EU 2024/825 Raises New Risks: Are You Ready for September 27?

• Directive EU 2024/825 strengthens consumer protection by targeting greenwashing, misleading sustainability claims, and other unfair commercial practices

• The Directive applies not only to EU companies, but to any business serving consumers in the EU market

• 27 September 2026 is the key deadline, when rules implementing the Directive begin to apply across the EU

• Companies can face serious penalties when consumer-facing claims or marketing practices violate national laws implementing the Directive

• Particular attention should be paid to terms such as green, sustainable, climate neutral, environmentally friendly, recyclable, eco-friendly, and carbon neutral

For years, European consumers have walked through a marketplace thick with badges. Some were useful. Some were decorative. Some were honest attempts at simplification. Others traded on the language of virtue without the discipline of proof. “Green”, “eco”, “responsible”, “climate friendly” and “certified” became easy words to print and difficult words to police.

Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024, published in the Official Journal of the European Union on 6 March 2024, is Europe’s answer to that fog. Its full title is “Directive (EU) 2024/825 as regards empowering consumers for the green transition through better protection against unfair practices and through better information.”

The Directive amends two pillars of EU consumer law: Directive 2005/29/EC on unfair commercial practices and Directive 2011/83/EU on consumer rights. That matters. This is not a decorative sustainability rule sitting outside consumer law. It is a direct intervention in the way companies communicate with buyers.

Why Europe Had To Act

The case for reform is straightforward. Consumers cannot make informed choices if commercial language becomes too elastic. A label that looks official but is self-created can mislead. A green claim without method can flatter a product. A future environmental promise without a plan can sound like progress while postponing accountability.

The European Commission, Directorate-General for Justice and Consumers, in “FAQ Empowering Consumers (GTD)”, published on 18 May 2026, explains that the Directive must be transposed by Member States and shall apply from 27 September 2026. The same document frames the reform around better consumer protection and better information for the green transition.

This is why the Directive deserves support. It does not punish serious marketing. It punishes loose marketing. It does not ban ambition. It asks ambition to show its working. It does not undermine credible recognitions. It separates them from vague symbols that pretend to mean more than they do.

Directive Or Regulation Matters

The legal form is important. Directive (EU) 2024/825 is a directive, not an EU regulation. The European Commission webpage “Types of EU law”, available at the publication date of this article, explains that regulations are binding in their entirety and directly applicable in all Member States without national transposition.

Directives work differently. The same European Commission webpage “Types of EU law” explains that directives set binding objectives for Member States, but leave national authorities free to choose the form and method for achieving those objectives. In practice, this means directives must be incorporated into national law.

That distinction explains the implementation landscape. The core European objective is common, but each Member State implements the Directive through its own legal machinery. For companies, the result is a shared EU claim discipline with national details in enforcement, wording, institutional practice and sanctions.

The Date That Changes Practice

The critical date is 27 September 2026. The European Commission webpage “Sustainable consumption”, available at the publication date of this article, states that Directive (EU) 2024/825 had to be transposed by 27 March 2026 and that the new rules apply from 27 September 2026.

For companies, this is not merely a legal date. It is an operating date. By then, marketing teams, legal teams, sustainability teams, product managers, packaging teams, e-commerce teams, retail designers, agencies and copywriters should know which claims are safe, which need evidence and which should disappear.

The practical problem is that claims linger. Old catalogues remain online. Product pages are copied across markets. Packaging stays in circulation. Retail media is reused. Campaign templates travel from one country to another. A claim designed before the new discipline may still be visible after the new discipline applies.

Who Falls Within Scope

The Directive is relevant to traders communicating with consumers in the EU market. That includes manufacturers, retailers, service providers, marketplaces, platforms, brand owners, distributors and advertisers. The legal issue is not only where a company is incorporated, but whether it addresses consumers in the European Union.

Non-EU companies should pay close attention. A business headquartered outside the EU but selling products, services or subscriptions to EU consumers cannot assume that local incorporation protects its marketing. If the consumer-facing commercial practice takes place in the EU market, EU consumer protection rules become relevant.

This is particularly important for international brands. A claim written once can be translated ten times, resized for banners, placed on packaging and repurposed for retail. Each step can change meaning. The Directive forces companies to treat claim management as a cross-border governance problem.

