastructure in another. Marketing teams therefore need to understand the basis and conditions for a recycling claim before putting it on packaging, advertising or an online product page.

UK advertising guidance provides a useful example. An unqualified claim that packaging is “widely recycled” is more likely to be misleading where there is not evidence that the material is recycled by the majority of local authorities.

This does not mean every claim needs to describe every aspect of every local waste-management system. It does mean companies should be able to substantiate the claim and communicate relevant qualifications where they are needed to prevent consumers from being misled.

Evidence needs to come before marketing

The changing regulatory environment is also raising the importance of substantiation.

Under the EU rules, recognised excellent environmental performance can include compliance with the EU Ecolabel Regulation, officially recognised EN ISO 14024 Type I ecolabelling schemes in EU member states, or top environmental performance for a specific characteristic under other applicable EU law.

This sets a higher bar than simply having a positive sustainability story.

A packaging manufacturer might have reduced the amount of material in a pack, incorporated recycled content or switched part of its manufacturing process to renewable energy. Those changes can be meaningful.

But evidence of one improvement does not necessarily support a broader claim about the environmental performance of the whole pack.

The UK Green Claims Code follows the same basic principle. Businesses are expected to hold robust, credible, relevant and up-to-date evidence for environmental claims.

Depending on the claim, supporting evidence might include material specifications, recycled-content documentation, testing, certification, production data, supplier information or lifecycle assessment.

The starting point should therefore be the claim itself: what precisely is the company telling the customer, and what evidence supports it?

Four questions to ask before making a green claim

Environmental claims should not be treated solely as a marketing decision.

Packaging specialists may understand material composition and manufacturing processes. Procurement teams may hold supplier documentation. Sustainability teams may have lifecycle or environmental data, while legal and compliance specialists assess whether a proposed claim is permissible in the markets where the product will be sold.

Bringing those functions together can help companies identify problems before a claim reaches packaging artwork or an online product page.

Four questions provide a useful starting point.

What exactly are we claiming?

A statement such as “sustainable packaging” can imply several different environmental benefits. A narrower factual claim is generally easier for consumers to understand and for a company to substantiate.

What part of the pack does the claim cover?

Evidence relating to one component should not be presented in a way that suggests the same environmental characteristic applies to the entire pack.

What evidence supports the claim?

Companies should be able to identify the testing, data, certification, supplier documentation or other evidence that substantiates the proposition being communicated.

Could consumers interpret the claim more broadly than intended?

Technical accuracy alone is not necessarily enough. A statement can be factually correct while the overall presentation gives consumers a broader impression than the evidence supports.

Sustainability labels face closer scrutiny

Words are not the only way packaging communicates environmental performance.

Logos, symbols, certification marks and other visual devices can carry substantial marketing weight. The EU directive therefore also introduces requirements concerning voluntary sustainability labels.

It prohibits the display of sustainability labels that are not based on a certification scheme or established by public authorities. Certification schemes must meet requirements covering areas including transparency, access, compliance monitoring and independent third-party assessment.

The rules also recognise that packaging design and imagery can contribute to the environmental impression received by consumers.

Replacing the words “green” or “eco-friendly” with leaves, nature imagery or similar visual cues does not necessarily remove the communication from regulatory scrutiny if the overall presentation creates a generic environmental claim.

For packaging businesses, reviewing environmental marketing therefore means looking at the whole pack, rather than checking individual words in isolation.

What about the EU Green Claims Directive?

The Green Claims Directive is separate from the Empowering Consumers for the Green Transition Directive, and the two should not be confused.

Proposed by the European Commission in 2023, the Green Claims Directive was intended to create a broader framework for the substantiation, communication and verification of explicit environmental claims.

As of August 2026, the European Parliament’s Legislative Train Schedule lists the proposal as “blocked”. It should therefore not be presented as an adopted EU obligation for packaging companies.

The distinction matters.

Directive (EU) 2024/825 has been adopted and its rules apply from 27 September 2026. The proposed Green Claims Directive is a separate legislative file.

For businesses planning compliance, the immediate focus should be on the rules that have already been adopted, while continuing to monitor developments around the separate Green Claims proposal.

What packaging companies should do now

Tighter regulation does not mean companies need to abandon environmental claims. It means they need to make those claims more precise, evidence-based and transparent.

A useful starting point is an audit of environmental claims across packaging artwork, websites, online marketplaces, brochures and advertising.

Businesses can identify broad terms such as “eco-friendly”, “green”, “sustainable”, “climate friendly” and “biodegradable” and establish exactly what each statement is intended to communicate.

Each claim can then be matched to the evidence supporting it.

Where the evidence supports a narrower proposition, replacing a broad environmental promise with a specific factual statement can make the communication clearer and more defensible.

Sustainability logos and third-party labels should also be reviewed, particularly where their certification basis, verification process or requirements are unclear.

Companies should also review packaging and products already moving through the supply chain. In June 2026, EU consumer-protection authorities issued a common understanding covering “old stock” carrying environmental claims or sustainability labels that was manufactured, ordered, distributed or placed on retailers’ shelves before 27 September 2026. The authorities said traders are expected to take timely, good-faith steps to adapt their business-to-consumer practices to the new rules.

This is more than a compliance exercise. Clearer environmental claims can help customers distinguish demonstrable improvements in packaging from general marketing language.

The end of vague green marketing

The regulatory response to greenwashing is changing the way environmental claims are made.

For packaging companies, the practical test is becoming simpler: say precisely what has improved, make clear what the claim covers and keep the evidence that proves it.

As environmental claims face closer scrutiny, specific, credible and verifiable information is becoming a more durable way for packaging businesses to communicate environmental performance.