EU Directive 2024/825 and Amazon: how to review environmental claims on product listings

Key point
From 27 September 2026, national rules implementing Directive (EU) 2024/825 apply across the European Union. Amazon has said that products sold in its EU stores must remove generic environmental claims and be able to substantiate remaining claims. An Amazon listing can no longer simply say a product is ‘eco-friendly’, ‘green’ or ‘sustainable’: it needs to communicate a specific, understandable and supported benefit.

Introduction

Consumers want clearer environmental information. Brands need to explain genuine progress without turning every product page into legal copy.

Directive (EU) 2024/825 - commonly called the Empowering Consumers for the Green Transition directive, or ECGT - strengthens EU rules against misleading commercial practices. It addresses, among other things, environmental claims that are overly broad, poorly scoped or based solely on carbon offsetting.

For brands and Amazon sellers, this is operational rather than theoretical. Amazon has published specific guidance for its EU stores: review content, remove generic claims and prepare supporting evidence. Non-compliant products may be identified in Account Health and can be deactivated.

This guide keeps three levels separate throughout:

• [EU law] what Directive 2024/825 says;

• [Amazon] what Amazon has officially communicated for EU stores;

• [Good practice] a practical way to reduce risk and organise listing content.

This article is educational, not legal advice. Product requirements can also depend on the category, country of sale and sector-specific rules.

What EU Directive 2024/825 changes

The key dates

[EU law] The directive was published on 6 March 2024. Member States had to transpose it by 27 March 2026, and their implementing measures must apply from 27 September 2026.

The directive amends, among other legislation, the Unfair Commercial Practices Directive. It does not create one EU-wide form that every listing must complete. Instead, it broadens the commercial practices that may be misleading or prohibited in consumer-facing communication.

Generic environmental claims are no longer enough

[EU law] A generic environmental claim is a message that suggests or creates the impression that a product, brand or activity has a positive or reduced environmental impact, without making that benefit clear and prominent on the same medium.

The directive gives examples such as:

• ‘environmentally friendly’;

• ‘eco-friendly’;

• ‘green’;

• ‘nature’s friend’;

• ‘ecological’.

‘Sustainable’ is not automatically banned in every context. However, when used on its own, without a defined environmental benefit and evidence, it is exactly the sort of high-risk wording the directive is designed to address.

A generic claim may still be defensible where the trader can demonstrate recognised excellent environmental performance relevant to that claim. In practice, that requires a robust file: clear scope, credible evidence and alignment between the wording and what it genuinely covers.

The issue is not merely the word - it is the overall impression

[EU law] The directive does not require brands to remove every environmental reference. It targets wording that leaves customers with a broader impression than the evidence supports.

For example, a true statement about packaging can still mislead if it implies that the whole product is environmentally better.

*These examples are not automatically approved claims. They illustrate the level of precision to aim for. Use must be based on relevant, current and demonstrable evidence.

A claim must cover what it says it covers

[EU law] The directive prohibits an environmental claim about an entire product, a trader’s activity or the whole brand where it actually relates only to one particular aspect.

For example, a bottle whose cap contains recycled plastic should not be presented as an ‘eco-friendly bottle’ on that basis alone. A claim limited to the cap, with the percentage and material concerned, is much closer to the underlying reality.

Legal compliance is not a distinctive product benefit

[EU law] It is also prohibited to present a requirement imposed by law on all products in a relevant category as if it were a distinctive feature of a particular product.

For that reason, ‘meets European environmental standards’ may be problematic where it merely describes a general legal obligation rather than a specific product benefit.

Areas to watch: carbon, labels and certifications

‘Carbon neutral’ and ‘climate neutral’ claims

[EU law] The directive adds to the blacklist claims that a product has a neutral, reduced or positive environmental impact because of greenhouse-gas emission offsetting.

The practical point is simple: offsetting on its own is not enough to market a product as ‘carbon neutral’ or ‘climate positive’.

This does not mean that all carbon information is prohibited. A brand may communicate genuine emission reductions where it can substantiate them and clearly state the scope, method, reference period and object of the claim. Complex claims should, however, be reviewed with legal, sustainability and quality teams.

