What is the Empowering Consumers Directive? It is Directive (EU) 2024/825, the EU law that rewrites the rules on green marketing by adding generic environmental claims, carbon neutral claims based on offsetting and self-certified sustainability labels to the list of commercial practices that are banned in all circumstances, and it starts to apply across the single market on 27 September 2026, fifteen days from today. The deadline arrives with the legal map still unfinished: on 28 May 2026 the European Commission opened infringement procedures against 20 member states that had not notified complete transposition, and national consumer authorities have only recently agreed how to treat products already on shelves. For general counsel at any brand, retailer or marketplace that sells to EU consumers, including those based in the UK, the US or Asia, the directive is now the most immediate piece of ESG law on the calendar, arriving while the wider ESG agenda is being reshaped by the Omnibus simplification of the CSRD and the CSDDD. This analysis explains what the directive does, what it bans, how it will be enforced and how it fits with the rest of the post-Omnibus sustainability rulebook.
What the Empowering Consumers Directive is
The short answer is that the Empowering Consumers Directive, often shortened to EmpCo or ECGT, is an amending directive rather than a free-standing code. It inserts new definitions, new misleading-practice rules and new blacklisted practices into the Unfair Commercial Practices Directive (Directive 2005/29/EC, the UCPD), and it adds new pre-contractual information duties on durability and repair to the Consumer Rights Directive (Directive 2011/83/EU).
The timetable is fixed in the directive itself. It was adopted on 28 February 2024 and published in the Official Journal on 6 March 2024. Member states had until 27 March 2026 to transpose it and must apply the new rules from 27 September 2026, a preparation period that the EU's Consumer Protection Cooperation (CPC) network describes as two and a half years in its June 2026 common understanding on old stock.
Because it works through the UCPD, the directive keeps that law's scope and its enforcement model. As the CPC network puts it, the directive does not regulate the placing of products on the market; it governs how products are presented to consumers, through packaging, websites, advertising and other commercial communications. Enforcement stays with national authorities and courts, not with Brussels.
The key new definitions, now written into Article 2 of the UCPD, are:
- Environmental claim. Any message that states or implies that a product, product category, brand or trader has a positive or zero impact on the environment, is less damaging than competitors, or has improved its impact over time.
- Generic environmental claim. An environmental claim whose specification is not provided in clear and prominent terms on the same medium.
- Sustainability label. A voluntary trust mark, quality mark or equivalent that sets a product, process or business apart by reference to its environmental or social characteristics.
- Certification scheme. A third-party verification scheme open on transparent, fair and non-discriminatory terms, with independent monitoring of compliance.
- Recognised excellent environmental performance. Performance that complies with the EU Ecolabel Regulation, a nationally or regionally recognised EN ISO 14024 type I ecolabel, or top environmental performance under other applicable EU law.
Who the directive applies to
The directive applies to every trader that makes environmental claims or uses sustainability labels in dealings with consumers in the EU, wherever the trader is established. TLT's August 2026 briefing makes the point plainly: all traders selling to EU consumers, whether or not they are based in the EU, will need to comply from 27 September. A UK fashion label shipping to Dublin, a US cosmetics brand selling through a German online shop and an Asian electronics maker listing on a pan-European marketplace are all inside the net for the claims they make to EU consumers. Marketplaces that host third-party listings are already under separate pressure from Brussels over product risks, as the €550m Digital Services Act fine on AliExpress showed.
The directive is, however, confined to business-to-consumer practices. The Commission's updated Questions and Answers, published on 18 May 2026 and summarised by Arendt, state that the directive does not alter the general scope of the UCPD and so applies to B2C commercial practices only. Claims made purely between businesses, for example in a supplier's sales pitch to a retailer, fall under the separate and less harmonised law on unfair market practices between companies.
Two qualifications matter in practice. First, member states may go further in their own law: Latham & Watkins noted in its 9 September 2026 alert that France extends UCPD protections to B2B contexts. Second, the same Q&A confirms that brand names, product names and company names can themselves be environmental claims. Whether a name such as one containing "eco" or "green" is caught depends on whether its use would lead the average consumer to expect an environmental benefit, assessed case by case.
