Can I put my own leaf logo on my packaging?

No. Annex I, point 2a, of Directive 2005/29/EC makes it unfair in all circumstances to display a sustainability label that is not based on a certification scheme or not established by public authorities. A label is allowed if a public authority established it — the directive names EMAS (Regulation (EC) No 1221/2009) and the EU Ecolabel (Regulation (EC) No 66/2010) — or if it rests on a certification scheme whose terms are publicly available, which is open on transparent and non-discriminatory terms, and compliance with which is monitored independently by a third party.

Is there a sell-by date for packaging already printed with the old claims?

Not one we could find. There is no sell-through period in the directive, none in the Finnish transposing act 573/2026, and the Dutch authority ACM publishes no deadline. Instead, the Consumer Protection Cooperation Network published a joint document on old stock: companies are expected to work towards full compliance in good time, and authorities may in specific cases take a genuine transitional situation into account, for example demonstrable old stock and demonstrable efforts to comply. The ACM adds that the pre-existing general rules on sustainability claims continue to apply, with no exception for old stock.

The EU green-claims rules — what you may no longer write on a label or in a listing (and the Dutch enforcement line)

Q: Since when do the EU green-claims rules apply?

Since 27 September 2026. Article 4(1) of Directive (EU) 2024/825 required Member States to adopt and publish their transposing measures by 27 March 2026 and to apply them from 27 September 2026. The directive itself was adopted on 28 February 2024 (OJ L, 2024/825, 6 March 2024).

Q: Which words are now banned on a label or in a listing?

Annex I, point 4a, of Directive 2005/29/EC now bans a generic environmental claim unless the trader can demonstrate recognised excellent environmental performance relevant to the claim. The directive's own examples of generic claims are 'environmentally friendly', 'eco-friendly', 'green', 'nature's friend', 'ecological', 'environmentally correct', 'climate friendly', 'gentle on the environment', 'carbon friendly', 'energy efficient', 'biodegradable' and 'biobased'. Point 4b bans whole-product claims when only an aspect is affected, and point 4c bans offsetting-based neutrality claims.

Q: Do the rules reach my webshop and advertising, or only the packaging?

They reach all commercial communication to consumers. 'Environmental claim' is defined in Article 2 of Directive 2005/29/EC as any message that is not mandatory by law, in any form, including text, pictorial, graphic or symbolic representation, such as labels, brand names, company names or product names. A generic claim stops being generic only if the specification is given in clear and prominent terms on the same medium — the directive names the same advertising spot, the product's packaging or the online selling interface.

The rule, and the date

The instrument is Directive (EU) 2024/825 of 28 February 2024, published in the Official Journal as OJ L, 2024/825, 6.3.2024, and commonly called the EmpCo or ECGT directive — "Empowering Consumers for the Green Transition". It does not create a new regime of its own. It amends two laws you already live with: the Unfair Commercial Practices Directive 2005/29/EC, which is the law behind most national rules on advertising to consumers, and the Consumer Rights Directive 2011/83/EC, which sets the information you owe before a distance sale.

The date is in Article 4(1), and it is why this note exists now: member states had to adopt and publish their transposing measures by 27 March 2026 and to apply them from 27 September 2026. That is the application date set by the directive itself, not a national one — so the same date runs in Finland, the Netherlands and everywhere else in the Union, however each member state wrapped it in national law.

What it is: A directive, so it works through national law. What you can be fined for is the national implementation — but the banned practices are written in the directive's own annex.
In force since: 27 September 2026, in every member state (Article 4(1)). Transposition itself was due by 27 March 2026.
Who it binds: Traders dealing with consumers — including a one-person shop, a marketplace seller and, on the plain wording of the definitions, claims about a brand, a product name or the business itself.
Where it applies: To commercial communication with consumers in the Union. Which authority pursues a seller established outside the country is a separate question, and one the sources we read do not answer — see what we could not establish.

The words that are now banned

The core new prohibition is Annex I, point 4a, of the Unfair Commercial Practices Directive. Annex I is the list of practices that are unfair in all circumstances — no case-by-case weighing, no defence that the consumer wasn't misled. Point 4a reads, in the directive's words, as making a generic environmental claim for which the trader is not able to demonstrate recognised excellent environmental performance relevant to the claim.