WHAT COMPANIES MUST WATCH AFTER 27 SEPTEMBER 2026

Ten executive takeaways on Directive (EU) 2024/825, national implementation, and consumer-claims governance

1. Companies must treat 27 September 2026 as an operational deadline for reviewing all consumer-facing claims across EU markets

2. Marketing, legal, sustainability, product, packaging, e-commerce, retail, and agency teams must align before claims reach consumers

3. Generic green claims will require precise qualification, credible evidence, and defensible meaning from the average consumer’s perspective

4. Sustainability labels must be based on credible certification schemes or public authority recognition, not self-created visual trust marks

5. Future environmental promises must be supported by realistic plans, measurable targets, transparency, and regular independent verification

6. Companies must assess total consumer impression, including wording, colours, icons, layout, context, proximity, and design hierarchy

7. Product comparisons based on environmental, social, or circularity characteristics require clear methodology, reliable evidence, and careful wording

8. Non-EU companies selling to EU consumers must comply because consumer-facing market activity triggers EU consumer protection rules

9. National implementation creates a shared EU core, but enforcement bodies, sanctions, guidance, and legal wording may differ locally

10. Companies using awards or certificates must preserve precise scope, traceability, substantiation, and separation from unsupported ESG claims

Not Just Greenwashing Rules

The Directive is often called anti-greenwashing legislation. That shorthand is useful, but incomplete. It covers environmental claims, sustainability labels, future environmental performance, durability, repairability, software updates, commercial guarantees and product comparisons based on environmental, social or circularity characteristics.

This last point matters. The Directive does not make all comparisons suspicious. It focuses on comparisons that rely on environmental, social or circularity characteristics, such as durability, repairability or recyclability. That is different from a consumer-research recognition used within its defined scope.

The article “EU tackles greenwashing: ‘Empowering Consumers Directive’ and proposals for the future”, published by Reuters Legal on 16 May 2024, explains that Directive (EU) 2024/825 addresses environmental claims, future environmental performance, sustainability labels and misleading product comparisons in the context of environmental, social and circularity characteristics.

The New Label Test

The Directive’s treatment of sustainability labels is one of its most important reforms. A sustainability label must be based on a certification scheme or established by public authorities. This is aimed at trust marks that appear independent, rigorous or official without having a credible basis.

The European Commission document “FAQ Empowering Consumers (GTD)”, published on 18 May 2026, explains that sustainability labels not based on a certification scheme or not established by public authorities are prohibited under the amended unfair commercial practices framework.

This does not mean every label is forbidden. It means labels must mean what they appear to mean. A company should be able to explain who owns the scheme, who verifies it, what criteria apply, what evidence is reviewed, how independence is protected and what the label does not cover.

Generic Green Claims Narrow

Generic environmental claims will also face a much tougher environment. Words such as “green”, “eco-friendly”, “sustainable”, “environmentally friendly” and “climate neutral” are powerful because they are broad. That is also what makes them dangerous when they are not precisely qualified and properly substantiated.

The European Commission webpage “Sustainable consumption”, available at the publication date of this article, states that Directive (EU) 2024/825 strengthens consumer protection rules against greenwashing and early obsolescence practices and improves information at the point of sale on durability, reparability and legal guarantee rights.

The lesson is simple. A vague green word is no longer a low-cost emotional flourish. It is a legal assertion about consumer meaning. If the claim cannot be defined, evidenced and defended, it should not sit at the centre of consumer communication.

Future Promises Need Architecture

The Directive also changes how companies speak about the future. A statement such as “net zero by 2030” may look like ambition. In consumer communication, however, ambition can become a claim. Once a future claim influences consumer perception, it requires structure.

The European Commission document “FAQ Empowering Consumers (GTD)”, published on 18 May 2026, explains that claims about future environmental performance require clear, objective, publicly available and verifiable commitments, supported by a detailed and realistic implementation plan, measurable time-bound targets and regular independent third-party verification.

This is a healthy discipline. The market does not benefit when future language substitutes for present evidence. Companies can still set ambitious targets. But consumer-facing promises should not sound like achieved performance if they are only aspirations awaiting execution.

Design Is Also Language

One of the Directive’s most important effects will be felt outside the legal department. It will be felt in design studios. Claims are not made only by sentences. They are made by colours, symbols, proximity, hierarchy, layout, images, icons, badges and the emotional architecture of a page.

Arendt, in “Publication of law of 9 June 2026 implementing Directive (EU) 2024/825 as regards empowering consumers for the green transition and updated Q&As published by EU Commission”, published on 15 June 2026, notes that environmental claims may arise through layout, colours, images, sounds, symbols and labels.

