The update clarifies how environmental claims made through brand, product or company names should be assessed, applying an objective “average consumer” standard rather than a more subjective test used previously. From the date of application, retailers will also need to display a harmonised notice on legal guarantee rights at the point of sale. A separate Common Understanding, agreed by national Consumer Protection Cooperation authorities on 30 June 2026, addresses how the rules apply to existing (“old”) stock already on shelves before the application date.

With the Directive applying from 27 September 2026, retailers across the EU have a narrow window to review marketing claims, guarantee notices and existing inventory for compliance.

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