Can I advertise my product as green? Claims that stand up
The word green on its own will no longer be allowed. From 27 September 2026 a generic environmental claim without demonstrable recognised excellent environmental performance is prohibited. The same goes for eco, environmentally friendly, climate friendly and sustainable. What is allowed is a specific claim about a concrete benefit that you can prove. This article shows, claim type by claim type, how to word it.
The short answer
Replace every generic term with a concrete, measurable and verifiable fact. Do not say what your product is; say what has been done to it. Name the component the claim concerns, the unit, the percentage and the basis of comparison. Make sure the evidence is ready before the statement goes out.
This article is practical in nature. For the legal framework we refer you to our overview of greenwashing and environmental claims.
The four questions to answer for each claim
- What does the claim cover? The whole product, one component, the packaging or the company. A benefit concerning a single aspect may not be attributed to the whole product.
- What are you comparing against? An earlier model, a competitor, a sector average or a statutory standard. Without a basis of comparison an improvement means nothing.
- What evidence do you hold? A measurement, a calculation, a certificate or a study. With a reference date and a source.
- Is the benefit relevant? Emphasising a benefit that does not matter to the consumer counts as misleading.
Claim type 1: use of materials
This is the simplest claim type, provided you are precise. Always name the object and the percentage.
| Avoid | Use instead |
|---|---|
| “Made from recycled material” | “The box consists of 100% recycled cardboard” |
| “Organic cotton T-shirt” where the cotton is 60% organic | “Contains 60% organic cotton” |
| “Sustainable wood” | “The wood comes from a certified managed forest, certificate number on the packaging” |
Substantiation: purchasing specifications, bills of materials or parts lists, supplier declarations and certificates. For food, the term organic requires certification.
Claim type 2: carbon and climate
This is where most changes. Claims that a product has a neutral, reduced or positive environmental effect on the basis of offsetting greenhouse gas emissions are on the blacklist. In other words: climate neutral, carbon neutral or climate positive is no longer permitted where offsetting carries the claim.
You may state as a matter of fact that you offset. Keep that strictly separate from any statement about the product.
| Avoid | Use instead |
|---|---|
| “Climate neutral product” | “We offset the emissions of this product through project X. The emissions themselves amount to Y kg CO2 equivalent per unit.” |
| “Carbon neutral delivery” | “Delivered by electric vehicles in the city centre of A to B” |
| “Less CO2” | “18% lower CO2 emissions per kilo than our 2024 model, measured under method Z” |
Substantiation: a footprint calculation with a named method and system boundary, the emission factors used, and the reference date. If you mention offsetting, name the project, the standard and the share that is offset.
Claim type 3: labels and logos
Displaying a sustainability label that is not based on a certification scheme and was not established by a public authority is on the blacklist. A self-designed logo with a leaf in it is therefore risky.
A certification scheme must meet cumulative requirements. It is open under transparent and fair conditions. Its requirements are drawn up by experts. There is a complaints and enforcement mechanism. And an independent third party monitors compliance.
| Avoid | Use instead |
|---|---|
| An in-house “Green Choice” seal on the packaging | A label from an independent certifier, with an explanation of what it means |
| Green colours, leaves and earth icons without an underlying benefit | Imagery matching the stated, substantiated benefit |
| A logo resembling a well-known label | An in-house scheme that you also identify as your own scheme |
Note: imagery without text can amount to a claim too. What counts is the overall impression of the statement.
Substantiation: the certificate, its scope, its period of validity and the audit reports. For an in-house scheme: the rules of the scheme and evidence of independent monitoring.
Claim type 4: promises about the future
You may not present a future target as a result already achieved. That is the heart of it. Communicating ambitions is allowed, but only in concrete and measurable terms.
| Avoid | Use instead |
|---|---|
| “On the way to a green future” | “Target: 90% of our electricity from our own solar installations in 2030. Position at 1 January 2026: 41%.” |
| “We are going climate neutral” | “We are cutting our scope 1 and 2 emissions by 30% against 2022. Achieved so far: 12%.” |
| “Fully circular soon” | “Since March 2026 we take back used products at all our branches” |
Substantiation: an adopted plan with interim targets, a budget and allocated responsibility, together with reported progress. Align the target with what you record in your ESG reporting. If you fall under the CSRD, your marketing must be consistent with your sustainability statement.
Claim type 5: packaging
A claim about the packaging may not be carried over to the product. The reverse applies as well. Be precise, too, about what the consumer has to do.
| Avoid | Use instead |
|---|---|
| “Sustainable packaging” | “This packaging weighs 22% less than our previous packaging” |
| “Recyclable” without more | “The box goes with waste paper. The film goes with residual waste.” |
| “Plastic free” where the seal contains plastic | “The box and the filling material are plastic free. The seal is not.” |
One further trap: presenting a legally required feature as a distinguishing characteristic of your offer is also on the blacklist. So do not advertise compliance with a standard that applies to everyone.
What substantiation you must be able to produce
The burden of proving the accuracy and completeness of your claim rests on you. Build a file for each claim containing:
- the exact wording and imagery of the statement, with the date of publication;
- the underlying fact, with source, method and unit;
- the basis of comparison, if you compare;
- the period of validity, with an agreed date for re-testing the claim;
- the name of the person who approved the claim.
Work with a fixed review before publication. Have marketing, purchasing and legal use the same checklist. That prevents a claim born in a presentation from ending up untested on the packaging.
Existing stock and printed material
The rules apply from 27 September 2026. There is no statutory transitional period. The ACM has explained that transitional situations may be taken into account in enforcement. That calls for demonstrable old stock and demonstrable efforts to comply quickly. So record those efforts: stock lists, orders for new printed material and a phase-out schedule.
Frequently asked questions
May I still use the word sustainable?
Only if you state immediately and visibly what the sustainability consists of, on the same medium. If the term stands alone, it is a generic environmental claim. That is prohibited without demonstrable recognised excellent environmental performance.
May I still work with my own label?
Only if it is based on a certification scheme meeting the statutory requirements, with independent monitoring. An internal label without external verification may not be displayed as a sustainability label.
How specific does a percentage have to be?
Specific enough for the consumer to know what it refers to. Name the component, the unit and the basis of comparison. A percentage without a reference point cannot be checked and is therefore vulnerable.
Would you like your packaging, webshop and campaigns reviewed before the rules take effect? We assess your claims and draw up a substantiation file. Law & More has offices in Eindhoven and Amsterdam and advises in Dutch and English. Please feel free to contact an environmental law attorney at Law & More.
