On September 27th, 2026 — this Sunday — the European Union’s Empowering Consumers for the Green Transition Directive, (EU) 2024/825, starts applying. From that day, a set of sustainability claims that have sat unchallenged in marketing copy, on packaging, and across corporate websites become, in plain terms, illegal.
This is not a communications problem. It is a legal and governance exposure sitting inside language your organization wrote years ago and stopped thinking about.
What gets banned
Three categories matter most:
Generic environmental claims. Words like “green,” “eco-friendly,” “climate friendly,” or “sustainable” — made without recognized, substantiated backing — will be prohibited. Vagueness is no longer a shield; it is the offense.
Self-made sustainability labels. Private labels and certifications your organization invented, that no independent body verifies, will be banned. If the label is yours and the verification is yours, the label goes.
Offset-based greenhouse-gas claims. This is the one that will sting. Claims like “carbon neutral” or “climate neutral” founded on offsetting — paying for emissions reductions elsewhere rather than reducing your own — will be prohibited. A decade of net-zero marketing, built on purchased absolutes, loses its legal footing.
The penalties are real
Member states are required to set effective, proportionate, and dissuasive penalties. For cross-border infringements, the directive requires maximum fines of no less than 4% of the trader’s annual turnover in the member state or states concerned — or at least €2 million where turnover figures are unavailable — alongside possible exclusion from public procurement. Treat those numbers as the shape of the risk, not the final word: exact enforcement sits with each member state’s transposition. The direction is unambiguous — Brussels intends these rules to bite.
This was never just a European story
If your organization does not operate in the EU, read this as an early warning, not someone else’s problem. Regulatory standards migrate. What Brussels prohibits this year becomes the benchmark your investors, your insurers, your litigation opponents, and eventually your own regulators measure you against. The companies that treat September 27th as a European administrative event will be the ones explaining themselves in other jurisdictions later.
The deeper truth: these were belief gaps made illegal
Here is what interests me, after nearly fifty years inside this work.
“Carbon neutral through offsetting” was never a strategy. It was a belief — unexamined, inherited, repeated across an industry until it felt like fact. Nobody asked what had to be assumed for the claim to be true. The assumption was that paying for reductions elsewhere was the same as reducing your own emissions. It was not. It never was.
The directive does not fix that thinking. It prices the symptom. The disease — the unexamined assumption underneath the claim — is still sitting in your strategy documents, your disclosures, and increasingly, in the AI systems now drafting them at machine speed.
Every banned claim on that list began as a belief gap: the distance between what an organization believed and what it could substantiate. Brussels has now made a subset of those gaps illegal. The rest are still yours to find.
What to do this week
Three steps, in order:
1. Inventory every claim. Every “green,” “sustainable,” “carbon neutral,” every private label, every offset-based statement — on your website, your packaging, your investor materials. All of it, in one list.
2. Strike what you cannot substantiate. Not what you believe. What you can prove, to the standard the directive demands. If in doubt, it goes.
3. Examine the beliefs that produced them. This is the step almost everyone skips, and it is the only one that prevents recurrence. For each struck claim, ask: what had to be assumed for us to publish that? Who examined the assumption? When? The claims are the surface. The assumptions are the system that made them.
The organizations that do all three will come out of this stronger — not just compliant, but clearer about what they actually stand on. The ones that do only the first two will be back here with the next directive.
Ken Alston has spent nearly fifty years inside sustainability — twenty years at SC Johnson, seventeen alongside William McDonough and Michael Braungart and a decade of independent Inquiry/private practice. He keynotes on the assumptions hiding inside executive decisions, and the morning-after workshop that exposes them. Bring Ken to your stage →


