Anti-Greenwashing Directive: What Changes for My Environmental Claims From 27 September 2026?

Persona: Sustainability and Communications Manager, manufacturing or consumer goods company, Europe

The mechanism of proof is changing, and it is changing fundamentally.

Until today, environmental claims had to be assessed on a case-by-case basis. To prohibit a claim, authorities needed to demonstrate that, in its specific context, it could mislead consumers.

From 27 September 2026, certain environmental claims become prohibited by definition, and companies must possess the evidence supporting them before anyone challenges them. This does not only concern companies that have exaggerated their environmental communications. It concerns any company that has ever used terms such as “sustainable”, “low impact”, or “carbon neutral” on a label, website, marketing material, or press release.

Italian Legislative Decree No. 30 of 20 February 2026, implementing EU Directive 2024/825 (the Anti-Greenwashing Directive), does not introduce a completely new obligation. The prohibition of misleading commercial practices already existed. The difference is that environmental claims were not included in any blacklist and therefore always had to be assessed individually.

From 27 September onwards, certain categories of environmental claims enter an automatic blacklist. Authorities no longer need to demonstrate that a claim is misleading. The mere existence of the claim in that form is sufficient. Penalties imposed by the Italian Competition Authority (AGCM) can reach up to €10 million, or up to 4% of annual turnover for widespread infringements at European level.

Environmental Claims That Become Prohibited by Definition

The legislation introduces a closed list of environmental claims that are prohibited in all circumstances, without any need to assess context.

The first category concerns claims of neutral, reduced, or positive environmental impact that are based on carbon offsetting schemes outside the product’s value chain. A statement such as “carbon neutral through the purchase of carbon credits” is prohibited. Not because carbon offsetting is necessarily fraudulent, but because it does not describe the actual environmental impact of the product itself. Claims referring to genuine emissions reductions achieved throughout the product’s life cycle remain allowed, provided they are clearly specified and can be substantiated.

The second category concerns sustainability labels that are neither based on a certification scheme subject to third-party independent verification nor established by a public authority. Self-declared labels, internally created sustainability marks, and labels lacking an independent certification system are prohibited by definition. For labels already in use, no transitional period applies.

The third category concerns claims relating to only one aspect of a product but presented as though they apply to the product as a whole. For example, highlighting recycled content when only the packaging contains recycled materials may fall within this category.

There is also the category that catches the greatest number of companies by surprise: generic environmental claims. Terms such as “eco-friendly”, “green”, or “environmentally friendly” are permitted only where the company can demonstrate a recognized and relevant form of environmental excellence. Under the Directive, this generally requires support from an EU Ecolabel, an officially recognized Type I national eco-label, or another form of top-tier environmental performance established under European legislation.

A claim ceases to be generic when it is clearly specified on the same communication medium. For example, “climate-friendly packaging” remains a generic claim, whereas “100% of the energy used to manufacture this packaging comes from renewable sources” is specific and remains permissible if properly substantiated.

Visual communication must also be assessed carefully. Leaves, landscapes, or green colour palettes, on their own, are not sufficient to constitute a generic environmental claim, because the Directive defines such claims as written or oral statements. However, when combined with text or logos, they may contribute to an environmental claim or be interpreted as a sustainability label. Furthermore, if visual elements create the impression of an environmental benefit that does not exist, they may still be challenged as misleading commercial practices and assessed on a case-by-case basis.

In none of these cases is fraudulent intent required. No consumer complaint is necessary. The mere existence of the claim on a label, a website, or within a marketing campaign is sufficient.

How To Substantiate an Environmental Claim That Can Withstand Scrutiny

Simply having “evidence” is not enough.

A claim capable of withstanding scrutiny must be supported by evidence with two specific characteristics:

• objective, meaning based on factual data;
• linked to the specific product, not to the company in general.

These are precisely the two characteristics that define a Digital Product Passport (DPP).

The DPP is not a document. It is a system of verifiable data linked to a specific product, continuously updateable over time, and independently accessible to market surveillance authorities and supply-chain stakeholders.

By its very nature, the DPP excludes the two most common forms of documentation traditionally used to support environmental claims. A self-declaration unsupported by objective evidence merely reflects what management states. A company-level process certification demonstrates how an organization operates in general. Neither links information to a specific product in a manner that can be independently verified by third parties.

To understand concretely what a DPP is and how it works, see Q&A 11 – What Data Should I Include in My Product’s DPP?

Companies that are building a Digital Product Passport today are often, without realizing it, building precisely this infrastructure. The DPP is not an additional compliance project. It is the foundation on which a company’s environmental claims stand or fall.

Legislative Decree 30/2026 has not changed the rules of the game. It has simply made the playing field visible. An environmental claim that cannot withstand an inspection, a retailer’s request, or a legal challenge was never merely a communication asset. It was a risk that had not yet materialized.

Companies that build today the evidence chain supporting their environmental claims are doing more than ensuring compliance. They are transforming a promise into something capable of withstanding scrutiny from anyone who chooses to question it.