The directive names the phrases it has in mind. Its list of examples includes "environmentally friendly", "eco-friendly", "green", "nature's friend", "ecological", "environmentally correct", "climate friendly", "gentle on the environment", "carbon friendly", "energy efficient", "biodegradable" and "biobased" — and anything similar that suggests or creates the impression of excellent environmental performance.

The escape hatch is narrow: "Recognised excellent environmental performance" is a defined term: the EU Ecolabel under Regulation (EC) No 66/2010, a national or regional EN ISO 14024 type I ecolabelling scheme officially recognised in a member state, or top environmental performance under other Union law — the directive's own example is energy class A under Regulation (EU) 2017/1369.
Same medium, or it stays generic: A claim is not generic if the specification is given in clear and prominent terms on the same medium — the directive names the same advertising spot, the product's packaging or the online selling interface. Its example: "climate-friendly packaging" is generic, whereas "100% of energy used to produce this packaging comes from renewable sources" is specific.
Not the whole product: Point 4b bans an environmental claim about the entire product or the entire business when it concerns only an aspect of the product or one activity — the recyclable bottle with the non-recyclable cap is exactly this.
Not offsetting: Point 4c bans claiming, on the basis of offsetting greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment. "Climate-neutral because we plant trees" is the practice this targets.
Promises about the future: Article 6(2) of the Unfair Commercial Practices Directive is amended: a claim about future environmental performance — carbon or climate neutrality by a date — is prohibited unless it rests on clear, objective, publicly available and verifiable commitments and targets set out in a detailed and realistic implementation plan, with an independent third-party expert verifying progress and the findings made available to consumers.

Your own logo is the thing that goes

This is the change that removes work rather than adding it. Annex I, point 2a makes it unfair in all circumstances to display a sustainability label that is not based on a certification scheme or not established by public authorities. A house-designed green tick, a leaf, a "we care" roundel or a self-invented "carbon neutral" badge is precisely the practice named. There is no threshold and no size exemption.

A sustainability label is defined broadly: any voluntary trust mark, quality mark or equivalent, public or private, that sets apart and promotes a product, a process or a business by reference to its environmental or social characteristics, or both. Mandatory labels are outside the definition — a legal requirement is not a claim.

What is left: A label established by a public authority. The directive names two: the EU Ecolabel (Regulation (EC) No 66/2010) and EMAS (Regulation (EC) No 1221/2009). It also leaves room for additional forms of expression and presentation of food under Article 35 of Regulation (EU) No 1169/2011.
Or a real certification scheme: A third-party verification scheme whose terms, including its requirements, are publicly available and which is open on transparent, fair and non-discriminatory terms to every trader willing and able to comply; whose requirements were developed with relevant experts and stakeholders; which can suspend or withdraw use of the label for non-compliance; and whose monitoring is carried out by a third party whose competence and independence rest on international, Union or national standards.
Read that list as a test: Most self-made marks fail it at the first clause. So do marks from a scheme that the trader itself runs or that nobody outside the company can join on equal terms.
Examples seen in Dutch retail: The Dutch consumer programme Radar names the EU Ecolabel, Beter Leven and Rainforest Alliance as the kind of independent mark that remains. Secondary source, and the list is illustrative, not exhaustive — a mark still has to pass the test above.

Packaging, advertising, listings

The rules reach the whole of your consumer-facing communication, and the wording is deliberately wide. An environmental claim is any message or representation that is not mandatory under Union or national law, in any form, including text, pictorial, graphic or symbolic representation, such as labels, brand names, company names or product names, in the context of a commercial communication, which states or implies that a product, a product category, a brand or a trader has a positive or zero impact on the environment, or is less damaging than others, or has improved its impact over time.

Two consequences follow for a small shop. A phrase in your listing title, your bullet points, your product images or an ad is a claim in exactly the same way as printing it on the carton. And because a generic claim is only rescued by a specification on the same medium, adding the proof on a separate page is not the fix — the qualification has to travel with the claim.