That means a company can create risk even with cautious copy. A blue value-for-money mark placed inside a green sustainability campaign can acquire a meaning it was never designed to carry. A medal near a leaf icon can imply endorsement of environmental attributes. Context can overclaim silently.

National Laws, Shared Core

Because this is a directive, national implementation matters. The EU core is common, but the legal route may differ. Some Member States implement through consumer codes, others through unfair commercial practice legislation, civil codes or sector-specific amendments. Enforcement agencies, sanction ranges and national guidance may also differ.

EUR-Lex, in its glossary entry “Transposition”, available at the publication date of this article, explains that transposition is the process of incorporating EU directives into the national laws of Member States. This is why companies should not treat every Member State as procedurally identical.

As of mid-August 2026, public implementation trackers and national sources indicate that several Member States have adopted national measures, including Germany, Italy, Ireland, Hungary, France, Croatia, Luxembourg and Slovakia. In other Member States, implementation was still pending, developing or subject to national procedural steps.

Implementation Is Not Identical

The same European rule can feel different in different markets. Linklaters, in “EU: The Directive on Empowering Consumers for the Green Transition, implementation in selected EU member states”, published on 11 March 2026, states that Germany implemented the Directive through an act published in the Federal Law Gazette on 19 February 2026.

Italy is notable for enforcement strength. The article “Italy Targets Greenwashing and Social Washing With Landmark New Rules”, published by Jones Day in April 2026, explains that Legislative Decree No. 30/2026 transposes Directive (EU) 2024/825 into the Italian Consumer Code and targets greenwashing and social washing.

Luxembourg provides another useful example. Arendt’s analysis “Publication of law of 9 June 2026 implementing Directive (EU) 2024/825 as regards empowering consumers for the green transition and updated Q&As published by EU Commission”, published on 15 June 2026, highlights a stricter understanding of certifier independence for sustainability labels.

Why Evidence Now Wins

The Directive will favour companies that can show their work. It increases the value of verifiable claims, transparent methods, defined scope and disciplined wording. In a marketplace where consumers distrust corporate assertion, independent research and traceable recognition become stronger strategic assets.

This is where ICERTIAS becomes more relevant, not less. The new EU framework does not reduce the value of independent recognitions. It raises the value of recognitions that can explain what they measure, how they are awarded, where they apply and what they do not claim.

The point is not that every recognition is automatically safe. The point is that recognitions with defined meaning are better suited to the new era than broad marketing superlatives. In the post-27 September market, scope is not a weakness. Scope is credibility.

What ICERTIAS Recognitions Mean

ICERTIAS recognitions have specific purposes. Best Buy Award concerns consumer-perceived value for money within a defined category, country and period. QUDAL - Quality Medal concerns consumer-perceived quality within a defined category, country and period. Customers’ Friend concerns customer experience and customer care within a defined market and scope.

The ICERTIAS webpage “Methodology | Best Buy Award by ICERTIAS”, available at the publication date of this article, states that Best Buy Award is not a sustainability, environmental or ESG label and is not designed to say anything about environmental or social performance.

The ICERTIAS webpage “Methodology | QUDAL - Quality Medal by ICERTIAS”, available at the publication date of this article, states that QUDAL - Quality Medal does not measure environmental, sustainability or ESG performance and focuses exclusively on how quality is perceived by respondents.

Customers’ Friend Has Defined Scope

Customers’ Friend should be understood with the same discipline. It concerns customer experience and customer care. It should not be stretched into environmental, climate, ethical, social-impact or ESG language unless the company has separate evidence supporting such claims.

The ICERTIAS webpage “Methodology | Customers’ Friend by ICERTIAS”, available at the publication date of this article, states that Customers’ Friend evaluates customer experience performance only and is not an environmental, ESG or sustainability label.

This approach fits the new EU direction. A recognition should not be asked to do work it was not designed to do. Best Buy Award should not become a green claim. QUDAL - Quality Medal should not become a safety claim. Customers’ Friend should not become an ethical sourcing claim.

Why They Are Different

ICERTIAS recognitions do not fall within the Directive’s sustainability-label logic when used for their true purpose because they do not promote environmental or social characteristics. They are not green, eco, ESG, climate, social-impact, ethical or sustainability recognitions.

Best Buy Award concerns value for money as perceived by consumers. QUDAL - Quality Medal concerns quality as perceived by consumers. Customers’ Friend concerns customer experience. Those are consumer-research and customer-experience recognitions, not environmental or social performance labels.

