Kilde › Guides › Green claims › The banned green-claims phrases, one b…
Current to 21 August 2026 · updates land in the changelog.
UCPD Annex I point 4a bans generic environmental claims in all circumstances unless the claim is specified in clear and prominent terms on the same medium, or carried by the narrow recognised-excellent-performance carve-out. Recital 9 lists the phrase family; recital 10 closes the carve-out for some words entirely. One section per phrase, each with a rewrite that survives.
Short answer: not as a bare claim. From 27 September 2026, making a generic environmental claim without being able to demonstrate recognised excellent environmental performance relevant to that claim is banned in all circumstances — UCPD Annex I point 4a, inserted by Directive (EU) 2024/825.
It sits in the recital-9 family of generic environmental claims — the examples the directive itself names as banned when unspecified: “environmentally friendly”, “eco-friendly”, “green”, “climate friendly” and similar.
The archetypal generic claim — recital 9 names it first. On pack, in ads or on a homepage it asserts excellent environmental performance without saying in what respect.
Made with 74% post-consumer recycled aluminium (verified March 2026)
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
Adding a leaf icon or green colourway next to the phrase makes it worse, not better — imagery counts toward the overall impression.
As a generic, unspecified environmental claim, yes — banned in all circumstances under UCPD Annex I point 4a unless specified on the same medium or carried by the narrow recognised-performance carve-out.
Replace or accompany it with a specific, substantiated statement — a number and a scope on the same medium — or qualify via the EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
Not on its own, no. From 27 September 2026, generic environmental claims are banned in all circumstances unless the trader can demonstrate recognised excellent environmental performance relevant to the claim — the rule is UCPD Annex I point 4a, inserted by Directive (EU) 2024/825.
The directive's own recital 9 names the family this word belongs to: generic environmental claims like “environmentally friendly”, “eco-friendly”, “green” and “climate friendly”, banned whenever they run unspecified.
Functionally identical to 'environmentally friendly' and named separately in recital 9; the hyphenated shorthand is the single most common phrase we see in EU product listings.
Refill system cuts packaging plastic by 62% per litre versus our 2024 bottle
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
Marketplace bullet points count as the same medium as the listing title — a specification buried in a linked PDF does not despecify the bullet.
Used bare, yes: point 4a of the UCPD blacklist bans it in all circumstances from that date, unless the claim is specified on the same medium or the narrow recognised-performance carve-out carries it.
Two options: turn it into a specific, substantiated statement (a number and a scope, on the same medium), or carry it on the carve-out — the EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
As a bare claim, it stops being lawful on 27 September 2026. That is when UCPD Annex I point 4a (inserted by Directive (EU) 2024/825) starts banning generic environmental claims outright wherever recognised excellent environmental performance relevant to the claim cannot be demonstrated.
This is recital-9 territory: the list of generic environmental claims the directive itself gives as examples — “environmentally friendly”, “eco-friendly”, “green”, “climate friendly” and the rest of the family — all banned as bare wording.
As a product descriptor ('green energy tariff', 'green delivery') it is a generic claim; as a literal colour word ('green T-shirt') it is not. Context decides, and the register should record which use you make.
Delivery by electric vehicle on 100% of last-mile routes in our own fleet
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
Brand names containing 'green' are not automatically banned, but pairing the name with environmental imagery can turn the overall presentation into a generic claim.
Yes, whenever it runs unspecified. From that date UCPD Annex I point 4a bans the generic form outright; specification on the same medium, or the narrow recognised-performance carve-out, are the only ways through.
Either specify it into a substantiated claim with a number and a scope on the same medium, or hold the narrow carve-out: EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
Short answer: not as a bare claim. From 27 September 2026, making a generic environmental claim without being able to demonstrate recognised excellent environmental performance relevant to that claim is banned in all circumstances — UCPD Annex I point 4a, inserted by Directive (EU) 2024/825.
It sits in the recital-9 family of generic environmental claims — the examples the directive itself names as banned when unspecified: “environmentally friendly”, “eco-friendly”, “green”, “climate friendly” and similar.
Recital 9 includes it to show the list reaches folksy variants, not just technical vocabulary — any 'kind to nature' formulation sits in the same family.
Sourced from FSC-certified forests (licence C000000)
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
Translating the phrase into another EU language does not escape the family — the directive's examples are illustrative, 'or similar'.
