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Current to 21 August 2026 · updates land in the changelog.
Twelve additions to the Unfair Commercial Practices Directive's Annex I: five environmental (points 2a, 4a, 4b, 4c, 10a) and seven on durability, repair and software (23d–23j). Annex I practices are unfair in all circumstances — there is no consumer-understanding defence. Each section carries the point's verbatim text, a plain-language reading, who it catches and the fix.
From 27 September 2026, Directive (EU) 2024/825 inserts twelve new practices into Annex I of the Unfair Commercial Practices Directive — the EU's per-se blacklist. Practices on it are unfair in all circumstances: no case-by-case defence, no “consumers understood us”. This page covers point 2a.
“Displaying a sustainability label that is not based on a certification scheme or not established by public authorities.”
A green badge, leaf icon, 'eco choice' flag or in-house score displayed on or near products must either come from public authorities or sit on a genuine certification scheme — third-party verified, open to applicants, with real non-compliance procedures. Self-awarded badges fail this point as written.
The register work here is inventory-shaped. Badges accumulate for years across packs, product pages, ads and retail media, and the ban attaches to the display itself, not to anyone's intent. In practice the exposure is rarely the flagship certification on the homepage; it is the forgotten leaf icon in a template footer, the in-house 'eco choice' flag a category manager added in 2023, the marketplace badge nobody owns. An estate sweep with a keep, replace or retire verdict per badge is the whole discipline.
Point 2a polices who stands behind a label; point 4a polices unattached green wording. A self-awarded badge that also says 'eco' can fail both at once, on different legs — removing the word does not cure the badge, and certifying the badge does not cure a generic slogan sitting next to it.
Anyone using badges, icons or scores on packs, product pages or ads — especially retailers with in-house 'eco' ranges.
Inventory every badge in your estate; keep only those from public authorities or qualifying certification schemes, and file the certificate for each.
A green badge, leaf icon, 'eco choice' flag or in-house score displayed on or near products must either come from public authorities or sit on a genuine certification scheme — third-party verified, open to applicants, with real non-compliance procedures. Self-awarded badges fail this point
Member States must apply the measures from 27 September 2026; the date is fixed in the directive and does not slide with late national transposition.
Point 4a is one of the twelve practices Directive (EU) 2024/825 adds to Annex I of the Unfair Commercial Practices Directive from 27 September 2026. Annex I is the per-se list: everything on it is unfair in all circumstances, and no consumer-understanding argument reopens the question.
“Making a generic environmental claim for which the trader is not able to demonstrate recognised excellent environmental performance relevant to the claim.”
'Eco-friendly', 'green', 'climate friendly' and family are banned unless you hold the narrow carve-out relevant to the claim (EU Ecolabel, a recognised EN ISO 14024 type-I scheme, or top performance under other Union law), or the claim stops being generic because you specify it in clear and prominent terms on the same medium.
This is the point that reaches ordinary product copy, which is why it carries the estate-sweep workload. The recital-9 examples supply the search list; the harder judgement is context, because imagery, colourways and placement feed the overall impression a claim makes. Teams that treat this as a wording problem tend to relabel and move on; teams that treat it as a claims-inventory problem end up with the register the directive effectively demands.
4a bans generic wording that specification can still save; 4b is about scope, where one green aspect gets sold as the whole product; 4c is the one ban specification cannot cure, because it attaches to the offsetting basis itself.
Every consumer-facing brand marketing into the EU — this is the point that catches ordinary product copy.
Grep your estate for the recital-9 phrase list; for every hit, either specify (number + scope, same medium), qualify via the carve-out, or retire the claim.
'Eco-friendly', 'green', 'climate friendly' and family are banned unless you hold the narrow carve-out relevant to the claim (EU Ecolabel, a recognised EN ISO 14024 type-I scheme, or top performance under other Union law), or the claim stops being generic because you specify it in clear an
From 27 September 2026 — a date the directive fixes itself, unaffected by how quickly individual Member States transpose.
