Environmental Claims on Apparel: What the EU Now Prohibits Outright

Many apparel brands have spent two years being told to get ready for the Green Claims Directive. That directive is not law, negotiations on it stopped, and the Commission has announced it intends to withdraw the proposal. Meanwhile a different instrument, adopted, and applying in the Member States from 27 September 2026, makes a short list of environmental marketing practices unlawful in all circumstances, and several of them describe exactly how garments are currently marketed.

Check the product scope, market and application dates against the current legal text. Confirm project-specific obligations with a qualified adviser.

The distinction that decides everything

European unfair commercial practices law works on two levels. Most misleading practices are assessed case by case: would this have caused the average consumer to take a decision they would not otherwise have taken? That assessment is where arguments happen.

Then there is an annex listing practices that are unfair in all circumstances. On that list, the assessment does not happen. There is no argument about whether anyone was actually misled, no defence that the claim was technically true, and no weighing of context. The practice is on the list, so it is prohibited.

The change that matters for apparel is that five environmental marketing practices have been added to that list, applying in the Member States from 27 September 2026.

Each of these describes a way of talking about products that is common in apparel and is prohibited without further inquiry.

Generic environmental claims

The first is the one that reaches many hangtags: making a generic environmental claim where the trader cannot demonstrate recognised excellent environmental performance relevant to that claim.

The Directive's own recitals give examples of what counts as generic, and the list is worth reading slowly because it is not a list of obviously silly claims. It includes environmentally friendly, eco-friendly, green, nature's friend, ecological, environmentally correct, climate friendly, gentle on the environment, carbon friendly, energy efficient, biodegradable and biobased, along with any similar statement suggesting excellent environmental performance.

What counts as recognised excellent environmental performance is narrower than many brands expect. The Directive points to the EU Ecolabel, to officially recognised ecolabelling schemes in Member States operating under the international standard for that kind of scheme, and to top performance under other Union law such as the highest class of an energy label. A commercial certification held on a material is not automatically one of those things.

And the performance has to be relevant to the claim actually made. The Directive's own worked example is that a claim of biodegradability cannot rest on an ecolabel whose criteria contain no biodegradability requirement. Holding a recognition proves what that recognition covers, not whatever the marketing team wrote.

A true fact about one part is not a claim about the product

The second prohibition is one likely to catch a brand acting in good faith: 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 business.

Nothing about the garment changes between these two statements. Only one of them describes it.

A garment is an assembly. It has body fabric, often a lining, sewing thread, interlinings, trims, labels and packaging, a point trims and components makes for a different reason. A recycled body fabric is a fact about the body fabric. Presented as *made from recycled materials*, it becomes a statement about a product that also contains conventional thread, conventional trims and conventional packaging.

The same applies upward. A brand with one initiative in one part of its operation, describing itself as sustainable, is making a claim about the whole business from a specific activity. Both directions are on the list.

The workable response is not to stop saying anything. It is to say the specific thing that is actually true and evidenced: which component, which material, and on what basis, which is the same discipline the site applies to performance claims, where a property, a method and a condition have to travel together for a claim to mean anything.

Offsetting cannot produce a neutrality claim

The third is short and absolute: claiming, on the basis of offsetting greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.

Note what it does and does not reach. It does not prohibit offsetting, and it does not prohibit saying that a business offsets. It prohibits converting offsetting into a product-level impact claim, carbon neutral, climate neutral, net zero as a property of the garment. That route to the claim is closed regardless of the quality of the offsets behind it.

Sustainability labels, and labels that are not schemes

The fourth prohibition concerns displaying a sustainability label that is not based on a certification scheme or established by public authorities. In practice that reaches self-created marks: a leaf icon, a brand's own green tag, an internal rating badge printed alongside genuine certification marks where a consumer cannot tell the difference.

Holding one does not authorise the other, and displaying the mark can itself be the claim.

The law is not a feature

The fifth addition is not framed as an environmental provision but bites hardest in this area: presenting requirements imposed by law on all products in the relevant category on the EU market as a distinctive feature of your offer.

Apparel does this often. A substance that is already restricted for all textiles in the EU, advertised as though its absence were a brand choice. A statement of compliance with a rule every competitor must also meet. The claim is true and it is not a distinction, and presenting it as one is now on the list.

The practical filter is a single question: would every other compliant product in this category be able to say the same thing? If so, saying it as a feature is the problem, not saying it at all. What is actually restricted, and for which products, is covered in chemical compliance.

The same list also reaches durability and repair

Two more additions to the same list are not environmental provisions but land on apparel marketing in the same way, and they belong here because a brand reviewing its claims against the annex needs the whole annex.

The first is falsely claiming that, under normal conditions of use, a good has a certain durability in terms of usage time or intensity. That reaches the durability language apparel reaches for most readily, a number of washes, a number of years, a garment described as lasting a lifetime. It does not prohibit durability claims; it prohibits ones that are not true. The distinction rests entirely on whether evidence exists for the specific figure being stated.

The second is presenting a good as allowing repair when it does not. A repair programme that exists in the marketing and not in the operation is on the list, and so is a garment presented as repairable whose construction does not permit it.

The directive many brands prepared for is not the one that applies

This is worth stating plainly because a great deal of published guidance has it the wrong way round.

One amends the rules directly and is being applied. The other never became law.

Where this sits for a manufacturer and a brand

These are marketing rules. They govern what is said to a consumer in a market, which means they attach to whoever makes the claim, normally the brand rather than the factory. A manufacturer can supply a certified material, a test report or a bill of materials; it cannot make a brand's claim lawful, and it has no visibility of what will eventually be printed.

That has a practical consequence for sourcing. If a claim depends on evidence about a material or a process, the evidence has to exist before the claim is printed, and it has to cover the specific goods rather than a category. That is the same discipline as chemical test reports: a report describes a tested sample, and what a certification establishes is what the scheme's criteria say and no more.

The last line is the one that prevents recurrence. Many problem claims are not written by anyone who considered the legal position; they are written by someone naming a collection.