As a generic, unspecified environmental claim, yes — banned in all circumstances under UCPD Annex I point 4a unless specified on the same medium or carried by the narrow recognised-performance carve-out.
Replace or accompany it with a specific, substantiated statement — a number and a scope on the same medium — or qualify via the EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
Not on its own, no. From 27 September 2026, generic environmental claims are banned in all circumstances unless the trader can demonstrate recognised excellent environmental performance relevant to the claim — the rule is UCPD Annex I point 4a, inserted by Directive (EU) 2024/825.
The directive's own recital 9 names the family this word belongs to: generic environmental claims like “environmentally friendly”, “eco-friendly”, “green” and “climate friendly”, banned whenever they run unspecified.
Common in continental usage ('ökologisch', 'écologique', 'ecológico'); the recital-9 family covers it in every language version.
Certified to the EU Ecolabel for laundry detergents (licence number on pack)
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
'Ecological' inside a certification's official name is the certification's claim, not yours — but only if the scheme actually qualifies under Art 2(s).
Used bare, yes: point 4a of the UCPD blacklist bans it in all circumstances from that date, unless the claim is specified on the same medium or the narrow recognised-performance carve-out carries it.
Two options: turn it into a specific, substantiated statement (a number and a scope, on the same medium), or carry it on the carve-out — the EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
As a bare claim, it stops being lawful on 27 September 2026. That is when UCPD Annex I point 4a (inserted by Directive (EU) 2024/825) starts banning generic environmental claims outright wherever recognised excellent environmental performance relevant to the claim cannot be demonstrated.
This is recital-9 territory: the list of generic environmental claims the directive itself gives as examples — “environmentally friendly”, “eco-friendly”, “green”, “climate friendly” and the rest of the family — all banned as bare wording.
A stiffer variant of the same promise; recital 9 lists it to close the 'we said correct, not friendly' loophole.
Meets the EU Ecodesign minimum for standby power (≤0.5 W)
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
Compliance with a legal minimum marketed as distinction can separately fail point 10a — legal requirements are not a virtue.
Yes, whenever it runs unspecified. From that date UCPD Annex I point 4a bans the generic form outright; specification on the same medium, or the narrow recognised-performance carve-out, are the only ways through.
Either specify it into a substantiated claim with a number and a scope on the same medium, or hold the narrow carve-out: EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
Short answer: not as a bare claim. From 27 September 2026, making a generic environmental claim without being able to demonstrate recognised excellent environmental performance relevant to that claim is banned in all circumstances — UCPD Annex I point 4a, inserted by Directive (EU) 2024/825.
It sits in the recital-9 family of generic environmental claims — the examples the directive itself names as banned when unspecified: “environmentally friendly”, “eco-friendly”, “green”, “climate friendly” and similar.
Recital 9's own worked example: 'climate-friendly packaging' is generic; '100% of energy used to produce this packaging comes from renewable sources' is specific — a full sentence, a number and a scope, on the same medium.
100% of energy used to produce this packaging comes from renewable sources
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
The specification must sit on the same medium as the claim — same pack panel, same ad, same page. A footnote on another page does not despecify a homepage headline.
As a generic, unspecified environmental claim, yes — banned in all circumstances under UCPD Annex I point 4a unless specified on the same medium or carried by the narrow recognised-performance carve-out.
Replace or accompany it with a specific, substantiated statement — a number and a scope on the same medium — or qualify via the EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
Not on its own, no. From 27 September 2026, generic environmental claims are banned in all circumstances unless the trader can demonstrate recognised excellent environmental performance relevant to the claim — the rule is UCPD Annex I point 4a, inserted by Directive (EU) 2024/825.
The directive's own recital 9 names the family this word belongs to: generic environmental claims like “environmentally friendly”, “eco-friendly”, “green” and “climate friendly”, banned whenever they run unspecified.
Soft-focus phrasing is still a performance claim; the recital-9 family is about the promise made, not the vocabulary register.
Fragrance-free formula; 94% of ingredients readily biodegradable per OECD 301
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
Pairing the phrase with pastel packaging and nature imagery compounds the generic impression rather than diluting it.
Used bare, yes: point 4a of the UCPD blacklist bans it in all circumstances from that date, unless the claim is specified on the same medium or the narrow recognised-performance carve-out carries it.