The new greenwashing blacklist
The heart of the Empowering Consumers Directive is a set of additions to Annex I of the UCPD, the blacklist of practices that are unfair in all circumstances. For a blacklisted practice, an authority or claimant does not need to prove that the average consumer was misled or that their decision was distorted: showing that the practice occurred is enough. That is the step change from the old case-by-case test.
| Annex I point | Practice banned outright from 27 September 2026 | Typical example at risk |
|---|---|---|
| 2a | Displaying a sustainability label that is not based on a certification scheme or established by public authorities | An in-house "planet approved" badge |
| 4a | Making a generic environmental claim where the trader cannot show recognised excellent environmental performance relevant to the claim | "Eco-friendly", "green" or "climate friendly" with no specification |
| 4b | Making an environmental claim about the entire product or business when it concerns only a certain aspect | "Made with recycled material" when only the packaging is recycled |
| 4c | Claiming, based on offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment | "Carbon neutral product" backed by purchased credits |
| 10a | Presenting requirements imposed by law on all products in the category as a distinctive feature of the trader's offer | Advertising a legally mandated ban on a substance as a special benefit |
| 23d to 23j | Early-obsolescence practices: hiding the effect of software updates, false durability or repairability claims, pushing early replacement of consumables, hiding limits on non-original parts | Claiming a device can be repaired when it cannot |
Alongside the blacklist, the directive strengthens the general misleading-action rules in Article 6 of the UCPD and the misleading-omission rules in Article 7, so claims that escape the blacklist can still be challenged on a case-by-case basis. Those provisions cover future performance claims, comparisons and the presentation of irrelevant benefits, discussed below.
Generic environmental claims and "recognised excellent environmental performance"
A generic environmental claim is lawful after 27 September only if the trader can demonstrate recognised excellent environmental performance relevant to the claim, which in practice means holding the EU Ecolabel, a qualifying official ecolabel, or meeting a top-performance standard set by EU law. For most consumer goods, no such benchmark exists, so the practical effect is that vague words used on their own will have to go.
The definition turns on specification. A claim is generic if its specification is not provided "in clear and prominent terms on the same medium". A drinks can marked "better for the planet" with no further explanation on the can is generic. The same product marked "packaging made from 80% recycled aluminium" is a specific claim, which must still be accurate and substantiated under the ordinary rules, but is not blacklisted. The "same medium" test means that a footnote on a separate web page is unlikely to cure a generic claim on the pack or in a video advert.
Advisers expect three categories of wording to be most exposed: umbrella adjectives such as "sustainable", "natural", "eco" and "conscious"; climate terms such as "climate positive" or "low impact"; and colour and imagery cues that imply environmental benefit. The UK's experience is instructive on the last point. When the Competition and Markets Authority secured undertakings from ASOS, Boohoo and George at Asda in March 2024, one of the commitments was not to use "natural" imagery such as green leaves, or logos and icons, in a way that suggests a product is more environmentally friendly than it is. EU regulators are likely to read the new definitions just as broadly.
Carbon neutral and offset-based claims
From 27 September 2026 a trader may no longer claim that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions where that claim rests on offsetting. This is point 4c of the new blacklist, and it is the change that removes the familiar "carbon neutral" and "climate neutral" product labels backed by purchased credits.
The ban targets product-level impact claims based on offsets, not climate finance as such. According to TLT, businesses may still describe investments in carbon credit projects, provided that information is presented transparently and is not misleading. A statement that a company funds a named reforestation project, with the volume and standard of credits, is a different message from telling consumers that the product itself has no climate impact.
The courts had already started down this road before the directive applied. On 26 August 2025 a Frankfurt regional court ruled that Apple had misled consumers by marketing the Apple Watch as a "CO2-neutral product", in a case brought by Deutsche Umwelthilfe under German unfair competition law. Insurance Journal reported that the claim relied on a eucalyptus planting project in Paraguay and that the court found leases for 75% of the project area were not secured beyond 2029. Apple said the ruling broadly upheld its approach but that it would phase out the "carbon neutral" label by September 2026 to comply with the incoming EU rules.
Counsel should also watch the interaction with other climate rules. A company that reports emissions under the CSRD, or that pays for embedded carbon under the EU carbon border adjustment mechanism, holds data that consumer authorities and campaign groups can use to test marketing claims. The reported number and the marketing message need to tell the same story.
Sustainability labels and certification schemes
After 27 September a sustainability label may be displayed only if it is based on a certification scheme or established by public authorities. Point 2a of the blacklist removes self-created and self-awarded labels, which have multiplied on packaging and product pages in recent years.
