Greenwashing: new rules on environmental claims apply from 27 September 2026

From 27 September 2026, the new rules introduced by Directive (EU) 2024/825 on empowering consumers for the green transition become applicable. In Italy, the Directive has been transposed by Legislative Decree No. 30 of 20 February 2026.

The new framework primarily affects commercial practices directed at consumers: packaging, voluntary labels, advertising, websites, e-commerce, promotional materials and, more generally, all messages used to present a product or a company to the public.

The objective is to reduce the risk of greenwashing by making the use of environmental claims, sustainability labels and climate-related statements more stringent.

What changes in practice

The new provisions strengthen controls over expressions such as “green”, “eco-friendly”, “sustainable”, “environmentally friendly” and similar wording. These claims cannot be used in a generic manner unless there is an adequate basis supporting their use.

Particular attention must also be paid to implicit environmental messages. Not only wording, but also colours, images, symbols, leaves, graphic elements or product presentation may, depending on the overall context, lead consumers to perceive an environmental benefit.

The new rules also concern sustainability labels and marks, which must be based on compliant certification schemes or be established by public authorities.

Claims stating that a product has a neutral, reduced or positive climate impact are also prohibited where such claims are based merely on greenhouse gas offsetting.

Finally, claims concerning future environmental performance must be supported by concrete and verifiable commitments and by realistic implementation plans.

The new European Commission FAQs

In September 2026, the European Commission published an updated version of its Questions & Answers, providing useful clarification for businesses. The document confirms that the rules concern B2C commercial practices and not the intrinsic composition of products.     

The FAQs also clarify that an environmental claim may arise from the overall presentation of a product: colours, images, symbols and graphic elements may contribute to creating an implicit environmental message.     

Another key point concerns existing stock. The Commission confirms that from 27 September 2026 the new rules also apply to existing products / old stock, including products or packaging already manufactured, ordered, distributed or placed on retailers’ shelves before that date.     

This does not mean that every product must automatically be recalled or destroyed. The FAQs recognise practical compliance solutions such as corrective stickers, supplementary information at the point of sale and other proportionate measures.   

What the Italian MIMIT Circular says about existing stock

The Italian Ministry of Enterprises and Made in Italy also addressed the issue of existing stock in its Circular of 27 August 2026.

The Ministry refers to the principle of proportionality and indicates that factors such as stock volumes, packaging cycles, existing orders, supply-chain dependencies, shelf life and the technical feasibility of correcting packaging should be taken into account.

For durable goods manufactured or placed on the market before 27 September 2026, the Circular indicates that physical adaptation of packaging may take place within a reasonable shelf-life period for the relevant product category, identified by the Ministry on an indicative basis as six months, provided that manufacture or placing on the market before the application date can be documented.

However, this should not be interpreted as a general six-month sell-off period applicable to all products. From 27 September 2026, businesses are still expected to adopt reasonable and proportionate measures to bring consumer-facing communications into compliance.

What companies should do now

Companies should carry out a systematic review of:

packaging and artwork, environmental claims, sustainability marks and symbols, websites and e-commerce content, catalogues, advertising materials and social media communications.

Existing stock should be assessed on a case-by-case basis, and companies should retain evidence of the corrective measures taken.

The new framework therefore concerns not only what is claimed, but also how it is communicated and how the average consumer may reasonably interpret it.

Cosmetic Solutions supports companies in the regulatory review of claims, packaging and commercial communications, including the management of products and stock already present on the market