This distinction should be stated clearly in any responsible guidance. The new EU rules are concerned with claims about environmental, social and sustainability characteristics, among other consumer-information issues. ICERTIAS recognitions should remain in their proper lane and, precisely for that reason, remain robust.

The Strength Of Defined Scope

The strongest argument for ICERTIAS in the new EU environment is definition. The recognitions do not float in vague language. They are tied to category, country, year, methodology and verification. That is exactly the direction in which European claim discipline is moving.

ICERTIAS “Claims Governance”, published in April 2026, sets out three fundamental rules: scope, traceability and clarity. It states that Best Buy Award and QUDAL - Quality Medal should state the awarded category, country and year, while Customers’ Friend should state country and year.

This is not defensive compliance. It is commercial strength. A consumer is more likely to trust a claim that tells them what it means. A regulator is less likely to challenge a claim that is bounded and traceable. A competitor has less room to attack when scope is visible.

The Risk Of Misuse

Even a credible recognition can be misused. If a company places an ICERTIAS mark beside a sustainability slogan, a green visual field, an ESG paragraph or a climate promise, it may create an implication the recognition does not support. The issue is not the award. The issue is the surrounding message.

ICERTIAS “Claims Governance”, published in April 2026, gives a Best Buy Award example in which green styling and the headline “Green and Great!” are identified as problematic because they imply environmental endorsement that Best Buy Award does not confer.

This distinction is crucial. Directive (EU) 2024/825 does not make ICERTIAS recognitions weaker. It makes careful use more valuable and careless use more dangerous. The answer is not to stop using credible recognitions. The answer is to govern how they are used.

A Practical Rule For Brands

Companies using ICERTIAS recognitions should follow a simple rule: use each recognition only for what it measures. If the claim concerns value for money, Best Buy Award may be relevant. If the claim concerns perceived quality, QUDAL - Quality Medal may be relevant. If the claim concerns customer experience, Customers’ Friend may be relevant.

If the claim concerns sustainability, climate, recycling, carbon, ethics, social impact, health, safety or ESG performance, the company needs separate substantiation. An ICERTIAS recognition should not be used directly or indirectly as evidence for those claims unless the relevant claim is independently supported through another appropriate basis.

This is the cleanest way to preserve strength. The recognition remains persuasive because it remains honest. It does not overreach. It does not borrow meaning from sustainability language. It gives consumers a specific signal and lets that signal do its proper work.

How Companies Should Prepare

Before 27 September 2026, companies should audit their claims. Packaging, online product pages, retail displays, newsletters, point-of-sale materials, sustainability pages, social media, influencer scripts, comparison tables, mobile banners and QR destinations should all be reviewed.

Each claim should be classified. Is it environmental, social, ESG, value, quality, customer-experience, durability, repairability, software, guarantee, price or future-performance related? Many risks begin because teams use the same approval route for claims that require very different evidence.

The final test should be the overall impression. What does the average consumer take away in two seconds? If the answer is broader than the evidence, the execution needs revision. Fine print can clarify a fair claim. It cannot rescue a misleading headline or visual system.

The New Competitive Divide

The Directive will create a divide between companies with claim governance and companies with claim improvisation. The first group will become more credible. The second will become more exposed. The difference will not be visible only in courtrooms. It will be visible in consumer trust, retailer confidence and competitive resilience.

For marketing leaders, the lesson is not to become timid. It is to become precise. A narrower claim with proof is often stronger than a broad claim with doubt. In consumer markets, credibility is not the enemy of persuasion. It is now one of persuasion’s main engines.

For legal and compliance leaders, the task is not merely to block language. It is to build systems: approved claim libraries, scope rules, visual guidance, digital certificate links, local market review, audit trails and escalation triggers for sustainability or superiority language.

Precision Is Power

Directive (EU) 2024/825 marks a turning point in European consumer communication. It says, in effect, that claims must become more adult. They must say what they mean, show what supports them and avoid borrowing authority from symbols or words that imply more than the evidence can carry.

That is good news for ICERTIAS. Best Buy Award, QUDAL - Quality Medal and Customers’ Friend are valuable precisely because they can be used as defined, evidence-based, traceable recognitions. They are not ESG badges. They are not sustainability claims. They are not environmental certificates. Their strength lies in their specific meaning.

After 27 September 2026, the best companies will not communicate less.

They will communicate better.

They will use recognitions with visible scope, careful wording, clear traceability and disciplined design.

In a market that is learning to distrust fog, clarity will become the strongest signal of all.