This is the page for Annex I point 4b — one of the twelve additions Directive (EU) 2024/825 makes to the UCPD blacklist, applying from 27 September 2026. Blacklist entries work per se: unfair in all circumstances, with nothing left to argue case by case.
“Making an environmental claim about the entire product or the trader's entire business when it concerns only a certain aspect of the product or a specific activity of the trader's business.”
Scope your claims. 'Made with recycled material' reads as the whole product; a company-level 'we're carbon conscious' halo on the strength of one green warehouse fails this point as written.
The practical trap is aggregation drift: a true statement about one component slides upward into packaging copy, then into a company-level story, gaining scope at every step while the evidence stays where it started. The discipline is naming the aspect every time — which material, which process, which site — and keeping company-wide claims tethered to audited, company-wide facts.
Where 4a asks whether a claim is specified at all, 4b asks whether the specification matches the claim's scope. A precisely worded claim can still fail 4b if it quietly lets one green aspect carry the whole product.
Brands with one genuinely green attribute tempted to let it carry the whole product or company story.
Name the aspect: which component, which process, which site — and keep company-level claims to audited company-level facts.
Scope your claims. 'Made with recycled material' reads as the whole product; a company-level 'we're carbon conscious' halo on the strength of one green warehouse fails this point as written.
27 September 2026. The directive sets the application date directly, so late national transposition does not postpone it.
From 27 September 2026, Directive (EU) 2024/825 inserts twelve new practices into Annex I of the Unfair Commercial Practices Directive — the EU's per-se blacklist. Practices on it are unfair in all circumstances: no case-by-case defence, no “consumers understood us”. This page covers point 4c.
“Claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.”
'Climate neutral (via offsets)' is banned outright — no asterisk, methodology page or certificate cures it, because the ban attaches to the offsetting basis itself. It covers 'reduced' and 'positive' too, not just 'neutral'. Actual lifecycle reductions can still be claimed with substantiation, and funding climate projects can still be communicated — as funding, not as product impact.
This ban is structural rather than evidential: certificate quality, methodology pages and asterisks change nothing, because the prohibition attaches to the offsetting basis itself. Brands whose neutrality story rests on purchased credits face a messaging rebuild, not a substantiation exercise — measured lifecycle reductions on one line, project funding described as funding on another, and the fused 'neutral' headline retired.
4a leaves a specification route open; 4c does not. That asymmetry is the thing to internalise: 'climate friendly' can sometimes be saved by specifying it, while 'climate neutral via offsets' cannot, however prominent the explanation.
Any brand whose neutrality story rests on purchased credits — including certified offset schemes.
Split the message: claim measured reductions with their basis; describe project funding as funding.
'Climate neutral (via offsets)' is banned outright — no asterisk, methodology page or certificate cures it, because the ban attaches to the offsetting basis itself. It covers 'reduced' and 'positive' too, not just 'neutral'. Actual lifecycle reductions can still be claimed with substantiat
Member States must apply the measures from 27 September 2026; the date is fixed in the directive and does not slide with late national transposition.
Point 10a is one of the twelve practices Directive (EU) 2024/825 adds to Annex I of the Unfair Commercial Practices Directive from 27 September 2026. Annex I is the per-se list: everything on it is unfair in all circumstances, and no consumer-understanding argument reopens the question.
“Presenting requirements imposed by law on all products within the relevant product category on the Union market as a distinctive feature of the trader's offer.”
If every product in the category must be that way by law — a banned substance absent, a mandated standard met — advertising it as your virtue fails this point as written.
The copy this catches is usually written in good faith — a compliance fact stated proudly. The test is category-wide legal necessity: if every competitor's product must be that way by law, presenting the fact as your distinction fails as written. The practical pass is a legal-baseline check per claim: is this required of the whole category on the Union market? If yes, the claim either goes, or gets restated as neutral information.