Filtered and compared products: Article 7 of the Unfair Commercial Practices Directive is amended so that a trader offering a service that compares products, including on environmental or social characteristics or circularity aspects such as durability, repairability or recyclability, must give information about the method of comparison, the products compared, the suppliers, and the measures to keep the information up to date.
Information, not only prohibitions: The same directive adds pre-contractual information duties: durability, repairability, the negative effects of a software update, the availability of spare parts and the use of non-original parts where that affects functionality — plus a harmonised notice on the legal guarantee and a harmonised label where a producer offers a commercial guarantee of durability. The Dutch authority ACM says both are introduced by the same rule change.
Durability claims are claims too: Annex I also gains points on software updates that degrade goods, falsely claimed durability, presenting a good as repairable when it is not, and pushing earlier replacement of consumables. If you write "lasts five years" you are in this territory, not only in environmental territory.

The Dutch line: the ACM

In the Netherlands the supervisor is the Autoriteit Consument & Markt (ACM), and it has published the enforcement line itself. Its publication Vanaf 27 september 2026 strengere eisen aan duurzaamheidsclaims states that the Dutch implementing law for the EmpCo/ECGT directive entered into force on 27 September 2026, that the ACM is the designated supervisor, and that it calls on businesses to review their existing claims critically.

ACM board member Martijn Ridderbos puts the change in one sentence: there will be clearer requirements for sustainability claims and "a definitive end to the use of company quality marks that are not independent". The ACM's own guidance for businesses adds that the pre-existing general rules on sustainability claims continue to apply alongside the new ones — "no exception" for old stock.

Vague words without substantiation: Claims such as "groen", "milieuvriendelijk" or "ecologisch" may only be made without further explanation if they meet strict European or national standards — and the ACM's guidance says only a few officially recognised marks do.
Labels: A sustainability label may only be used if a public authority established it or if it is based on a certification scheme meeting the legal criteria. The ACM lists them: transparent, open and fair so that compliant traders can take part; drawn up with relevant experts and stakeholders; a procedure to suspend or withdraw the mark for non-compliance; and independent monitoring of compliance.
Old stock: The ACM acknowledges that old stock is a real problem, especially for slow-moving products, and that goods already on the shelves might otherwise have to be recalled or destroyed. Its answer is not a deadline but a document — see below.
Consumers who cannot tell the difference: The consumer programme Radar reports that a third of consumers cannot distinguish an independent certification mark from a fake logo. That is the mischief the label ban addresses. Secondary source; the ACM's own publications do not quote a figure.

The Finnish line

Finland transposed the directive by amending the Consumer Protection Act: laki kuluttajansuojalain muuttamisesta 573/2026, given on 26 June 2026. Read on Finlex, its entry-into-force provision is worth knowing because it is staggered: chapters 5 and 8 applied from 31 July 2026, and chapters 2 and 6 from 27 September 2026 — so the marketing chapter runs on the EU date. Contracts made before entry into force are governed by the provisions that were in force when they were made.

Chapter 2 is the marketing chapter, and it is where the new duties sit. Supervision is unchanged: marketing and conduct in customer relationships are supervised in the consumer interest by the Consumer Ombudsman (kuluttaja-asiamies).

New 2:6a: A ban on marketing a consumer good with aspects that are irrelevant and do not relate to the characteristics of the good, the trader or the business, where that is likely to lead the consumer into a purchase decision they would not otherwise have made.
New 2:6b: Environmental claims about future environmental performance may not be used in marketing or in a customer relationship without clear, objective, publicly available and verifiable commitments. Those commitments must be set out in a detailed, feasible implementation plan with measurable targets, and an independent outside expert must regularly verify progress with the findings made available to consumers.
The list of misleading facts grows: Section 2:6 now treats as potentially misleading a statement about the durability, repairability and recyclability of goods and other environmental, social and circular-economy characteristics — the durability and circularity mention is the new part.
New 2:8f: A duty on a trader who offers a service comparing consumer goods to give information about the comparison of environmental and social impacts — the Finnish counterpart of the comparison-tool duty.
The guarantee label: For distance selling, chapter 6 points to Commission Implementing Regulation (EU) 2025/1960 for the layout and content of the harmonised notice on the legal guarantee of conformity and the harmonised label for a commercial guarantee of durability. That is the same "standard label" the Dutch coverage describes.

