Rules on green claims will tighten on 27 September 2026 – what do companies need to know?

“Environmentally friendly”, “carbon neutral” and “responsible” have become established terms in marketing. Environmental claims have not been allowed to be misleading before either, but from 27 September 2026 the rules will become more specific and certain practices will be prohibited in all circumstances. The new rules on green claims mean that companies should review their consumer-facing environmental claims, sustainability labels, climate targets and product information.

What rules are changing?

The reform is based on Directive (EU) 2024/825, which amends the EU directives on unfair commercial practices and consumer rights. In Finland, the Directive has been implemented through an amendment to the Consumer Protection Act and a new Government Decree. The reform applies to consumer-facing marketing and practices in customer relationships, regardless of the size of the company. The rules may apply to websites, advertising, commercial content on social media, packaging, product information in online stores and other sustainability communications aimed at consumers.

The Directive should not be confused with the separate Green Claims Directive proposal. Its legislative process is currently stalled, and the proposal has neither been adopted nor formally withdrawn.

When will the new rules apply?

The new provisions will apply from 27 September 2026. A limited transitional rule applies to marketing included on goods, or on their packaging, that were placed on the market before that date. Certain prohibitions concerning sustainability labels, generic environmental claims and the scope of environmental claims will only apply to such marketing from 27 March 2027. This is not a general extension for all green claims. The transitional rule does not apply, for example, to online advertising, new packaging or other practices prohibited under the new rules.

What kinds of environmental claims can be used?

Generic expressions such as “environmentally friendly”, “green”, “ecological” and “climate friendly” will generally be prohibited unless the company can demonstrate recognised excellent environmental performance that is relevant to the claim. Such performance may be based, for example, on the EU Ecolabel or an officially recognised Type I ecolabel compliant with EN ISO 14024.

A generic claim can be made more specific by clearly explaining, in the same communication, which characteristic or part of the product the claim relates to. Even a specific claim must be truthful, up to date and verifiable. A company must not market an entire product or business as environmentally better if the claimed benefit relates only to the packaging or to one particular function.

The assessment of the term “responsible” depends on the overall impression created by the communication, as the term may refer not only to environmental impacts but also to social characteristics. If it creates the impression of a positive environmental impact, the rules on environmental claims may apply.

What about carbon neutrality and offsetting?

A product or service must not be marketed as having a neutral, reduced or positive environmental impact if the claim is based on greenhouse gas emissions offsetting. For example, offsetting-based claims such as “carbon-neutral product”, “carbon-neutral delivery” and “climate compensated” will be prohibited.

A company may still communicate genuine emissions reductions and the financing of climate projects, provided that the information is presented accurately and without misleading consumers. Offsetting must not, however, be presented as an environmental characteristic of the product itself or as a way of cancelling out the emissions caused by the product.

What is required for sustainability labels and climate targets?

A sustainability label may only be used if it is based on a qualifying third-party certification scheme or has been established by a public authority. The scheme’s conditions must be publicly available, transparent and non-discriminatory, and compliance with the requirements must be independently monitored. A company’s own assessment or internal scoring system is not, on its own, sufficient to support a “Green Choice”-type label.

A future-looking environmental claim, such as “we will be carbon neutral by 2030”, requires public and verifiable commitments as well as a detailed and realistic implementation plan.

The plan must include a measurable timeline, an assessment of the resources needed and regular monitoring by an independent expert. The expert’s findings must also be made available to consumers.

What else does the reform cover?

The new prohibitions also concern product durability, software updates and repairability. For example, it is prohibited to market goods if the company has information about a feature that limits their durability, or to claim that goods are repairable when they cannot be repaired. A software update that merely enhances functionality must not be presented as necessary.

Before a contract is concluded, consumers must be provided with new information, including information about the statutory liability for defects. Where the conditions laid down by law are met, information must also be provided about a producer’s free-of-charge durability guarantee lasting more than two years, the minimum period for software updates, the repairability score, and the availability of spare parts and repair instructions.

What can happen if the rules are breached?

Compliance with the rules is supervised by the Finnish Consumer Ombudsman.

Non-compliant practices may be prohibited, and the prohibition may be reinforced with a conditional fine. A penalty payment may also be imposed for breaches of the rules. In certain situations, the Market Court may require a company to correct its marketing.

A consumer may also be entitled to a reasonable price reduction if an unfair commercial practice can be assumed to have influenced the purchasing decision. An intentional or negligent breach may also result in liability for damages.

What should companies do now?

Before 27 September 2026, companies should:

• review environmental claims used on websites, in campaigns, on social media and on packaging;

• specify which product, characteristic or stage of the product life cycle each claim relates to;

• compile up-to-date evidence supporting the claims and document the calculation methods used;

• review offsetting claims, proprietary sustainability labels and future environmental targets;

• ensure that product information flows properly from manufacturers to sellers and online stores; and

• assign clear responsibility for approving and monitoring environmental claims.

The reform does not mean the end of sustainability communications. However, broad promises will increasingly need to be replaced with specific, understandable and verifiable information.

Folks helps companies identify risks related to environmental claims and packaging labels and build practical processes for marketing that complies with the new rules.

Anna Paimela

Partner

anna.paimela@legalfolks.fi  

+358 40 1648626

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