The definition of a certification scheme sets a real bar. The scheme must be run by a third party, open to all traders willing and able to comply on transparent, fair and non-discriminatory terms, and subject to independent monitoring of compliance. A brand's internal "responsible range" badge, a retailer's own "better choice" icon or an industry logo with no independent verification will not qualify. Because the definition of a sustainability label covers social as well as environmental characteristics, the rule also reaches marks about fair wages, worker welfare or ethical sourcing.
Retailers need to check not only their own labels but those that appear on third-party products they sell and on their websites, including search filters and category badges. The CMA's March 2024 undertakings required the three UK retailers to make statements about accreditation schemes clear as to whether the accreditation applied to particular products or to the firm's wider practices, and required product filters to show only items meeting the filter's criteria. Brands looking for help with label strategy and advertising copy can find advertising and marketing law advisers in the Corporate INTL directory.
Net zero targets, comparative claims and durability
The directive does not ban net zero pledges, but it makes them much harder to use in consumer marketing. Under the new Article 6(2)(d) of the UCPD, a claim about future environmental performance is misleading unless it is backed by clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan, with measurable, time-bound targets, that is regularly verified by an independent third-party expert whose findings are made available to consumers.
That requirement converts what was often a corporate aspiration into a verifiable obligation. Italy's competition authority showed the direction of travel under the existing rules when it fined Shein's European platform operator €1 million in August 2025; according to reporting on the decision, the authority found that targets to cut emissions by 25% by 2030 and reach zero by 2050 were presented in a vague and generic way and were contradicted by increases in reported emissions. Boards that tie executive pay to environmental performance should expect the same targets to be scrutinised when they appear in advertising.
Comparative claims are also tightened. TLT summarises the new Article 7(7) as requiring any comparison of products on environmental or social characteristics to include clear information about the comparison method, the products compared, their suppliers and how the information is kept up to date. Article 6(2)(e) adds that advertising benefits for consumers that are irrelevant and do not result from any feature of the product is misleading.
Durability, repair and the harmonised label
The directive is not only about climate claims. It also targets early obsolescence and gives consumers new information on durability and repair, through amendments to the Consumer Rights Directive and blacklist points 23d to 23j.
Traders must give pre-contractual information on any commercial guarantee of durability longer than two years, on a reparability score where one has been set at EU level, on the availability, cost and ordering of spare parts, and on the period of software updates for goods with digital elements. The Commission adopted an implementing regulation on 25 September 2025 creating a harmonised legal notice on the two-year legal guarantee and a harmonised label for commercial durability guarantees, and the Commission's sustainable consumption page confirms that both become mandatory from 27 September 2026. For distance sales, the label must be shown clearly and prominently directly before the consumer places the order.
These rules sit alongside the product-design side of EU circular economy law and will bite on companies that have made public circularity commitments. False claims about repairability or durability can also feed into product liability exposure where goods fail early.
The transposition gap: 20 member states behind schedule
The Empowering Consumers Directive will apply on 27 September in principle everywhere, but the national laws that implement it were not all in place by the March deadline. On 28 May 2026 the Commission sent letters of formal notice to Belgium, Bulgaria, Czechia, Estonia, Greece, Spain, France, Croatia, Cyprus, Latvia, Luxembourg, Hungary, Malta, the Netherlands, Austria, Poland, Portugal, Slovenia, Finland and Sweden for failing to communicate complete transposition. Those states had two months to respond, after which the Commission may issue a reasoned opinion.
Some of those states have since legislated. Luxembourg, for example, adopted a law on 9 June 2026 amending its Consumer Code to implement the directive with effect from 27 September 2026, according to Arendt. Latham & Watkins reported that as of 24 August 2026 some member states had still not completed transposition. The seven member states not named in the May decision were Denmark, Germany, Ireland, Italy, Lithuania, Romania and Slovakia.
For a multinational, the practical consequence is uneven exposure. Where national law is in force, authorities and private claimants can rely on it directly. Where it is not, businesses face legal uncertainty rather than freedom: existing national law implementing the UCPD already prohibits misleading environmental claims, and national courts are required to interpret national law as far as possible in line with a directive once its deadline has passed. Local counsel in key markets, such as Germany, France and the Netherlands, can confirm the status of the national text and any gold-plating. Regulatory and public law advisers track the infringement procedure itself.
Old stock: what the CPC network's June 2026 understanding allows
The directive contains no grandfathering clause for products already made, so packaging printed before 27 September with a now-banned claim is, in principle, caught once it is offered to consumers. The CPC network has responded with a pragmatic but non-binding framework, published in June 2026, which national authorities are expected to consider when exercising their enforcement powers.
