The European Commission has scheduled an EMAS Helpdesk webinar for September 30, 2026, to explain how Directive (EU) 2024/825 on empowering consumers for the green transition (ECGT) will apply in the EU from September 27, 2026. From that date, generic environmental claims, climate-neutral claims that rest on offsetting, and sustainability labels that are not based on a certification scheme or not established by public authorities become unfair commercial practices. The two-hour English session, 10:00 to 12:00 CEST, maps how Eco-Management and Audit Scheme (EMAS) registration interacts with those bans.
The Directive was published in the Official Journal on March 6, 2024 and entered into force on March 26, 2024. Member States had until March 27, 2026 to transpose it; several missed that deadline and sit in infringement. The application date of September 27, 2026 is not postponed. The EMAS Helpdesk webinar is operational guidance, not a stay of enforcement.
What becomes illegal on September 27, 2026?
Three categories of environmental communication in a commercial practice toward consumers are blacklisted. A generic environmental claim (for example "eco-friendly", "green" or equivalent) is prohibited unless the trader demonstrates recognised excellent environmental performance relevant to the claim. A claim that a product has a neutral, reduced or positive environmental impact because of greenhouse-gas offsetting is prohibited; residual emissions cannot be netted into a climate-neutral or carbon-neutral claim. Displaying a sustainability label that is not based on a certification scheme, or not established by public authorities, is prohibited; self-created logos and in-house seals fall.
A claim about a future environmental objective or climate strategy is lawful only if it is clear, objective, publicly available and verifiable, with a detailed implementation plan, measurable time-bound targets and independent monitoring. EMAS environmental programmes sit inside that test.
| Practice | Until September 26, 2026 | From September 27, 2026 |
|---|---|---|
| Generic claim ("green", "eco-friendly") | Contested under existing UCPD rules | Per-se unfair unless recognised excellent environmental performance is shown |
| Climate-neutral via offsets | Widely used in consumer copy | Banned as an unfair commercial practice |
| Self-created sustainability label | Common on packs and websites | Banned unless a certification scheme or public authority stands behind it |
| Future environmental objective | Often unsubstantiated roadmap language | Lawful only with a detailed, time-bound, independently monitored plan |
Who has to comply, including cosmetics brands?
Every trader that makes an environmental claim in a commercial communication to EU consumers is in scope, regardless of where the company is established. That includes cosmetics and personal-care brands whose packs, ads, e-commerce pages or influencer briefs use "natural", "organic", "eco", "clean" or equivalent environmental language. Regulation (EU) No 655/2013 remains the lex specialis for cosmetic product-claim substantiation; ECGT adds a consumer-protection overlay that can prohibit the same wording as an unfair commercial practice even where a 655/2013 file exists. National consumer authorities will enforce, not cosmetics competent authorities.
Italy transposed by Decreto Legislativo 20 febbraio 2026, n. 30 (applicable September 27, 2026, AGCM). Romania transposed by OUG 18/2026 (green-claims rules apply September 27, 2026, ANPC). Austria amended the UWG on July 7, 2026, also applicable September 27, 2026. Member States that missed the March 27, 2026 transposition deadline, including Czechia, Sweden, Hungary and Spain, do not get extra time: the bans apply on September 27, 2026 while Commission infringement continues in parallel.
Does EMAS registration keep environmental claims legal?
No. EMAS registration under Regulation (EC) No 1221/2009 is a recognised environmental-management scheme. The webinar will present an EMAS-ECGT mapping paper on where that scheme can support a claim and where it cannot. The paper is not yet published; the Green Forum page states that the full agenda will follow. Until then, treat EMAS as evidence of a management system and of verified organisation-level performance, not as a licence to put "eco-friendly", "climate neutral" or a house sustainability logo on a product.
EMAS can underpin organisation-level performance communication and, where the verified data match the claim, a specific non-generic statement. It does not cure an offset-based climate-neutral claim, a self-created label, or a generic product claim that is not tied to recognised excellent environmental performance of that product.
What must teams do before September 27?
Complete a line-by-line inventory of every environmental statement that will still be live on September 27, 2026: on-pack, e-commerce, paid media, retailer copy and influencer briefs. Pull anything generic, anything that nets residual emissions through offsets, and any in-house sustainability seal that is not a certification scheme or a public-authority label. Rewrite future-objective language so each remaining claim has a public, time-bound plan and independent monitoring. Cosmetics teams should run the same inventory against the 655/2013 file so a claim that survives ECGT still meets the common criteria.
Where a Member State has named the enforcer (AGCM, ANPC, the Austrian UWG courts), brief that contact and the expected path: typically the national unfair-commercial-practice fine and a stop order, not a cosmetics-file deficiency. Continuous, per-jurisdiction monitoring surfaces this kind of claims-rule change the moment a Commission page or a national transposition publishes.
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Verify applicability of each live claim, check the transposing act and named enforcer in each Member State where you sell, and brief marketing, packaging, legal and, for cosmetics, the person responsible under Regulation (EC) No 1223/2009. Obsidian tracks ECGT application, EMAS guidance and national green-claims transpositions as they publish.
