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The EU Anti-Greenwashing Rules are Coming

RE-NUT AG

May 1, 2026

From September 27, 2026, the EU's Empowering Consumers for the Green Transition Directive becomes enforceable across all Member States, making generic environmental claims on food products legally risky. Here is what is changing, what food brands must do, and why RE-NUT® is already on the right side of this shift.

If your product packaging says "sustainable," "eco-friendly," "green," "planet-friendly," or "climate neutral" and you cannot back that claim with specific, verifiable, independently assessed evidence, you have approximately five months to fix it. That is the current state of EU consumer protection law. The Empowering Consumers for the Green Transition Directive, known by its acronym ECGT, and formally Directive (EU) 2024/825, was adopted by the European Parliament in March 2024 and must be transposed into national law by Member States by March 27, 2026. It enters into application six months later, on September 27, 2026. From that date, enforcement agencies across the EU will have a clear, harmonised legal basis to act against vague or unsubstantiated environmental claims in consumer-facing communications. The food industry, which has been one of the heaviest users of green marketing language for the past decade, is squarely in the crosshairs.

What the Directive Actually Does

The ECGT amends the EU's Unfair Commercial Practices Directive (the foundational law governing misleading commercial behaviour toward consumers) and introduces a specific new category of prohibited practices around environmental and sustainability claims.

The key changes are direct and consequential:

Generic environmental claims are banned. Terms like "eco-friendly," "green," "natural," "sustainable," or "environmentally responsible" applied to a product without specific, substantiated context are prohibited. The directive blacklists these as inherently misleading because they create a positive environmental impression without any verifiable basis.

"Climate neutral" claims based on offsets are banned. A product cannot be described as "climate neutral," "carbon neutral," or "net zero" if that claim rests on the purchase of carbon credits or offsets rather than actual reductions in the product's emissions value chain. This closes off one of the most widely used greenwashing routes in the food and beverage sector.

Unverified sustainability labels are restricted. Sustainability labels must be based on independent, transparent, and credible certification systems. Self-declared ecolabels, logos or icons designed to look like third-party certifications but issued by the brand itself, are prohibited.

Forward-looking sustainability claims require a plan. Claims like "climate neutral by 2030" or "net zero by 2050" require a detailed, publicly available, independently verified implementation plan with measurable and time-bound targets. Vague future commitments without a documented roadmap are prohibited.

Crucially, enforcement is not waiting for September 2026. National authorities in several EU countries, notably the Netherlands' Authority for Consumers and Markets and Germany's Deutsche Umwelthilfe, are already pursuing greenwashing cases under existing consumer protection law. German courts have already found that vague climate claims must be clarified on the same medium to avoid misleading consumers. The Directive provides a harmonised framework; the enforcement is already here.

"Whether or not this directive goes through, you can't mislead consumers. That obligation already exists, and it's being enforced."

— Jellien Roelofs, greenwashing legal expert, Lasting Legal (Netherlands), speaking to Fi Global Insights

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What This Means for Food Brands Specifically

The food and beverage sector has been particularly prolific in its use of green marketing language. A 2020 EU study found that over half of environmental claims made by businesses were vague, misleading, or unverified. A high-profile 2024 case found that 247 out of 450 products of one of the biggest food companies in the world carried sustainability claims that were considered misleading, including generic phrases like "sustainably grown cocoa" and "sustainable packaging," as well as in-house logos designed to resemble third-party ecolabels. For food brands, the practical implications of the ECGT fall into several immediate areas:

Common food marketing claims and their status from September 2026:

Common claim	Status from Sep 2026	What's required instead
"Sustainable" / "eco-friendly" / "green"	🚫 Banned (generic)	Specific, substantiated claim referencing a defined environmental metric (e.g. "60% less water than conventional almond processing")
"Climate neutral" / "carbon neutral"	🚫 Banned if offset-based	Must reflect actual emissions reductions in value chain, not purchased carbon credits
"Made with sustainable ingredients"	⚠️ High risk	Requires defining which ingredient, which sustainability metric, and third-party verification
"Environmentally responsible production"	🚫 Banned (generic)	Specific production practice must be named and evidenced
Own-brand ecolabel / green leaf logo	🚫 Banned if unverified	Must be based on an independent, accredited certification scheme
"Net zero by 2040"	⚠️ Risky without a plan	Requires published, time-bound, independently verified implementation roadmap
"Upcycled" / "zero waste" (specific claim)	✅ Permissible if evidenced	Must be documented with specific process data showing measurable waste reduction
"Certified organic" (third-party certified)	✅ Permissible	Third-party verification already meets the standard