Two options: turn it into a specific, substantiated statement (a number and a scope, on the same medium), or carry it on the carve-out — the EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
As a bare claim, it stops being lawful on 27 September 2026. That is when UCPD Annex I point 4a (inserted by Directive (EU) 2024/825) starts banning generic environmental claims outright wherever recognised excellent environmental performance relevant to the claim cannot be demonstrated.
This is recital-9 territory: the list of generic environmental claims the directive itself gives as examples — “environmentally friendly”, “eco-friendly”, “green”, “climate friendly” and the rest of the family — all banned as bare wording.
Sits at the border of the generic-claims family and the point-4c offsetting ban: if the friendliness rests on offsets, 4c bans it outright; if it rests on reductions, it must be specified.
Manufacturing emissions cut 31% per unit since 2024 (site energy data, verified)
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
If any part of the claim's basis is offsetting, no specification cures it — point 4c attaches to the offsetting basis itself.
Yes, whenever it runs unspecified. From that date UCPD Annex I point 4a bans the generic form outright; specification on the same medium, or the narrow recognised-performance carve-out, are the only ways through.
Either specify it into a substantiated claim with a number and a scope on the same medium, or hold the narrow carve-out: EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
Short answer: not as a bare claim. From 27 September 2026, making a generic environmental claim without being able to demonstrate recognised excellent environmental performance relevant to that claim is banned in all circumstances — UCPD Annex I point 4a, inserted by Directive (EU) 2024/825.
It sits in the recital-9 family of generic environmental claims — the examples the directive itself names as banned when unspecified: “environmentally friendly”, “eco-friendly”, “green”, “climate friendly” and similar.
Generic on its own — but this family has the cleanest fix in the whole list, because an official measurement scale exists.
Energy class B under Regulation (EU) 2017/1369 (label on product page)
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
An energy rating carries only energy claims — recital 10: demonstrated performance must be relevant to the entire claim, so class A does not support 'biodegradable' or 'sustainable'.
As a generic, unspecified environmental claim, yes — banned in all circumstances under UCPD Annex I point 4a unless specified on the same medium or carried by the narrow recognised-performance carve-out.
Replace or accompany it with a specific, substantiated statement — a number and a scope on the same medium — or qualify via the EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
Not on its own, no. From 27 September 2026, generic environmental claims are banned in all circumstances unless the trader can demonstrate recognised excellent environmental performance relevant to the claim — the rule is UCPD Annex I point 4a, inserted by Directive (EU) 2024/825.
The directive's own recital 9 names the family this word belongs to: generic environmental claims like “environmentally friendly”, “eco-friendly”, “green” and “climate friendly”, banned whenever they run unspecified.
Sounds technical but is generic without conditions: biodegrades where, in what timeframe, under what process? Recital 9 lists it alongside the folksy phrases for exactly that reason.
Certified industrially compostable (EN 13432); not suitable for home composting
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
Claiming compostability without naming the required facility conditions is the classic trap — 'biodegradable' bags that survive a home compost heap invite both 4a and the general misleading tests.
Used bare, yes: point 4a of the UCPD blacklist bans it in all circumstances from that date, unless the claim is specified on the same medium or the narrow recognised-performance carve-out carries it.
Two options: turn it into a specific, substantiated statement (a number and a scope, on the same medium), or carry it on the carve-out — the EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
As a bare claim, it stops being lawful on 27 September 2026. That is when UCPD Annex I point 4a (inserted by Directive (EU) 2024/825) starts banning generic environmental claims outright wherever recognised excellent environmental performance relevant to the claim cannot be demonstrated.
This is recital-9 territory: the list of generic environmental claims the directive itself gives as examples — “environmentally friendly”, “eco-friendly”, “green”, “climate friendly” and the rest of the family — all banned as bare wording.
A materials claim that reads like an environmental one; without a percentage and a standard it stays in the generic family.
Contains 87% bio-based carbon content, measured per EN 16640
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
Part-bio-based products claiming the whole ('plant-based bottle' for a 30% bio-PET blend) also engage point 4b — whole-product claims for a partial aspect.
Yes, whenever it runs unspecified. From that date UCPD Annex I point 4a bans the generic form outright; specification on the same medium, or the narrow recognised-performance carve-out, are the only ways through.
Either specify it into a substantiated claim with a number and a scope on the same medium, or hold the narrow carve-out: EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law.