The common understanding sets out six principles. Traders must move towards compliance without delay and in good faith; old stock does not exempt anyone. Authorities may phase enforcement where old stock creates genuine and specific transitional difficulties, and may prioritise claims already addressed by earlier enforcement or guidance, online claims, the most harmful practices, non-packaging claims and marketing materials, and products with a short shelf life or fast stock rotation. They may take into account practical constraints such as packaging cycles, stock volumes, prior orders, supply-chain dependencies, long shelf lives and the feasibility of corrective measures.
Authorities expect reasonable and proportionate efforts, which may include removing or correcting online claims, updating advertising, adapting future packaging and new orders, using stickers or removing labels where feasible, displaying corrective information at the point of sale, coordinating with suppliers, and keeping records of the steps taken and when. They may refrain from requiring destruction or recall of products, and in justified cases may take a compliance-oriented approach before a sanction-oriented one, especially in the early stages.
Two lessons follow. Online claims will get little leniency, because the network says they do not face the same challenges as offline claims. And the evidence file matters: a business that can show a dated audit, a correction plan and supplier instructions is far better placed than one that did nothing and hopes for a grace period.
Penalties and private enforcement
Breaches of the Empowering Consumers Directive are penalised under the UCPD's existing sanctions regime, which was toughened by the Modernisation Directive, Directive (EU) 2019/2161. For widespread infringements subject to coordinated action under the CPC Regulation, member states must provide for fines with a maximum of at least 4% of the trader's annual turnover in the member state or member states concerned, or at least €2 million where turnover information is not available. Latham & Watkins notes that several member states have set higher ceilings.
The same directive added Article 11a to the UCPD, which gives consumers harmed by unfair commercial practices access to proportionate and effective remedies, including compensation and, where relevant, a price reduction or termination of the contract. That opens the door to individual and collective claims. The experience of mass emissions litigation in England and of US consumer class actions over product marketing, such as the CeraVe baby-product claim against L'Oréal, shows how marketing claims can become the foundation for group litigation.
Enforcement models differ. Latham & Watkins describes Germany and Austria as operating substantially private enforcement schemes, in which competitors and qualified associations bring injunction claims, as Deutsche Umwelthilfe did against Apple. In other states, consumer or competition authorities lead, as Italy's AGCM did against Shein. Businesses facing claims across several markets will want disputes counsel who can coordinate a consistent defence.
What happened to the Green Claims Directive?
The Green Claims Directive, the second half of the EU's original anti-greenwashing package, has not been adopted and its future remains unclear. It would have required explicit environmental claims to be substantiated by lifecycle-based evidence and verified by an accredited body before publication.
On 20 June 2025 the Commission announced its intention to withdraw the proposal, days before a trilogue scheduled for 23 June, which was then cancelled. Latham & Watkins observed at the time that the formal status remained unclear. The file has not advanced since.
The consequence is that the Empowering Consumers Directive is now the operative EU framework on green claims. There is no pre-approval system: traders decide for themselves whether a claim is specific, accurate and substantiated, and bear the risk if an authority, competitor or consumer group disagrees.
How the directive fits with CSRD and CSDDD after the Omnibus
The Empowering Consumers Directive has been untouched by the Omnibus simplification, and it now reaches far more companies than the EU's sustainability reporting and due diligence laws do. That asymmetry is the most important strategic point for ESG teams in 2026.
The Omnibus I directive, Directive (EU) 2026/470, was published in the Official Journal on 26 February 2026 and entered into force on 18 March 2026. According to Latham & Watkins' summary, it narrows the CSRD to EU undertakings and groups with more than 1,000 employees and net turnover above €450 million, and to non-EU groups with more than €450 million of EU turnover and an EU subsidiary or branch above €200 million. The CSDDD now applies to EU companies with more than 5,000 employees and net worldwide turnover above €1.5 billion, and to non-EU companies with more than €1.5 billion of EU turnover, with compliance required from 26 July 2029, penalties capped at 3% of net worldwide turnover and the EU-level civil liability regime removed. Member states must transpose the CSRD changes by 19 March 2027 and the CSDDD changes by 26 July 2028. On the reporting standards, the Commission adopted revised ESRS on 3 July 2026, mandatory for financial years from 1 January 2027, Linklaters reported.
