Kilde › Guides › Green claims › Green claims rules by Member State: wh…
Current to 21 August 2026 · updates land in the changelog.
The application date is fixed in the directive and does not move with late national transposition: from 27 September 2026 the twelve banned practices apply to marketing aimed at consumers in every Member State. What differs by country is the transposition status, the enforcing authority and the penalty regime. One section per state, in the order of the transposition table; jump with the list below.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Austria. It inserts twelve new per-se banned practices into the UCPD blacklist: practices that are unfair in all circumstances, with no “but consumers understood us” defence.
Austria is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Austrian implementing act, the date your marketing needs to be ready for does not move.
Yes in effect. The directive fixes 27 September 2026 as the application date and it does not slide with late transposition. Austria had communicated national measures at our last verification, but the marketing deadline is the same either way.
As a generic, unspecified claim, yes — unless it is specified in clear and prominent terms on the same medium, or carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Belgium. Its mechanism is blunt: twelve new practices join the per-se UCPD blacklist, unfair in all circumstances, leaving no room for a “consumers knew what we meant” defence.
Belgium is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Belgian implementing act, the date your marketing needs to be ready for does not move.
For marketing purposes, yes. 27 September 2026 is written into the directive itself and does not move with transposition delays; at our last verification Belgium had communicated national measures, which changes the legal plumbing but not the date to be ready for.
Used bare, yes: the generic-claims ban catches it unless the claim is specified in clear and prominent terms on the same medium, or the narrow recognised-performance carve-out applies.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Bulgaria. The change arrives as twelve additions to the UCPD blacklist — per-se bans, unfair in all circumstances, immune to case-by-case justification.
Bulgaria is one of the 9 Member States that had not yet communicated transposition measures as of our verification date. The European Commission sent letters of formal notice to 20 Member States on 28 May 2026 over transposition delays.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Bulgarian implementing act, the date your marketing needs to be ready for does not move.
Directives lack horizontal direct effect (Faccini Dori, C-91/92), so the new points bind traders only via national law — but courts must interpret existing national law in conformity with the directive (Marleasing, C-106/89), and most greenwashing already violates the current misleading-practices rules. The CPC network coordinates enforcement EU-wide. The practical consequence for a brand selling in Bulgaria: the rewrite work cannot wait for the national act — most claims that fail the new blacklist already sit badly under the current misleading-practices rules.
Treat the date as fixed: the directive sets 27 September 2026 and late national transposition does not postpone it. Bulgaria had not yet communicated its measures when we last verified — either way, copy sold there needs to be ready.
Yes, when unspecified. The lawful versions are a claim specified with clear and prominent terms on the same medium, or one carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Croatia. It inserts twelve new per-se banned practices into the UCPD blacklist: practices that are unfair in all circumstances, with no “but consumers understood us” defence.
Croatia is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Croatian implementing act, the date your marketing needs to be ready for does not move.
Yes in effect. The directive fixes 27 September 2026 as the application date and it does not slide with late transposition. Croatia had communicated national measures at our last verification, but the marketing deadline is the same either way.
As a generic, unspecified claim, yes — unless it is specified in clear and prominent terms on the same medium, or carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Cyprus. Its mechanism is blunt: twelve new practices join the per-se UCPD blacklist, unfair in all circumstances, leaving no room for a “consumers knew what we meant” defence.
Cyprus is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Cypriot implementing act, the date your marketing needs to be ready for does not move.
For marketing purposes, yes. 27 September 2026 is written into the directive itself and does not move with transposition delays; at our last verification Cyprus had communicated national measures, which changes the legal plumbing but not the date to be ready for.
Used bare, yes: the generic-claims ban catches it unless the claim is specified in clear and prominent terms on the same medium, or the narrow recognised-performance carve-out applies.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Czechia. The change arrives as twelve additions to the UCPD blacklist — per-se bans, unfair in all circumstances, immune to case-by-case justification.
Czechia is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Czech implementing act, the date your marketing needs to be ready for does not move.
Treat the date as fixed: the directive sets 27 September 2026 and late national transposition does not postpone it. Czechia had communicated its measures when we last verified — either way, copy sold there needs to be ready.
Yes, when unspecified. The lawful versions are a claim specified with clear and prominent terms on the same medium, or one carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Denmark. It inserts twelve new per-se banned practices into the UCPD blacklist: practices that are unfair in all circumstances, with no “but consumers understood us” defence.