The Finnish act is not a translation of the directive's annex. We read 573/2026 and the consolidated Consumer Protection Act on Finlex and could not find the bare-bones bans of Annex I points 2a and 4a in that text — a trader's own label and a generic claim. What we did find is listed above. Either they sit in provisions we failed to identify, or in another act; we are not going to guess. If you know where they are, tell us — see what we could not establish.

Old stock, and the date nobody fixed

You may have read that goods already labelled the old way stay sellable for six months, until late March 2027. We could not verify that, and we are not printing it as a rule. What the texts say is narrower and less comfortable.

The directive: Contains no sell-through or stock period. It sets one date — 27 September 2026 — and nothing about goods printed before it.
The Finnish act: Contains no label transition either. Its only transitional provision concerns contracts concluded before entry into force.
What actually exists in the Netherlands: The Consumer Protection Cooperation Network, the network of European consumer authorities, published a joint document on old-stock situations at the ACM's initiative. It says companies are expected to work towards full compliance in good time, and that authorities can take genuine transitional problems into account in specific cases — for example demonstrable old stock plus demonstrable efforts to comply as quickly as possible.
Read it as discretion, not a deadline: It is a statement of how enforcers intend to exercise judgement in particular cases. It is not a period during which the rules do not apply, and the ACM says in terms that the pre-existing general rules on sustainability claims continue to apply, with no exception for old stock.

Practical translation. A box with "100% eco-friendly" on it is a live claim the day you ship it, whether it was printed in 2024 or last week. Old stock is an argument you might be able to make if challenged, not a plan.

A checklist for a small seller

This is an audit you can do in an afternoon for a small catalogue. It is a reading of the sources on this page, not legal advice.

1. Collect every claim you make: Listing title, description, bullet points, image overlays, packaging, inserts, care cards, ad copy, social posts, the "about" text of your shop, and any sustainability filter or comparison page you run. Images and text count together, and a colour or a leaf can carry the claim by itself.
2. Split them in two: Claims you can evidence, and claims you cannot. Then look hard at the first pile: the evidence has to be current, and for the strong ones you need recognised excellent environmental performance, not a supplier's estimate.
3. Delete the adjectives, or specify them on the same medium: "Sustainable", "eco-friendly", "green", "natural", "climate neutral" as bare statements go. "Made from 70% recycled material" can stay if it is true and supported. If you keep a broad word, the specification has to sit in the same listing or on the same packaging — not on a linked page.
4. Take your own logo off: Any sustainability mark you designed, for your shop or for a product line, has no route through Point 2a unless a public authority established it or it rests on a real certification scheme with independent monitoring. Removing it is cheaper than defending it.
5. If you promise a future target, write the plan: A dated commitment needs an implementation plan with measurable targets and independent verification, with the findings available to consumers. If you cannot produce that, drop the commitment.
6. Date the file: Every claim you keep should have a source and a date next to it in a folder you can open in five minutes. That is the same evidence discipline the rest of this site asks for, and it is what a substantiation request actually tests.
7. Ask what your marketplace does: If the platform writes the claim, the platform is also exposed — but so is your listing. Check what your shop template says about sustainability before you assume the text was someone else's problem.

What we could not establish

We would rather leave a gap visible than fill it with something plausible.

A sell-by date for old stock: We found no six-month period and no March 2027 date in the directive, in the Finnish act 573/2026, or in the ACM's publications. What exists is the Consumer Protection Cooperation Network document on old-stock situations, which sets out discretion rather than a deadline.
Whether the old-stock relief reaches online sellers: The network document speaks of old stock, not of where it is offered. The Dutch coverage is written from the consumer's point of view and does not say whether a webshop listing counts. Nobody in the sources distinguishes.
How a seller established outside the Union is treated: The national rules are supervised nationally — the ACM in the Netherlands, the Consumer Ombudsman in Finland. How those authorities pursue a trader with no establishment in their country is not addressed in the sources we read. The general direction of EU consumer enforcement is cross-border, which is why this is not a reason to ignore the rules.
The Finnish act's own-label and generic-claim bans: We could not locate them in 573/2026 or the consolidated Consumer Protection Act on Finlex. Either they sit in a provision we did not identify or in a separate act. If you find them, bring them in.
The Dutch implementing act's name and number: The ACM refers to "de Nederlandse implementatiewet" and says it has passed the Tweede and Eerste Kamer, but we have not verified its official title or number, so we do not print one.
The Finnish retailer numbers: You may see Finnish coverage reporting how many own-brand products the grocers relabelled. We could not open a citable article for those figures, so we do not repeat them. The rule is the directive and the national act — what a particular retailer did is market evidence, not a duty.