The Broader Context: Why This Is Happening Now

The ECGT does not exist in isolation. It is part of a broader EU regulatory shift, the European Green Deal legislative package, that is systematically increasing the substantiation burden on environmental claims across all sectors.

Alongside the ECGT, food and ingredient companies need to be aware of several parallel developments:

The Corporate Sustainability Reporting Directive (CSRD) requires large companies and listed SMEs to report on sustainability using European Sustainability Reporting Standards (ESRS), which include scope 3 (supply chain) emissions, resource use, and biodiversity impacts. The data generated by CSRD reporting is increasingly expected to underpin consumer-facing claims.

Spain's mandatory origin labelling for almonds (in force since January 2025) signals a wider EU trend toward ingredient-level provenance transparency, making "we know exactly where this came from and how it was made" an increasingly material claim, not just marketing.

The EU Deforestation Regulation (EUDR) requires companies placing certain commodities, including nuts, on the EU market to demonstrate their supply chains are deforestation-free. Supply chain documentation requirements are tightening across the board.

The cumulative effect is a regulatory environment in which "sustainable" is a legal claim, requiring the same rigour as a nutritional declaration or an allergen statement.

Where RE-NUT® Stands

RE-NUT® did not build its sustainability positioning is built around a process. The RE-NUT® in-shell processing technology is patented, documented, and produces measurable outcomes. Every sustainability claim we make, or that a licensee makes using RE-NUT® ingredients, is anchored in something specific and verifiable:

· Zero shell disposal: the entire nut (shell, skin, and kernel) is converted into food-grade ingredient fractions. No shell biomass is burned. No fraction is discarded.

· Documented process: the technology is described in European patents, validated by independent laboratories, and the resulting ingredients have been assessed for safety through GLP-compliant studies published in peer-reviewed scientific literature.

· No generic claims: RE-NUT® does not describe its products as "eco-friendly" or "sustainable" without qualification. Where environmental claims are made, they describe specific outcomes of a specific process.

· SDG alignment is outcome-based: RE-NUT® supports SDGs 2, 6, 12, and 15 (zero hunger, clean water, responsible consumption and production, and life on land).

For food companies licensing RE-NUT® technology or sourcing RE-NUT® ingredients, this matters. The documentation trail that ECGT compliance requires such as process data, third-party evidence, measurable outcomes, is already being built as part of the regulatory pathway for novel food authorisation. The EFSA dossier, the published genotoxicity study, the patent record are the evidence base for defensible sustainability claims.

The companies that will emerge from this regulatory shift strongest are the ones who built their claims on a documented process from the beginning.

What Food Brands Should Do Now

September 27, 2026 is five months away. For food and ingredient companies operating in the EU, the practical checklist is:

1. Audit all consumer-facing environmental claims: on packaging, websites, social media, and advertising. Flag any claim that uses generic language without a specific, evidenced basis.

2. Remove or substantiate: any claim that cannot be backed by documented process data, life-cycle assessment, or third-party verification. "Sustainable" without qualification is a legal liability.

3. Review carbon offset-based claims: "climate neutral," "carbon neutral," "net zero" product claims that rest on purchased offsets rather than actual emissions reductions must be reformulated or removed.

4. Check sustainability labels: any ecolabel or sustainability icon that is self-declared rather than issued by an independent, accredited third party must be removed.

5. Build documentation: for claims you want to keep, build an audit-ready evidence file linking the claim to specific process data, measurable outcomes, and third-party verification.

The transition from aspirational to evidenced sustainability claims is a market repositioning opportunity. The brands that emerge from this shift with the clearest, most defensible sustainability stories will be the ones that built those stories on substance from the beginning.

RE-NUT® was built that way. We think the market is finally catching up.

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