125 days until the claims on your webshop become a fine risk
125 days. That's when the EU Green Claims Directive becomes mandatorily enforceable in the Netherlands. Vague environmental claims on your webshop, ads or packaging will be fined by the Authority for Consumers and Markets (ACM) from 27 September 2026. The ACM can fine up to 900,000 euros per breach, or a percentage of your annual turnover if that is higher (for large-scale EU-wide breaches up to 4%).
The timing is no coincidence. Three days before this blog, Everlane was sold to Shein. A D2C brand that spent sixteen years building on the promise of being ethical and sustainable did not even survive four months before the EU made it legally impossible to run such a claim unproven. Anyone who lets their brand identity rest on a single unproven claim has no backup. Not in a market correction, not with a regulator.
Important to be clear about: the binding law is the Empowering Consumers Directive (EmpCo, EU 2024/825), which becomes applicable on 27 September 2026. There was also a separate legislative proposal named the Green Claims Directive, but the European Commission withdrew it in 2025. "Green Claims Directive" lives on mainly as a popular term for the approach to environmental claims; the rules in this blog come from EmpCo and the existing ban on unfair commercial practices that the ACM already enforces.
This blog works through six claim types that, from 27 September, can no longer be used freely on your webshop, your packaging or your product page. Per claim: what gets banned, why, what is still allowed and a concrete alternative. After that, an audit checklist to be in order before 27 September. For the packaging layer of that same 2026 stack, see also our PPWR checklist for 12 August and the PPWR breakdown per packaging type.
1. "Climate neutral" without a Life Cycle Assessment
The word climate neutral is on the EmpCo blacklist. What gets banned: positioning a product, service or entire brand as climate neutral without an independently verified Life Cycle Assessment (LCA) that backs up the claim, and without transparent substantiation of the remaining emissions.
Why this gets tough: until now, "climate neutral" has in most cases been based on carbon offsetting, not on actual emission reduction. The European Commission has consistently branded that practice as greenwashing. The directive now requires three conditions: an independently verified LCA, a reduction following a scientific pathway, and transparent substantiation of location and method for any compensation.
What is still allowed: dated, specific claims about actual reduction. "Our CO2 emissions per unit have dropped 42% since 2022" is allowed, provided it is substantiated. The claim should not be absolute, but relative and dated.
Concrete alternative on your product page: turn "climate neutral product" into "CO2 per unit: 42% reduced since 2024 (validated by [name of LCA firm])". Shorter, sharper, legally unassailable.
2. "Eco", "sustainable", "green" as vague terms
The three vaguest environmental adjectives are the most used in Dutch e-commerce and the most vulnerable under EmpCo. What gets banned: using "eco", "sustainable", "green", "environmentally friendly", "nature friendly" or "climate friendly" without concrete substantiation of what the claim refers to.
Why: these terms have no legal definition and are therefore unprovable by definition. A product is not "sustainable"; a specific aspect of it is measurably more sustainable than a comparable reference point. The directive obliges you to point to that reference point. For the broader context of why this has such high impact on your brand identity, see E-commerce brand identity: the 10-20% revenue you miss.
What is still allowed: claims that make the property concrete and compare it. "Made from 80% recycled plastic" is allowed. "Our packaging is 40% lighter than our 2023 version" is allowed. "FSC-certified cardboard" is allowed.
Concrete alternative: replace "100% green production" with "produced in a solar-powered factory since 2024". Verifiable, not vague.
3. Future promises without a reduction plan
"CO2 neutral by 2030." That slogan sits on dozens of Dutch webshops and will be fined from 27 September. What gets banned: future environmental claims without a verified reduction plan, interim measurable targets and publicly accessible progress reporting.
Why: a claim about a future state is sales-promoting and consumers buy on the image. Without a plan underneath it, it's advertising without backing. The ACM calls this an aspirational claim without substantiation, and the directive makes it fineable.
What is still allowed: future claims that meet three conditions. A detailed reduction plan with annual milestones up to the end target. Independent verification of the plan and the interim figures. Public reporting of progress, for example on a dashboard.