Denmark is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Danish implementing act, the date your marketing needs to be ready for does not move.
Yes in effect. The directive fixes 27 September 2026 as the application date and it does not slide with late transposition. Denmark had communicated national measures at our last verification, but the marketing deadline is the same either way.
As a generic, unspecified claim, yes — unless it is specified in clear and prominent terms on the same medium, or carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Estonia. Its mechanism is blunt: twelve new practices join the per-se UCPD blacklist, unfair in all circumstances, leaving no room for a “consumers knew what we meant” defence.
Estonia is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Estonian implementing act, the date your marketing needs to be ready for does not move.
For marketing purposes, yes. 27 September 2026 is written into the directive itself and does not move with transposition delays; at our last verification Estonia had communicated national measures, which changes the legal plumbing but not the date to be ready for.
Used bare, yes: the generic-claims ban catches it unless the claim is specified in clear and prominent terms on the same medium, or the narrow recognised-performance carve-out applies.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Finland. The change arrives as twelve additions to the UCPD blacklist — per-se bans, unfair in all circumstances, immune to case-by-case justification.
Finland is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Finnish implementing act, the date your marketing needs to be ready for does not move.
Treat the date as fixed: the directive sets 27 September 2026 and late national transposition does not postpone it. Finland had communicated its measures when we last verified — either way, copy sold there needs to be ready.
Yes, when unspecified. The lawful versions are a claim specified with clear and prominent terms on the same medium, or one carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including France. It inserts twelve new per-se banned practices into the UCPD blacklist: practices that are unfair in all circumstances, with no “but consumers understood us” defence.
France is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date. France communicated pre-existing provisions only; the full transposition bill was still pending at our verification date, so treat the French position as partially settled.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the French implementing act, the date your marketing needs to be ready for does not move.
Yes in effect. The directive fixes 27 September 2026 as the application date and it does not slide with late transposition. France had communicated national measures at our last verification, but the marketing deadline is the same either way.
As a generic, unspecified claim, yes — unless it is specified in clear and prominent terms on the same medium, or carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Germany. Its mechanism is blunt: twelve new practices join the per-se UCPD blacklist, unfair in all circumstances, leaving no room for a “consumers knew what we meant” defence.
Germany is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date. Germany has fully transposed: an UWG amendment (Federal Law Gazette, 19 February 2026) and a separate CRD implementation act (5 February 2026), both entering into force on 27 September 2026.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the German implementing act, the date your marketing needs to be ready for does not move.
For marketing purposes, yes. 27 September 2026 is written into the directive itself and does not move with transposition delays; at our last verification Germany had communicated national measures, which changes the legal plumbing but not the date to be ready for.
Used bare, yes: the generic-claims ban catches it unless the claim is specified in clear and prominent terms on the same medium, or the narrow recognised-performance carve-out applies.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Greece. The change arrives as twelve additions to the UCPD blacklist — per-se bans, unfair in all circumstances, immune to case-by-case justification.
Greece is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Greek implementing act, the date your marketing needs to be ready for does not move.
Treat the date as fixed: the directive sets 27 September 2026 and late national transposition does not postpone it. Greece had communicated its measures when we last verified — either way, copy sold there needs to be ready.
Yes, when unspecified. The lawful versions are a claim specified with clear and prominent terms on the same medium, or one carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Hungary. It inserts twelve new per-se banned practices into the UCPD blacklist: practices that are unfair in all circumstances, with no “but consumers understood us” defence.
Hungary is one of the 9 Member States that had not yet communicated transposition measures as of our verification date. The European Commission sent letters of formal notice to 20 Member States on 28 May 2026 over transposition delays.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Hungarian implementing act, the date your marketing needs to be ready for does not move.
Directives lack horizontal direct effect (Faccini Dori, C-91/92), so the new points bind traders only via national law — but courts must interpret existing national law in conformity with the directive (Marleasing, C-106/89), and most greenwashing already violates the current misleading-practices rules. The CPC network coordinates enforcement EU-wide. The practical consequence for a brand selling in Hungary: the rewrite work cannot wait for the national act — most claims that fail the new blacklist already sit badly under the current misleading-practices rules.
