The European Union has introduced Directive (EU) 2024/825, formally amending Directives 2005/29/EC and 2011/83/EU, specifically aimed at empowering consumers for the green transition through enhanced protection against unfair commercial practices and the provision of better information. While not specifically targeting textiles, the Directive introduces sweeping changes to how traders of physical goods, including fashion and textile companies, must substantiate and present their sustainability claims regarding their products and businesses.

The core objective is to ensure that consumers can make informed purchasing decisions and contribute to more sustainable consumption patterns. This places a significant responsibility on traders to provide clear, relevant, and reliable information.

Here is a breakdown of what fashion and textile companies need to be aware of regarding this new regulatory landscape, particularly concerning greenwashing and product information.

1. The Strict New Rules Against Greenwashing

The Directive introduces specific rules into Union consumer law to tackle misleading environmental claims, often referred to as 'greenwashing'. Several practices are now explicitly classified as unfair commercial practices, prohibited either on a case-by-case assessment or in all circumstances.

📍 Curbing Misleading Environmental and Social Claims

Traders must ensure they do not mislead consumers regarding a product's environmental or social characteristics or its circularity aspects, such as durability, reparability, or recyclability. These characteristics are now included in the list of main product features regarding which a trader's practices can be considered misleading.

For textile companies, this means scrutiny extends beyond environmental impact to include social aspects. Information provided on social characteristics throughout the value chain can relate to the quality and fairness of working conditions (like adequate wages, safety, and social dialogue), respect for human rights, equal treatment, or ethical commitments such as animal welfare.

📍 Prohibition of Generic Claims

Making a generic environmental claim—one that is not specific and lacks recognized excellent environmental performance relevant to the claim—is now prohibited in all circumstances.

Examples of prohibited generic environmental claims include statements that suggest or create the impression of excellent environmental performance, such as: 'environmentally friendly,' 'eco-friendly,' 'green,' 'nature's friend,' 'ecological,' 'climate friendly,' 'gentle on the environment,' 'sustainable,' or 'conscious'.

For example: A t-shirt labeled simply as "sustainable" without specific substantiation would violate this provision.

If a generic claim is used, it must be supported by demonstrated recognized excellent environmental performance. However, if the environmental claim's specification is provided in clear and prominent terms on the same medium (e.g., product packaging or online interface), it is considered a specific claim and does not fall under this generic claim prohibition.

📍 Banning Misleading Scope Claims

It is now prohibited to make an environmental claim about the entire product or the trader's entire business when that claim only concerns a specific, unrepresentative activity or a certain aspect of the product.

For example: Marketing a textile product as 'made with recycled material' if, in fact, only the packaging is made of recycled material, could be prohibited as it gives the impression that the entire product meets the claim.

📍 Total Ban on Carbon Offsetting Claims

The Directive explicitly prohibits making claims that a product has a neutral, reduced, or positive impact on the environment based on the offsetting of greenhouse gas emissions.

Examples of such prohibited claims include: 'climate neutral,' 'CO2 neutral certified,' 'carbon positive,' 'climate net zero,' or 'climate compensated'.

This means fashion brands can no longer claim products are 'climate neutral' through purchasing carbon credits or offsets. Such statements are deemed misleading because they suggest the claim relates to the product itself or its supply and production, or they give the false impression that its consumption has no environmental impact. Such claims are only permissible if based on the actual lifecycle impact of the product, not external offsetting.

📍 Future Performance Claims

Claims regarding future environmental performance (such as a transition to carbon neutrality by a certain date) must be supported by clear, objective, publicly available, and verifiable commitments and targets. These must be set out in a detailed and realistic implementation plan that shows how the commitments will be achieved, allocates resources, and is regularly verified by an independent third-party expert whose findings are made available to consumers.

2. Mandatory Transparency for Sustainability Labels

Fashion and textile companies frequently rely on sustainability labels (voluntary trust marks or quality marks referencing environmental or social characteristics) to promote their products. The Directive now prohibits the displaying of any sustainability label that is not based on a certification scheme or not established by public authorities.