Unlike the green-wording points, 10a has nothing to do with environmental language as such; it polices the framing of legal minimums anywhere in the deck. A perfectly specified, fully substantiated claim still fails here if what it describes is simply what the law already requires of everyone.
Copy that leans on 'BPA-free', 'meets EU safety standards' and similar where the law already requires it category-wide.
Usually deletion; if the fact matters to buyers, state it as information, not differentiation.
If every product in the category must be that way by law — a banned substance absent, a mandated standard met — advertising it as your virtue fails this point as written.
From 27 September 2026 — a date the directive fixes itself, unaffected by how quickly individual Member States transpose.
From 27 September 2026, Directive (EU) 2024/825 inserts twelve new practices into Annex I of the Unfair Commercial Practices Directive — the EU's per-se blacklist. Practices on it are unfair in all circumstances: no case-by-case defence, no “consumers understood us”. This page covers point 23e.
“Presenting a software update as necessary when it only enhances functionality features.”
'Required update' language is reserved for updates that actually are — security, compatibility, conformity. Feature drops are optional and must read that way.
The word 'required' in an update prompt becomes a regulated claim here. The clean implementation is two prompt templates gated by a decision rule: security, compatibility and conformity updates may say necessary; feature drops must read as optional. The familiar failure mode is a product team borrowing the urgent template because optional updates get ignored.
23e polices the label on the update; 23d polices silence about its effects. Marking a feature drop 'required' violates 23e even when its effects are fully disclosed — and full honesty in the label does not excuse silence that fails 23d.
Product and release teams wording update prompts.
Two prompt templates: 'required' (security/compatibility only) and 'optional' (features).
'Required update' language is reserved for updates that actually are — security, compatibility, conformity. Feature drops are optional and must read that way.
Member States must apply the measures from 27 September 2026; the date is fixed in the directive and does not slide with late national transposition.
Point 23f is one of the twelve practices Directive (EU) 2024/825 adds to Annex I of the Unfair Commercial Practices Directive from 27 September 2026. Annex I is the per-se list: everything on it is unfair in all circumstances, and no consumer-understanding argument reopens the question.
“Any commercial communication in relation to a good containing a feature introduced to limit its durability despite information on the feature and its effects on the durability of the good being available to the trader.”
If you know — or have information available — that a feature limits the good's life, any commercial communication for that good fails this point as written. This one reaches the product decision, not just the copy.
This is the deepest-reaching point in the set, because 'any commercial communication' makes it operate at the product level: while a durability-limiting feature is known and present, every advertisement for that good is exposed. The compliance conversation escalates accordingly, from the copy desk to product management — the feature, not the phrasing, is the risk.
23g punishes durability claims that are false; 23f punishes marketing a product whose durability limiter you know about, regardless of what the copy claims. Fixing the wording addresses 23g and leaves 23f entirely untouched.
Hardware makers with consumable-lockouts, battery pairing or software kill-switches.
Escalate beyond marketing: the durability-limiting feature itself is the exposure.
If you know — or have information available — that a feature limits the good's life, any commercial communication for that good fails this point as written. This one reaches the product decision, not just the copy.
From 27 September 2026 — a date the directive fixes itself, unaffected by how quickly individual Member States transpose.
This is the page for Annex I point 23g — one of the twelve additions Directive (EU) 2024/825 makes to the UCPD blacklist, applying from 27 September 2026. Blacklist entries work per se: unfair in all circumstances, with nothing left to argue case by case.
“Falsely claiming that under normal conditions of use a good has a certain durability in terms of usage time or intensity.”
'Lasts twice as long', '10-year build' need test evidence under normal-use conditions.
The claims this catches are marketing's favourites — 'lasts twice as long', 'ten-year build' — and the cure is unglamorous: a test file per claim, run under normal-use conditions, filed where an authority request can be answered without a scramble. Where an official durability label exists for the category, pairing the claim with it is the strong position.