Yes in effect. The directive fixes 27 September 2026 as the application date and it does not slide with late transposition. Hungary had not yet communicated national measures at our last verification, but the marketing deadline is the same either way.
As a generic, unspecified claim, yes — unless it is specified in clear and prominent terms on the same medium, or carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Ireland. Its mechanism is blunt: twelve new practices join the per-se UCPD blacklist, unfair in all circumstances, leaving no room for a “consumers knew what we meant” defence.
Ireland is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Irish implementing act, the date your marketing needs to be ready for does not move.
For marketing purposes, yes. 27 September 2026 is written into the directive itself and does not move with transposition delays; at our last verification Ireland had communicated national measures, which changes the legal plumbing but not the date to be ready for.
Used bare, yes: the generic-claims ban catches it unless the claim is specified in clear and prominent terms on the same medium, or the narrow recognised-performance carve-out applies.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Italy. The change arrives as twelve additions to the UCPD blacklist — per-se bans, unfair in all circumstances, immune to case-by-case justification.
Italy is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date. Italy transposed via Legislative Decree (D.Lgs) 30/2026.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Italian implementing act, the date your marketing needs to be ready for does not move.
Treat the date as fixed: the directive sets 27 September 2026 and late national transposition does not postpone it. Italy had communicated its measures when we last verified — either way, copy sold there needs to be ready.
Yes, when unspecified. The lawful versions are a claim specified with clear and prominent terms on the same medium, or one carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Latvia. It inserts twelve new per-se banned practices into the UCPD blacklist: practices that are unfair in all circumstances, with no “but consumers understood us” defence.
Latvia is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Latvian implementing act, the date your marketing needs to be ready for does not move.
Yes in effect. The directive fixes 27 September 2026 as the application date and it does not slide with late transposition. Latvia had communicated national measures at our last verification, but the marketing deadline is the same either way.
As a generic, unspecified claim, yes — unless it is specified in clear and prominent terms on the same medium, or carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Lithuania. Its mechanism is blunt: twelve new practices join the per-se UCPD blacklist, unfair in all circumstances, leaving no room for a “consumers knew what we meant” defence.
Lithuania is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Lithuanian implementing act, the date your marketing needs to be ready for does not move.
For marketing purposes, yes. 27 September 2026 is written into the directive itself and does not move with transposition delays; at our last verification Lithuania had communicated national measures, which changes the legal plumbing but not the date to be ready for.
Used bare, yes: the generic-claims ban catches it unless the claim is specified in clear and prominent terms on the same medium, or the narrow recognised-performance carve-out applies.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Luxembourg. The change arrives as twelve additions to the UCPD blacklist — per-se bans, unfair in all circumstances, immune to case-by-case justification.
Luxembourg is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Luxembourgish implementing act, the date your marketing needs to be ready for does not move.
Treat the date as fixed: the directive sets 27 September 2026 and late national transposition does not postpone it. Luxembourg had communicated its measures when we last verified — either way, copy sold there needs to be ready.
Yes, when unspecified. The lawful versions are a claim specified with clear and prominent terms on the same medium, or one carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Malta. It inserts twelve new per-se banned practices into the UCPD blacklist: practices that are unfair in all circumstances, with no “but consumers understood us” defence.
Malta is one of the 9 Member States that had not yet communicated transposition measures as of our verification date. The European Commission sent letters of formal notice to 20 Member States on 28 May 2026 over transposition delays.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Maltese implementing act, the date your marketing needs to be ready for does not move.
Directives lack horizontal direct effect (Faccini Dori, C-91/92), so the new points bind traders only via national law — but courts must interpret existing national law in conformity with the directive (Marleasing, C-106/89), and most greenwashing already violates the current misleading-practices rules. The CPC network coordinates enforcement EU-wide. The practical consequence for a brand selling in Malta: the rewrite work cannot wait for the national act — most claims that fail the new blacklist already sit badly under the current misleading-practices rules.
Yes in effect. The directive fixes 27 September 2026 as the application date and it does not slide with late transposition. Malta had not yet communicated national measures at our last verification, but the marketing deadline is the same either way.
As a generic, unspecified claim, yes — unless it is specified in clear and prominent terms on the same medium, or carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Netherlands. Its mechanism is blunt: twelve new practices join the per-se UCPD blacklist, unfair in all circumstances, leaving no room for a “consumers knew what we meant” defence.