Concrete alternative: replace "CO2 neutral by 2030" with "Target: 70% CO2 reduction by 2030 versus 2022, validated by SBTi, with an annual update at /duurzaamheid". Longer, that's true. But sustainable.
4. Carbon offsetting outside your own value chain
Here EmpCo gets specific. What gets banned: basing a neutrality claim on carbon offsetting (tree projects, clean-water projects, reforestation) that takes place outside your own value chain.
Why: the European Commission has explicitly determined that offsetting outside your own chain cannot be substantiation for a neutrality claim. The reason is that it does not reduce your actual emissions and shifts the problem to projects you do not control.
What is still allowed: investments in offsetting remain legal and even worth encouraging. They just can no longer serve as the basis for a neutrality claim. You can say "we invest in reforestation in northern Spain" as long as it is not tied to a neutrality claim.
Concrete alternative: separate the two stories. Tell your reduction story apart from your offsetting story. Do not connect them in the same claim.
5. Brand names with a green connotation as an implicit claim
Here comes the hard one for brand policy. What gets banned: a brand name, sub-brand or product-line name with an explicit green connotation that has no substantiation underneath it. Examples of risky names: "EcoLine", "GreenSeries", "PureGarden", "EarthFriendly".
Why: the directive treats a name as an implicit claim. The ACM has already indicated that a seller running "GreenSeries" as a product line must place substantiation on the packaging of what is green about it, or change the name.
What is still allowed: a brand name with green aesthetics (green letters, a leaf logo) without an explicit green claim in the name itself. Or a name with a claim, provided the packaging carries substantiation or links via QR code.
Two options for "EcoBox 50". Option one: choose a neutral name such as "Box 50". Option two: keep the name and place a QR code on the packaging that leads directly to the substantiation. Tight packaging space is no excuse; a QR code to a substantiation page on your website is sufficient. A renaming process often runs in parallel with a broader branding project to sharpen the positioning around the name at the same time.
6. "100% recyclable" without dependence on the chain
The sixth claim that, from 27 September, can no longer stand without conditions: "100% recyclable". What gets banned: a recyclability claim without stating where and how the packaging is actually recycled in practice.
Why: a product is theoretically recyclable, but in practice it is often incinerated because the Dutch recycling infrastructure does not process the type of material. The directive requires that a claim hold in execution too, not only in theory.
What is still allowed: a claim that is specific about the chain. "Recyclable via the PMD stream", "Recyclable in 8 out of 10 municipalities", "Compostable according to NEN-EN 13432", "Aluminium: 75% is recycled in the Netherlands (NedVang 2024)".
Concrete alternative: replace "100% recyclable" with "Recyclable via PMD; check your municipality". Honest, specific and legally without a shadow.
What to do before 27 September: the Green Claims audit
Here comes the work. A Green Claims audit does four things, in this order:
- Inventory all claims: hero text, product pages, ads, packaging, email templates, social bios and terms and conditions
- Categorise per claim: provable / unprovable / reformable
- Write an alternative wording for every unprovable claim that is specific and dated
- Plan the packaging adjustment for unproven brand names or QR-code addition for existing packaging
The order matters. Starting with packaging is logical, because a new print run takes eight to twelve weeks. After that the homepage and product pages, which are quick to adjust. Ads come last because they run continuously and are simple to update. Anyone who starts now is ready before 27 September. Anyone who waits until July risks a packaging run that is no longer allowed in September.
Brand identity is broader than the claim alone
A Green Claims audit without a broader brand picture is treating the symptom. A brand that gets its claims legally clean, but then has no sharp positioning, falls back on generic marketing. Six years of e-commerce branding at Oase Creative show that brands which revise their claims usually have to sharpen their positioning again as well; the two exercises overlap.
Since 14 May 2026, the first paying client is running through the brand audit pipeline at Oase Creative. For other brands that want to be ready before 27 September: the audit comes in standard fields with the claim inventory, the rewording proposal and a packaging action list that your printer can execute. Reachable via contact.
What EmpCo teaches the market is this. Brands that leaned on a single unproven claim have no backup when that claim falls. Everlane is not alone. The directive forces the market back toward substantiation. For brands that were already doing it right, that's no problem. For the rest it's a reminder: 125 days until the fine threshold moves.
