Applicable laws
EU Directive 2024/825
Who does this directive apply to? Any company, regardless of size, that markets products or services within the European Union and communicates publicly (website, packaging, advertising, social media, notice) an environmental claim regarding its products, brand or activity. Manufacturers, distributors, importers, marketplaces and service providers alike are all liable for the claims they broadcast.
What the directive precisely forbids. Vague and unprovable claims ('green', 'eco', 'environmentally friendly', 'good for the planet', 'carbon-neutral') without quantified and methodological evidence. In-house self-certifications without a recognized external framework. Sustainability labels not based on a certification system approved by a public body. Greenwashing by omission (highlighting a secondary attribute to hide a major impact).
Concrete obligations. Every claim must be: (1) precise and quantified, (2) based on recognized scientific or technical evidence, (3) accompanied by a transparent and accessible methodology, (4) updated at least annually, (5) auditable by an independent third party. An internal registry dating every claim, its proof, its validity and its owner must be available to authorities within 30 days.
Controls and sanctions. These are the DGCCRF in France, the European Commission for cross-border cases, and equivalent authorities in other Member States. Sanctions include: fines up to 4% of annual global turnover, product withdrawal, publication of the sanction decision, consumer class actions. Regulation (EU) 2023/988 strengthens traceability and imposes heavier sanctions for repeat offenders. Application in France: transposition expected mid-2026, but authorities already rely on the Consumer Code (articles L.121-2 et seq. on misleading commercial practices).
⚠️ What you actually risk
Fine up to 4% of annual turnover
For serious and repeated breach, the authority can impose up to 4% of the group's annual global turnover. On a €10M turnover: up to €400,000 in fines alone.