Netherlands is one of the 9 Member States that had not yet communicated transposition measures as of our verification date. The Dutch transposition bill passed the lower house on 23 April 2026; Senate approval was still pending at our verification date. The European Commission sent letters of formal notice to 20 Member States on 28 May 2026 over transposition delays.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Dutch implementing act, the date your marketing needs to be ready for does not move.
Directives lack horizontal direct effect (Faccini Dori, C-91/92), so the new points bind traders only via national law — but courts must interpret existing national law in conformity with the directive (Marleasing, C-106/89), and most greenwashing already violates the current misleading-practices rules. The CPC network coordinates enforcement EU-wide. The practical consequence for a brand selling in Netherlands: the rewrite work cannot wait for the national act — most claims that fail the new blacklist already sit badly under the current misleading-practices rules.
For marketing purposes, yes. 27 September 2026 is written into the directive itself and does not move with transposition delays; at our last verification Netherlands had not yet communicated national measures, which changes the legal plumbing but not the date to be ready for.
Used bare, yes: the generic-claims ban catches it unless the claim is specified in clear and prominent terms on the same medium, or the narrow recognised-performance carve-out applies.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Poland. The change arrives as twelve additions to the UCPD blacklist — per-se bans, unfair in all circumstances, immune to case-by-case justification.
Poland is one of the 9 Member States that had not yet communicated transposition measures as of our verification date. No Polish transposition measure had been located at our verification date. The European Commission sent letters of formal notice to 20 Member States on 28 May 2026 over transposition delays.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Polish implementing act, the date your marketing needs to be ready for does not move.
Directives lack horizontal direct effect (Faccini Dori, C-91/92), so the new points bind traders only via national law — but courts must interpret existing national law in conformity with the directive (Marleasing, C-106/89), and most greenwashing already violates the current misleading-practices rules. The CPC network coordinates enforcement EU-wide. The practical consequence for a brand selling in Poland: the rewrite work cannot wait for the national act — most claims that fail the new blacklist already sit badly under the current misleading-practices rules.
Treat the date as fixed: the directive sets 27 September 2026 and late national transposition does not postpone it. Poland had not yet communicated its measures when we last verified — either way, copy sold there needs to be ready.
Yes, when unspecified. The lawful versions are a claim specified with clear and prominent terms on the same medium, or one carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Portugal. It inserts twelve new per-se banned practices into the UCPD blacklist: practices that are unfair in all circumstances, with no “but consumers understood us” defence.
Portugal is one of the 9 Member States that had not yet communicated transposition measures as of our verification date. The European Commission sent letters of formal notice to 20 Member States on 28 May 2026 over transposition delays.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Portuguese implementing act, the date your marketing needs to be ready for does not move.
Directives lack horizontal direct effect (Faccini Dori, C-91/92), so the new points bind traders only via national law — but courts must interpret existing national law in conformity with the directive (Marleasing, C-106/89), and most greenwashing already violates the current misleading-practices rules. The CPC network coordinates enforcement EU-wide. The practical consequence for a brand selling in Portugal: the rewrite work cannot wait for the national act — most claims that fail the new blacklist already sit badly under the current misleading-practices rules.
Yes in effect. The directive fixes 27 September 2026 as the application date and it does not slide with late transposition. Portugal had not yet communicated national measures at our last verification, but the marketing deadline is the same either way.
As a generic, unspecified claim, yes — unless it is specified in clear and prominent terms on the same medium, or carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Romania. Its mechanism is blunt: twelve new practices join the per-se UCPD blacklist, unfair in all circumstances, leaving no room for a “consumers knew what we meant” defence.
Romania is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Romanian implementing act, the date your marketing needs to be ready for does not move.
For marketing purposes, yes. 27 September 2026 is written into the directive itself and does not move with transposition delays; at our last verification Romania had communicated national measures, which changes the legal plumbing but not the date to be ready for.
Used bare, yes: the generic-claims ban catches it unless the claim is specified in clear and prominent terms on the same medium, or the narrow recognised-performance carve-out applies.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Slovakia. The change arrives as twelve additions to the UCPD blacklist — per-se bans, unfair in all circumstances, immune to case-by-case justification.