Short answer: not as a bare claim. From 27 September 2026, making a generic environmental claim without being able to demonstrate recognised excellent environmental performance relevant to that claim is banned in all circumstances — UCPD Annex I point 4a, inserted by Directive (EU) 2024/825.
Recital 10 of the directive singles this word out as harder than the ordinary generic claims: because it carries a social dimension as well as an environmental one, it can never rest on the environmental carve-out alone — no ecolabel or energy class by itself justifies it.
Recital 10 treats 'sustainable' as harder than the recital-9 family: because it carries a social dimension as well as an environmental one, it can never rest on the environmental carve-out alone.
Scope the claim to something measurable — 'cuts water use 40% per wash (internal test protocol, 2026)' — and retire the bare word
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
The most dangerous word in an EU copy deck as of 27 September 2026: no ecolabel, energy class or certificate alone justifies it.
As a generic, unspecified environmental claim, yes — banned in all circumstances under UCPD Annex I point 4a unless specified on the same medium or carried by the narrow recognised-performance carve-out.
Replace or accompany it with a specific, substantiated statement — a number and a scope on the same medium — or qualify via the EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law. For this word, recital 10 closes the carve-out route on its own.
Not on its own, no. From 27 September 2026, generic environmental claims are banned in all circumstances unless the trader can demonstrate recognised excellent environmental performance relevant to the claim — the rule is UCPD Annex I point 4a, inserted by Directive (EU) 2024/825.
Recital 10 of the directive singles this word out as harder than the ordinary generic claims: because it carries a social dimension as well as an environmental one, it can never rest on the environmental carve-out alone — no ecolabel or energy class by itself justifies it.
The fashion-industry favourite ('conscious collection') sits in recital 10's social-dimension trio — the carve-out for recognised excellent environmental performance cannot carry it by itself.
Name the practice: 'This line uses 100% GOTS-certified organic cotton (certificate no. on page)'
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
Collection-level labels sweep every item in the range into the claim — one non-conforming SKU poisons the label.
Used bare, yes: point 4a of the UCPD blacklist bans it in all circumstances from that date, unless the claim is specified on the same medium or the narrow recognised-performance carve-out carries it.
Two options: turn it into a specific, substantiated statement (a number and a scope, on the same medium), or carry it on the carve-out — the EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law. For this word, recital 10 closes the carve-out route on its own.
As a bare claim, it stops being lawful on 27 September 2026. That is when UCPD Annex I point 4a (inserted by Directive (EU) 2024/825) starts banning generic environmental claims outright wherever recognised excellent environmental performance relevant to the claim cannot be demonstrated.
Recital 10 of the directive singles this word out as harder than the ordinary generic claims: because it carries a social dimension as well as an environmental one, it can never rest on the environmental carve-out alone — no ecolabel or energy class by itself justifies it.
'Responsibly made' and 'responsibly sourced' promise both environmental and social performance; recital 10 keeps them off the environmental carve-out alone.
State the audited fact: 'All tier-1 suppliers audited to amfori BSCI in 2025–26' [check your certificate scope before using]
[ILLUSTRATIVE — a pattern, not legal clearance. Substantiation must be your own evidence, filed per claim.]
Sourcing claims invite requests for the audit trail — the substantiation file matters more here than the wording.
Yes, whenever it runs unspecified. From that date UCPD Annex I point 4a bans the generic form outright; specification on the same medium, or the narrow recognised-performance carve-out, are the only ways through.
Either specify it into a substantiated claim with a number and a scope on the same medium, or hold the narrow carve-out: EU Ecolabel, a recognised ISO 14024 type-I scheme, or top performance under other Union law. For this word, recital 10 closes the carve-out route on its own.
The EU Green Claims Compliance Kit: the twelve banned practices verbatim with plain-language readings, 13 rewrite patterns, the claim register and the substantiation file — built from the Official Journal text with pinpoint citations.
Get the kit — US$190 Free 4-page sample (PDF)Instant download · 14-day unconditional refund · single-organisation licence · full product page
General information and document templates only — not legal advice, and no clearance opinions. EmpCo binds traders through national transposition: wording and enforcement vary across the 27 Member States, and everything on this page keys to the directive baseline. Sources are Directive (EU) 2024/825 (CELEX 32024L0825) and our audited kit research. © 2026 Kilde.
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