23g needs a false or unsubstantiated durability claim; 23f fires without any claim at all, on the known feature. Between them they cover both directions: what you say about lifespan, and what you built into it.
Any durability marketing without a test file behind it.
Hold the test report in the substantiation file; pair with the official durability label where one applies.
'Lasts twice as long', '10-year build' need test evidence under normal-use conditions.
27 September 2026. The directive sets the application date directly, so late national transposition does not postpone it.
From 27 September 2026, Directive (EU) 2024/825 inserts twelve new practices into Annex I of the Unfair Commercial Practices Directive — the EU's per-se blacklist. Practices on it are unfair in all circumstances: no case-by-case defence, no “consumers understood us”. This page covers point 23h.
“Presenting a good as allowing repair when it does not.”
'Repairable' claims need parts, documentation and a realistic repair path to exist.
'Repairable' is now a checklist claim: parts actually orderable, documentation actually published, a realistic path for a competent repairer to succeed. The gap this point exposes is marketing running ahead of operations — the badge ships while the spare-parts programme is still a roadmap item.
23h is about the repair promise on the product; 23j handles the adjacent scare-copy problem (what gets said about third-party parts); 23i the consumables-timing nudges. Three angles on the same after-sale story.
Brands marketing repairability as a feature.
Before the claim ships: parts available? documentation published? realistic path for a competent repairer?
'Repairable' claims need parts, documentation and a realistic repair path to exist.
Member States must apply the measures from 27 September 2026; the date is fixed in the directive and does not slide with late national transposition.
Point 23i is one of the twelve practices Directive (EU) 2024/825 adds to Annex I of the Unfair Commercial Practices Directive from 27 September 2026. Annex I is the per-se list: everything on it is unfair in all circumstances, and no consumer-understanding argument reopens the question.
“Inducing the consumer to replace or replenish the consumables of a good earlier than necessary for technical reasons.”
Low-ink-style nudges ahead of technical need fail this point as written.
The regulated object here is device behaviour: the low-ink warning, the filter-change prompt, the cartridge lockout. Each replacement nudge needs a measured technical threshold behind it, and the threshold needs a record. Firmware and product teams own this one; marketing usually hears about it last.
23i polices when the device asks for consumables; 23j polices what is said, or hidden, about third-party alternatives. A prompt can be perfectly honest under 23j and still premature under 23i.
Printer-ink, filter and cartridge patterns — any device that prompts replacement.
Tie every replacement prompt to a measured technical threshold, and record the threshold.
Low-ink-style nudges ahead of technical need fail this point as written.
From 27 September 2026 — a date the directive fixes itself, unaffected by how quickly individual Member States transpose.
This is the page for Annex I point 23j — one of the twelve additions Directive (EU) 2024/825 makes to the UCPD blacklist, applying from 27 September 2026. Blacklist entries work per se: unfair in all circumstances, with nothing left to argue case by case.
“Withholding information concerning the impairment of the functionality of a good when consumables, spare parts or accessories not supplied by the original producer are used, or falsely claiming that such impairment will happen.”
Both directions are banned: hiding a real third-party-parts limitation, and inventing one — 'void your warranty' scare copy where nothing impairs.
This point cuts both ways, which is what makes it unusual: hiding a real third-party-parts limitation fails, and inventing one — warranty-void scare copy where nothing impairs — fails too. The compliance artifact is a documented position per product family: what genuinely impairs with non-original parts (disclosed), and what does not (with the scare lines deleted).
Where 23i regulates replacement timing, 23j regulates truthfulness about compatibility. And unlike the straightforward omission points, 23j's second limb bans a positive false statement: the invented impairment claim.
Manufacturers of devices with consumable or accessory ecosystems.
Document what genuinely impairs and disclose it; delete scare copy about what does not.
Both directions are banned: hiding a real third-party-parts limitation, and inventing one — 'void your warranty' scare copy where nothing impairs.
27 September 2026. The directive sets the application date directly, so late national transposition does not postpone it.
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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