Slovakia is one of the 18 Member States that had communicated national transposition measures to the European Commission as of our verification date.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Slovak implementing act, the date your marketing needs to be ready for does not move.
Treat the date as fixed: the directive sets 27 September 2026 and late national transposition does not postpone it. Slovakia had communicated its measures when we last verified — either way, copy sold there needs to be ready.
Yes, when unspecified. The lawful versions are a claim specified with clear and prominent terms on the same medium, or one carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Slovenia. It inserts twelve new per-se banned practices into the UCPD blacklist: practices that are unfair in all circumstances, with no “but consumers understood us” defence.
Slovenia is one of the 9 Member States that had not yet communicated transposition measures as of our verification date. The European Commission sent letters of formal notice to 20 Member States on 28 May 2026 over transposition delays.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Slovenian implementing act, the date your marketing needs to be ready for does not move.
Directives lack horizontal direct effect (Faccini Dori, C-91/92), so the new points bind traders only via national law — but courts must interpret existing national law in conformity with the directive (Marleasing, C-106/89), and most greenwashing already violates the current misleading-practices rules. The CPC network coordinates enforcement EU-wide. The practical consequence for a brand selling in Slovenia: the rewrite work cannot wait for the national act — most claims that fail the new blacklist already sit badly under the current misleading-practices rules.
Yes in effect. The directive fixes 27 September 2026 as the application date and it does not slide with late transposition. Slovenia had not yet communicated national measures at our last verification, but the marketing deadline is the same either way.
As a generic, unspecified claim, yes — unless it is specified in clear and prominent terms on the same medium, or carried by the narrow recognised-excellent-performance carve-out.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Spain. Its mechanism is blunt: twelve new practices join the per-se UCPD blacklist, unfair in all circumstances, leaving no room for a “consumers knew what we meant” defence.
Spain is one of the 9 Member States that had not yet communicated transposition measures as of our verification date. Spain closed its public consultation but had adopted no act at our verification date. The European Commission sent letters of formal notice to 20 Member States on 28 May 2026 over transposition delays.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Spanish implementing act, the date your marketing needs to be ready for does not move.
Directives lack horizontal direct effect (Faccini Dori, C-91/92), so the new points bind traders only via national law — but courts must interpret existing national law in conformity with the directive (Marleasing, C-106/89), and most greenwashing already violates the current misleading-practices rules. The CPC network coordinates enforcement EU-wide. The practical consequence for a brand selling in Spain: the rewrite work cannot wait for the national act — most claims that fail the new blacklist already sit badly under the current misleading-practices rules.
For marketing purposes, yes. 27 September 2026 is written into the directive itself and does not move with transposition delays; at our last verification Spain had not yet communicated national measures, which changes the legal plumbing but not the date to be ready for.
Used bare, yes: the generic-claims ban catches it unless the claim is specified in clear and prominent terms on the same medium, or the narrow recognised-performance carve-out applies.
From 27 September 2026, the EU's Empowering Consumers Directive (“EmpCo”, Directive (EU) 2024/825) rewires how green marketing is policed in every Member State — including Sweden. The change arrives as twelve additions to the UCPD blacklist — per-se bans, unfair in all circumstances, immune to case-by-case justification.
Sweden is one of the 9 Member States that had not yet communicated transposition measures as of our verification date. The European Commission sent letters of formal notice to 20 Member States on 28 May 2026 over transposition delays.
Member States must apply the measures from 27 September 2026 (Art 4(1)); the application date does not slide with late transposition. Whatever the state of the Swedish implementing act, the date your marketing needs to be ready for does not move.
Directives lack horizontal direct effect (Faccini Dori, C-91/92), so the new points bind traders only via national law — but courts must interpret existing national law in conformity with the directive (Marleasing, C-106/89), and most greenwashing already violates the current misleading-practices rules. The CPC network coordinates enforcement EU-wide. The practical consequence for a brand selling in Sweden: the rewrite work cannot wait for the national act — most claims that fail the new blacklist already sit badly under the current misleading-practices rules.
Treat the date as fixed: the directive sets 27 September 2026 and late national transposition does not postpone it. Sweden had not yet communicated its measures when we last verified — either way, copy sold there needs to be ready.
Yes, when unspecified. The lawful versions are a claim specified with clear and prominent terms on the same medium, or one carried by the narrow recognised-excellent-performance carve-out.
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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