Sources

The directive text and the two authorities are the backbone. Everything interpretive is attributed to whoever said it, and secondary sources are marked as such. We read Directive (EU) 2024/825 in full for this page, plus the Finnish transposing act, the consolidated Consumer Protection Act and the ACM's publications.

Directive (EU) 2024/825 — EUR-Lex The authoritative text, adopted 28 February 2024, OJ L, 2024/825, 6.3.2024. Source for Article 4(1) on the 27 March 2026 transposition deadline and the application date of 27 September 2026; the new definitions of environmental claim, generic environmental claim, sustainability label, certification scheme and recognised excellent environmental performance in Article 2 of Directive 2005/29/EC; Annex I points 2a, 4a, 4b, 4c, 10a and 23d–23j; the amendments on future-performance claims in Article 6(2) and on comparison services in Article 7; the EMAS and EU Ecolabel examples; and the "climate-friendly packaging" example. Read in full for this page
ACM — Vanaf 27 september 2026 strengere eisen aan duurzaamheidsclaims Official, Netherlands. Source for the Dutch implementing law entering into force on 27 September 2026, for the ACM as designated supervisor, for the ACM's call to review existing claims, for the quotation attributed to board member Martijn Ridderbos, for claims such as "groen", "milieuvriendelijk" and "ecologisch" needing strict European or national standards, for the label criteria including independent control and transparency, and for the information and guarantee-label duties
ACM — Toelichting op de toepassing van de EU-richtlijn duurzaamheidsclaims bij oude voorraden Official, Netherlands. Source for the Consumer Protection Cooperation Network's joint document on old-stock situations, for companies being expected to work towards full compliance in good time, for authorities being able to take demonstrable old stock and demonstrable compliance efforts into account, for labels needing a recognised certification system or a public authority, and for the existing general rules applying with no exception for old stock
ACM — Duurzaamheidsinformatie (guidance for traders) Official, Netherlands. Source for general claims being prohibited unless recognised excellent environmental performance can be demonstrated, for only a few officially recognised marks qualifying, for the whole-product rule and its bottle-and-cap example, for "Groen onderweg" against "Deze vrachtwagen rijdt 100% elektrisch", for "Duurzaam geproduceerd" against "Gemaakt met 70% gerecycled materiaal", for the substantiation and future-goal requirements, for the bar on offsetting-based neutrality claims, and for the four criteria a certification scheme must meet
Laki kuluttajansuojalain muuttamisesta 573/2026 — Finlex Official, Finland (Finnish and Swedish). The transposing act given on 26 June 2026. Source for its entry into force in two stages — chapters 5 and 8 from 31 July 2026, chapters 2 and 6 from 27 September 2026 — and for contracts made before entry into force being governed by the provisions then in force
Kuluttajansuojalaki 38/1978, consolidated — Finlex Official, Finland. Source for the new 2:6a ban on marketing with irrelevant aspects, the new 2:6b on claims about future environmental performance with an implementation plan and independent expert verification, the durability, repairability and recyclability addition to 2:6, the new 2:8f comparison-information duty, the reference in chapter 6 to Commission Implementing Regulation (EU) 2025/1960 on the harmonised guarantee notice and label, and the Consumer Ombudsman's role in supervising marketing and conduct in customer relationships
AVROTROS Radar — Strengere eisen aan duurzaamheidsclaims op producten Secondary, consumer programme, 3 October 2026. Source for the third of Dutch consumers who cannot tell an independent certification mark from a fake logo, and for the EU Ecolabel, Beter Leven and Rainforest Alliance being named as marks that remain. Its framing that the ACM has allowed supermarkets to sell off old stock is superseded here by the ACM's own publications, cited above

Tell us what we got wrong

Two gaps above are worth a source on their own: where the Finnish act puts the own-label and generic-claim bans, and whether any authority has set a transition period for old stock with a date on it. A source we can open beats ten pages of commentary, and we will correct this page in public if it turns out we have something wrong.

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