| Instrument | Who is covered | What it requires | Key date |
|---|---|---|---|
| Empowering Consumers Directive (2024/825) | Every trader making B2C claims to EU consumers, any size, anywhere | No generic claims, offset-based neutrality claims or uncertified labels; verified plans for future claims | Applies 27 September 2026 |
| CSRD after Omnibus I (2026/470) | More than 1,000 employees and over €450m turnover; non-EU groups over €450m EU turnover | Sustainability statement under revised ESRS | Transposition by 19 March 2027 |
| CSDDD after Omnibus I (2026/470) | More than 5,000 employees and over €1.5bn turnover; non-EU over €1.5bn EU turnover | Risk-based human rights and environmental due diligence | Compliance from 26 July 2029 |
| UK DMCC Act 2024 consumer regime | Traders dealing with UK consumers | No misleading claims under general and banned-practice rules | CMA direct fining since 6 April 2025 |
Two practical links follow. First, many mid-sized companies that fell out of the CSRD will no longer produce audited sustainability data, yet their marketing claims are still judged against the directive's substantiation standards, so they need an evidence base of their own. Second, supply-chain claims such as "responsibly sourced" or "deforestation free" require information from suppliers that the CSDDD would have compelled large buyers to gather. The CMA's January 2026 guidance, Making green claims: getting it right across the supply chain, makes the equivalent point for the UK: retailers, brands and manufacturers share responsibility for claims they pass along. Investment in supply-chain traceability technology is increasingly a marketing-compliance tool as well as a due diligence one.
The UK position after Brexit
The directive does not apply in the UK, but UK businesses selling to EU consumers must comply with it, and at home they face a regulator with new teeth. Since 6 April 2025 the CMA has been able to decide for itself that consumer law has been broken and to impose fines of up to 10% of global turnover, under the Digital Markets, Competition and Consumers Act 2024, as it announced in its 7 April 2025 statement. Breaching undertakings given to the CMA can cost up to 5% of global turnover.
| Issue | EU from 27 September 2026 | UK today |
|---|---|---|
| Generic claims | Blacklisted unless recognised excellent environmental performance is shown | Assessed case by case under the Green Claims Code and the general ban on misleading practices |
| Offset-based carbon neutral claims | Blacklisted for product impact claims | No outright statutory ban; must not mislead |
| Own-brand sustainability labels | Blacklisted unless certified or public | Must not mislead; CMA undertakings precedent on accreditation statements |
| Maximum fine | Set nationally, at least 4% of turnover in the states concerned (or €2m) for widespread infringements | Up to 10% of global turnover, imposed directly by the CMA |
| Enforcer | National authorities, courts and, in some states, competitors and associations | CMA, Trading Standards, ASA |
The practical answer for most groups is a single claims standard built to the stricter EU blacklist, applied to both markets. Groups can find advisers on the United Kingdom side of the regime through the Corporate INTL directory.
A pre-27 September checklist and when to take advice
With two weeks to go, the Empowering Consumers Directive checklist is short but demanding. Legal, marketing and sustainability teams should work through it together, because the claims that create risk are usually written outside the legal function.
- Inventory every environmental and social claim across packaging, websites, marketplaces, apps, social media, in-store material and product names, in every EU market.
- Remove or specify generic claims, unless the product holds the EU Ecolabel or another qualifying recognised label.
- Withdraw offset-based product neutrality claims and, if the business wishes, replace them with transparent statements about climate contributions.
- Audit labels and badges, keeping only those based on a certification scheme or set by public authorities.
- Test net zero and target claims against the implementation-plan and independent-expert requirements, or take them out of consumer-facing material.
- Fix online claims first, then plan packaging changes, and document each step in line with the CPC old-stock principles.
- Update durability and repair information and display the harmonised notice and label where required.
- Check national transposition in each market and brief local counsel on any stricter national rules.
Boards also need to be briefed: research has long pointed to gaps in boards' sustainability knowledge, and greenwashing liability is now a board-level risk. Where the claims inventory is large, the product range is sold in many member states or an enforcement letter has already arrived, it is time to bring in specialist help. The Corporate INTL directory lists energy, environment and resources advisers with experience of green claims across the EU, and the directive's arrival on 27 September is the moment when what is the Empowering Consumers Directive stops being a research question and becomes a compliance deadline.
Frequently asked questions
What is the Empowering Consumers Directive?
It is Directive (EU) 2024/825, which amends the Unfair Commercial Practices Directive and the Consumer Rights Directive to combat greenwashing and early obsolescence. It bans generic environmental claims, offset-based neutrality claims and uncertified sustainability labels outright, and adds durability and repair information duties. It applies from 27 September 2026.
When does the EmpCo directive apply?