If a label is based on a certification scheme, the trader must ensure it meets minimum conditions of transparency and credibility. This includes objective monitoring of compliance carried out by a third party whose competence and independence are ensured based on international, Union, or national standards and procedures.

For example: Self-created "eco-friendly" labels without third-party certification will no longer be permitted.

3. Focus on Durability and Reparability of Goods

To address practices associated with early obsolescence, the Directive introduces rules regarding the lifespan and repair of goods. Purchasing products expected to last longer than they do causes consumer detriment and has negative environmental impacts (increased waste and resource use).

For textile products, durability and repair claims are now closely regulated:

  • It is prohibited to falsely claim that a good has a certain durability in terms of usage time or intensity under normal conditions of use.
  • It is prohibited to present a product as allowing repair when such repair is not possible.

For example: Claiming jeans will "last a lifetime" without substantiation, or advertising shoes as "repairable" when replacement parts aren't available.

4. New Pre-Contractual Information Obligations

The Directive also amends the Consumer Rights Directive (2011/83/EU) to ensure consumers receive specific information about a product's durability and reparability before they conclude the contract.

Traders will be required to provide the following information (if made available by the producer):

Commercial Guarantee of Durability: If the producer offers a commercial guarantee of durability that covers the entire good and lasts more than two years at no additional cost, the trader must inform the consumer using a harmonised label. This label will also remind consumers of the legal guarantee of conformity.

Legal Guarantee Reminder: A separate harmonised notice must be used to remind consumers of the existence and main elements of the legal guarantee of conformity, including its minimum duration of two years.

Reparability Information: Where applicable, the trader must provide the reparability score for the goods. If a score is not established at the Union level, the trader must provide other relevant repair information made available by the producer, such as the availability, estimated cost, and procedure for ordering spare parts, and the availability of repair and maintenance instructions.

Environmentally Friendly Delivery: Traders should, where applicable, inform consumers about the availability of environmentally friendly delivery options.

Implementation Timeline

Member States are required to adopt and publish the measures necessary to comply with this Directive by 27 March 2026. They must apply those measures from 27 September 2026.

This means fashion brands have limited time to:

  • Review all current sustainability claims
  • Update product descriptions and labels
  • Implement verification systems
  • Train teams on new requirements

Frequently Asked Questions

💡 What is the EU Empowering Consumers Directive?

The EU Empowering Consumers Directive (EU) 2024/825 is legislation that strengthens consumer protection against greenwashing and misleading environmental claims, requiring businesses to substantiate all sustainability claims with clear, verifiable evidence.

💡 When does Directive 2024/825 come into force?

Member States must adopt the directive by March 27, 2026 and apply it from September 27, 2026.

💡 What green claims are now prohibited?

Generic claims like "sustainable," "eco-friendly," or "green" without specific substantiation are prohibited. All carbon offsetting claims (like "climate neutral" or "carbon neutral") are also banned unless based on actual lifecycle impacts.

💡 How does this affect fashion brands?

Fashion brands must review and substantiate all sustainability claims, ensure any labels are third-party certified, provide durability and reparability information, and remove any generic or offsetting-based environmental claims from their products and marketing.

💡 Can we still use sustainability certifications?

Yes, but only if they are based on approved certification schemes with third-party verification. Self-created labels or unverified claims are no longer permitted.

Next Steps for Compliance

As the fashion industry prepares for these significant regulatory changes, companies should begin their compliance journey now:

  • Audit current claims - Review all product descriptions and marketing materials
  • Gather substantiation - Compile evidence for all environmental and social claims
  • Update systems - Implement processes for ongoing compliance monitoring
  • Train teams - Ensure all stakeholders understand the new requirements

Need help ensuring compliance with the EU Empowering Consumers Directive?

Contact BetterChoice for a comprehensive compliance assessment of your sustainability claims.

This guide provides general information about EU Directive 2024/825. For specific legal advice regarding your company's compliance obligations, consult with qualified legal counsel.