Green claims law: what changed, and what is coming

Saying a product or a hotel is good for the environment is now a regulated act in both the UK and the EU. If you sell, list or simply repeat someone else’s environmental claim, the rules below decide whether you are allowed to, and what you need to be holding when somebody asks.

This page is written to be useful to anyone: a reader who wants to know why so many eco labels vanished, a business working out what it can say, or a platform working out what it can display. Every fact here carries its source at the bottom.

• In the UK, this is already live. The regulator can fine you directly, without going to court, up to 10 percent of global turnover.
• Repeating somebody else’s green claim can make it your claim. That is the change most businesses have not absorbed.
• In the EU, from 27 September 2026, a sustainability label you invented yourself becomes unlawful unless it rests on a third party certification scheme or a public authority.
• The evidence has to exist before you publish the claim, not be assembled later when somebody challenges it.

Status: in force now. The Digital Markets, Competition and Consumers Act 2024 was enacted on 24 May 2024, and its consumer protection powers took effect in April 2025.

• The Competition and Markets Authority can decide a business has broken consumer law and fine it directly, without first going to court.
• Penalties reach the higher of £300,000 or 10 percent of global annual turnover. Individuals can be fined up to £300,000.
• On 22 January 2026 the CMA published Making green claims: getting it right across the supply chain, its first cross sector guidance since the Green Claims Code of 2021.
• That guidance is the sharp one. A business can be treated as making a green claim where it repeats, relies on or passes on a claim that originated elsewhere, including through product descriptions, online listings, marketing material and imagery.
• Retailers and platforms cannot rely blindly on a supplier’s assurance. They are expected to take reasonable steps to verify, and what counts as reasonable scales with how significant the claim is, what evidence is available and the size of the business.

The practical effect: if you display a supplier’s environmental claim, you need to be able to show what you did to check it, and you need to have done that before publishing.

Status: applies from 27 September 2026. Directive (EU) 2024/825 was adopted on 28 February 2024. Member states had to transpose it into national law by 27 March 2026, and the rules apply from 27 September 2026.

• Sustainability labels that are not based on a third party certification scheme, or established by a public authority, are banned. A badge a company invented for itself becomes unlawful.
• Generic environmental claims are banned without substantiation. Words such as eco friendly, green and climate neutral cannot stand on their own.
• Climate neutrality claims resting on carbon offsetting are restricted. Offsetting alone will not support a claim that a product is climate neutral.

This is the certification rule. It is the reason the direction of travel across travel and retail is away from self scored badges and towards assessment by somebody outside the company making the claim.

There is a separate proposal called the Green Claims Directive, and it is not the same thing as the directive above. It was the proposal that would have required mandatory third party verification of every explicit environmental claim.

On 20 June 2025 the European Commission announced its intention to withdraw it, after objections that it was too complex and costly, particularly for small businesses. Final negotiations were cancelled days later. It was never formally withdrawn, so its legal status remains unresolved.

Cite it as a live requirement and anyone who follows this properly will correct you. The two rules above are real, in force or dated, and they are more than enough.

Booking.com launched its Travel Sustainable programme in 2021 and awarded a badge to more than 500,000 properties, scoring them with levels and green leaves.

The Netherlands Authority for Consumers and Markets called the scheme misleading, saying it risked giving a distorted impression of how sustainable a property actually was, partly because some of the listed measures were not significant, such as removing single use plastics that were already banned in the EU. Booking.com took the programme offline on 25 March 2024 and moved to labelling third party certification instead, with a filter to match.

Worth being precise about the cause, because it is often reported loosely: this was regulator action in 2024, not the Empowering Consumers Directive, which does not apply until September 2026. It is what the new rule looks like arriving early.

If you sell something: hold the evidence for every environmental claim before it goes live, be specific rather than generic, and be careful with any label you created yourself.

If you list other people’s products or properties: the supply chain guidance is aimed squarely at you. Repeating a supplier’s claim can make it yours, and blind reliance on their word is not a defence. What protects you is a record of what you checked, against what source, and when.

If you are reading rather than selling: this is why badges are disappearing and why certification names are appearing in their place. It is also a reasonable test to apply to us. Ask where a claim came from and when it was last checked, and if a site cannot tell you, that is your answer.

Everything above, with its source. Primary legislation and regulators first, then legal analysis. All checked on 8 August 2026.

Primary sources

• EUR-Lex: Directive (EU) 2024/825, the Empowering Consumers Directive, full text
• ACM (Netherlands Authority for Consumers and Markets): Booking.com takes Travel Sustainable programme offline following ACM action
• European Commission transition pathways: Directive (EU) 2024/825 summary for retail

UK: DMCC Act and CMA enforcement

• Pinsent Masons: DMCC Act overhauls UK consumer law enforcement and expands consumer rights
• Ashurst: Liftoff for the CMA direct consumer enforcement powers
• Baker Botts: New CMA consumer protection comes into force, April 2025

UK: the January 2026 supply chain guidance

• White & Case: Supply chain green claims: UK CMA signals enforcement escalation
• Freshfields: CMA new guidance sharpens expectations on environmental claims about supply chains
• Norton Rose Fulbright: Green claims: CMA guidance on supply chain responsibility
• Fieldfisher: CMA issues significant new guidance on supply chain responsibility for environmental claims
• TLT: Navigating green claims: CMA guidance for supply chain actors

EU: the withdrawn Green Claims Directive proposal

• Latham & Watkins: Commission announces intention to withdraw the Green Claims Directive proposal, status remains unclear
• European Economic and Social Committee: Current affairs: withdrawal of the Green Claims Directive

The Booking.com badge

• PhocusWire: Booking.com drops the Travel Sustainable programme
• Skift: Booking.com ends possibly misleading sustainability programme
• ShortTermRentalz: Booking.com ends sustainability programme due to ACM pressure

It would be poor form to write all of that and not meet it. Our method is published and versioned, our commercial relationships are disclosed with a register of who has paid us, anyone can challenge a rating and every correction is logged in public, and the data carries the source and the date behind each field.

You can check all of that from the transparency page.