Member states had to transpose it by 27 March 2026, and the new rules apply from 27 September 2026. On 28 May 2026 the Commission opened infringement procedures against 20 member states that had not notified complete transposition, so the national implementing laws are not yet uniform across the EU.
Does the directive apply to companies outside the EU?
Yes. It applies to any trader making environmental claims or using sustainability labels towards consumers in the EU, wherever the trader is based. A UK, US or Asian brand selling to EU consumers online or through retailers and marketplaces must comply for those sales.
Can companies still say a product is carbon neutral?
Not where the claim is based on offsetting. From 27 September 2026, claiming that a product has a neutral, reduced or positive greenhouse gas impact because of offsets is a blacklisted practice. Companies may still describe their investment in carbon credit projects, provided the information is transparent and not misleading.
Are words like "eco-friendly" and "sustainable" banned?
Used on their own, largely yes. A generic environmental claim is blacklisted unless the trader can show recognised excellent environmental performance, such as the EU Ecolabel. A specific, accurate and substantiated claim on the same medium, for example the percentage of recycled content, remains lawful.
What is the current status of the Green Claims Directive?
The proposal has not been adopted. The Commission announced its intention to withdraw it on 20 June 2025, and a planned trilogue on 23 June 2025 was cancelled. The file has not advanced, so the Empowering Consumers Directive is the operative EU framework on green claims.
What are the penalties for breaching the directive?
Penalties are set nationally under the UCPD. For widespread infringements subject to coordinated EU action, maximum fines must be at least 4% of annual turnover in the member states concerned, or at least €2 million if turnover data is unavailable. Consumers can also seek compensation, price reductions or contract termination.
What happens to products already on shelves on 27 September?
There is no formal grace period. The CPC network's non-binding June 2026 common understanding lets authorities phase enforcement for genuine old-stock difficulties, accept stickers or point-of-sale corrections and avoid demanding destruction or recall. Online claims are expected to be corrected promptly, and traders should keep records of their compliance steps.
How does the directive relate to the CSRD after the Omnibus?
They are separate. Omnibus I narrowed the CSRD to groups with more than 1,000 employees and over €450 million turnover, but the Empowering Consumers Directive applies to every trader making consumer-facing claims. Companies outside the CSRD still need their own evidence to substantiate any environmental claim.
Sources
- EUR-Lex: Directive (EU) 2024/825 on empowering consumers for the green transition
- EUR-Lex: Directive (EU) 2019/2161 (Modernisation Directive)
- European Commission: Infringement decisions, 28 May 2026 (INF/26/1097)
- CPC Network: Common understanding on old stock situations under Directive (EU) 2024/825 (June 2026)
- European Commission: Sustainable consumption
- Arendt: Law of 9 June 2026 implementing Directive (EU) 2024/825 and updated Commission Q&As (15 June 2026)
- Latham & Watkins: EU Empowering Consumers Directive new rules on green claims apply from 27 September 2026 (9 September 2026)
- TLT: The EU Empowering Consumers for the Green Transition Directive (20 August 2026)
- Latham & Watkins: European Commission announces intention to withdraw Green Claims Directive proposal (June 2025)
- EUR-Lex: Directive (EU) 2026/470 (Omnibus I)
- Latham & Watkins: EU Sustainability Omnibus published in the Official Journal (February 2026)
- Linklaters: Commission adopts revised ESRS and voluntary reporting standard (July 2026)
- CMA: New consumer protection regime comes into force (7 April 2025)
- CMA: Making green claims, getting it right across the supply chain (22 January 2026)
- CMA: Green claims, CMA secures landmark changes from ASOS, Boohoo and Asda (27 March 2024)
- Insurance Journal: Apple Watch not a "CO2-neutral product", German court finds (27 August 2025)
- Sustainability Online: Italy's Competition Authority fines Shein €1 million for greenwashing (August 2025)
About this article
This analysis was researched and written by The Corporate INTL Newsroom, which covers cross-border legal, regulatory and business developments for lawyers, professional advisers and financiers in over 150 jurisdictions. It has been checked against the text of Directive (EU) 2024/825, the Commission's infringement decision of 28 May 2026, the CPC network's June 2026 common understanding, UK regulator publications and primary reporting. National implementing laws vary and several were still being finalised at the time of writing. This article is general information, not legal advice; for advice on a specific matter, consult a qualified adviser. Last reviewed 12 September 2026. For more analysis like this, visit the Corporate INTL newsroom or subscribe to Corporate INTL.
