Green Claims and Product Data: What EU E-Commerce Must Show From September 2026

On 27 September 2026, the Empowering Consumers for the Green Transition Directive starts to apply across the EU. It changes what you are allowed to say about a product's environmental credentials, and it adds mandatory information to the buying flow.

This one is unusual because the work is mostly content and templates rather than architecture. That makes it cheap to do and easy to postpone until it is expensive. It also arrives on top of the General Product Safety Regulation, which has been quietly reshaping product listings since December 2024 and which a lot of sites still have not fully implemented.

Together they mean your product detail page has a longer list of required elements than it did two years ago.

The Empowering Consumers Directive

Directive (EU) 2024/825 amends the Unfair Commercial Practices Directive and the Consumer Rights Directive. Member States had to transpose it by 27 March 2026, and it applies from 27 September 2026.

Generic environmental claims are out

Claims like "eco-friendly", "green", "climate neutral", "environmentally conscious" or "kind to nature" become prohibited unless you can demonstrate recognised excellent environmental performance relevant to the claim.

That is a much higher bar than it sounds. It is not enough that the claim is technically defensible. Vague claims without specification are banned outright as misleading.

The workable alternative is specific and substantiated. "Made from 80 percent recycled polyester" is a claim you can support. "Eco-friendly fabric" is not.

Offsetting claims are out

Claiming that a product has a neutral, reduced or positive environmental impact because of emissions offsetting is prohibited. This is the provision that ends "carbon neutral shipping" and "climate neutral product" badges where the neutrality comes from buying credits.

You can still buy offsets. You cannot use them as the basis for a product-level neutrality claim to consumers.

Sustainability labels need certification

Displaying a sustainability label that is not based on a certification scheme or established by public authorities is prohibited. Self-created badges are the target. If your site displays a green leaf icon your design team invented, it needs to go or be backed by a real scheme.

Durability and repairability information

The directive adds obligations around commercial guarantees, durability and software updates:

• Presenting requirements imposed by law as a distinctive feature is banned. "Free two year warranty" cannot be presented as a benefit when it is the statutory minimum.
• Omitting information about a software update that negatively affects functionality is banned.
• Presenting goods as repairable when they are not, or failing to say that repair is restricted, is banned.
• Where a producer offers a commercial guarantee of durability longer than two years, a harmonised label must be shown.
• A harmonised notice informing consumers of the statutory guarantee of conformity must be provided.

The harmonised notice and label are specified formats. They have to appear in the buying flow, which is a template change on product pages and, depending on your implementation, in the cart or checkout.

What This Means as Work

The plan we use with e-commerce clients:

Audit every claim on the site. Product descriptions, category pages, banners, the sustainability landing page, email templates, packaging images, filter labels and the badges on product cards. Export product descriptions from your PIM or CMS and grep for the vocabulary: eco, green, sustainable, natural, climate, carbon, neutral, biodegradable, planet, environmentally.

The list is always longer than expected, because claims accumulate over years across product imports, supplier copy and marketing campaigns.

Classify each claim. Substantiated and specific, keep. Generic, rewrite or delete. Offsetting-based, delete. Self-created label, delete or replace with a certified scheme.

Fix the data model, not just the text. If sustainability claims live in free text descriptions, you will be doing this again. Structured attributes for recycled content, certifications with scheme references, durability guarantee length and repairability information mean you can validate at import and generate consistent, compliant display.

Implement the harmonised notice and label. These need a place in the page template and in your translation pipeline for every language you serve.

Update supplier onboarding. If you sell third-party products, supplier-provided copy is where non-compliant claims enter. Add claim requirements to your supplier data specification and validate at import.

The GPSR Layer Underneath

The General Product Safety Regulation (EU) 2023/988 has applied since 13 December 2024, and its distance selling obligations are still incompletely implemented on a lot of sites.

For any product offered online, the listing must clearly show:

• The name, registered trade name or trade mark of the manufacturer, plus a postal address and electronic contact details.
• Where the manufacturer is outside the EU, the name, postal address and electronic contact details of the responsible person established in the EU.
• Information identifying the product, including a picture, the type and any product identifier.
• Any warning or safety information required, in a language easily understood by consumers in the Member State where the product is sold.

Online marketplaces carry additional obligations, including a single contact point for authorities and consumers, registration on the Safety Gate portal, and acting on authority orders to remove dangerous product listings without undue delay, generally within two working days.

The recurring failure we see is treating this as a data problem for the legal team rather than a schema problem. Manufacturer contact details and EU responsible person are product attributes. They need fields, they need validation, and they need to be mandatory at import. Sites that handled it by adding a paragraph to a template end up with thousands of listings where the paragraph is empty.

There is also a language dimension that catches multilingual retailers. Warnings must be in a language easily understood in the Member State of sale, which means your translation pipeline needs to treat safety text as mandatory content rather than as optional marketing copy.

What Is Coming After

Two files worth tracking without building for yet.

The Green Claims Directive would add a mandatory ex-ante verification regime for explicit environmental claims, with independent verification before a claim is used. It has had a difficult passage and its final shape is not settled. If it lands, it turns claim substantiation from an internal exercise into a certification process.

The Digital Fairness Act is expected as a Commission proposal in late 2026, aimed at dark patterns, personalised pricing, addictive design and influencer marketing. Application is realistically 2028 to 2030. It matters now because it signals which patterns have a limited future: fake urgency counters, drip pricing, pre-ticked boxes, confirmshaming, and the general category of interface designs that work by making the user's preferred option harder to find.

If your conversion rate depends on any of those, it is worth knowing the direction of travel.

Why This Is Worth Doing Properly

There is a reason to treat this as more than a compliance chore.

Structured, verified product information is the same asset that drives good search visibility, rich results and clean product feeds. Schema.org product markup wants exactly the fields that GPSR and the Empowering Consumers Directive require: manufacturer, identifiers, warranty terms, material composition. The retailers who did this work as a data project rather than a template patch ended up with better feeds, fewer marketplace rejections and better organic visibility.

Compliance and merchandising want the same thing here, which does not happen often.

Where to Start

If you sell physical goods to EU consumers, spend a day doing three things:

1. Export your product descriptions and grep for environmental vocabulary. Count the claims.
2. Check what percentage of your catalogue has manufacturer contact details and, where relevant, an EU responsible person. Then check whether it is displayed on the listing.
3. Look at your product page template and work out where the harmonised guarantee notice will go.

That gives you a scope estimate, which is what you need before September.

We build and maintain e-commerce platforms for companies selling across Europe, including product information management, multilingual content pipelines and the structured data that both regulators and search engines want. If you need help with the catalogue side of this, write to office@c9group.dev.

The wider regulatory picture is in our 2026 EU digital compliance guide, and there is more about our European work on the market entry page.

We build software rather than provide legal advice. Whether a specific claim is substantiated is a question for your counsel, and we build the system that carries whatever answer they give.