Sustainability labels

[EU law] Sustainability labels may not be displayed unless they are based on a certification scheme or established by public authorities. The directive defines a certification scheme as a third-party verification mechanism with transparent criteria and a process for monitoring compliance.

An in-house leaf icon, an invented ‘green choice’ badge or a proprietary logo suggesting certification can therefore create risk. A third-party certification logo is not decoration either: it must be valid for the relevant product, used correctly and supported by documentation.

‘Biodegradable’, ‘recyclable’ and ‘compostable’: state the conditions

[Good practice] These terms are more specific than ‘green’, but are still easy to overstate. Before publishing them, check at least:

• the exact item concerned: product, component, packaging, ink or refill;

• the material and percentage where relevant;

• necessary conditions: home or industrial composting, available collection route or specialist treatment;

• the standard, test or certification behind the claim;

• the geography in which the claim is true;

• the evidence expiry date.

Do not turn a limited packaging benefit into a promise about the entire product.

What Amazon now asks for on EU listings

Amazon’s official announcement

[Amazon] In a Seller Central announcement, Amazon says that, from 27 September 2026, the directive applies to all products sold in its EU stores.

Amazon describes the relevant generic claims as vague marketing terms with no specific, measurable or verifiable environmental benefit. Its examples include ‘eco-friendly’, ‘green’, ‘sustainable’ and ‘carbon neutral’ when the latter is supported only by carbon offsetting.

Amazon asks selling partners to:

1. remove generic claims from product listings;

2. provide supporting documentation for remaining environmental claims.

Amazon gives product durability, energy efficiency and recyclability as examples of claims that may need evidence. It also says it will communicate instructions on how to submit that documentation.

Possible Amazon consequences

[Amazon] Amazon says that non-compliant products will be identified in the Account Health dashboard and may be deactivated.

This is stronger than a simple editorial recommendation. It supports prioritising an audit of EU ASINs, especially where sensitive terms appear in prominent content.

Two common assumptions should nevertheless be avoided:

• Amazon has not said in this announcement that every occurrence of a particular word will automatically deactivate a listing;

• Amazon has not published, in this announcement, one final universal list of accepted documents for every claim type.

In short: prepare evidence and correct generic content, but do not invent a precise Amazon rule that has not been published.

What about Vendor Central?

[Amazon] The publicly accessible announcement was published in Seller Central and concerns products sold in EU stores. It is not, by itself, detailed Vendor Central operating guidance.

[Good practice] Brands working through Vendor Central should still audit product pages they contribute to or influence. Shoppers see the same detail page, and a non-compliant claim may sit in A+ Content, an image, a brand description or central catalogue data.

How to audit an Amazon listing in practice

The goal is not to remove all environmental language. It is to answer, for every claim: what exactly does it promise, what is its scope, and what evidence supports it?

1. Build an inventory of wording and promises

[Good practice] Start by searching for obvious expressions in every language used in your stores:

• eco-friendly, environmentally friendly, green, sustainable, responsible, low impact;

• biodegradable, compostable, recyclable, reusable;

• zero waste, plastic-free, impact-free;

• carbon neutral, climate neutral, net zero;

• natural, non-toxic or ‘clean’ where they imply an environmental promise;

• label names, logos, leaf icons and badges linked to the product.

This is a starting list, not an official word blacklist. Context, imagery, country and evidence all matter.

2. Review every content area

Do not restrict the audit to the title. Review:

3. Give each claim a risk level

A simple triage method is:

• Red - remove or obtain rapid approval: generic claim, or a ‘carbon neutral’ claim based only on offsetting;

• Amber - make it more precise and document it: a potentially genuine benefit, but too broad, incomplete or unsupported;

• Green - retain under control: a specific, correctly scoped and documented claim.

Green does not mean ‘permanently approved by Amazon’. It means the claim appears better prepared and should remain monitored.

4. Keep an evidence file for each claim

[Good practice] For every claim you retain, keep a single source of truth containing:

• the exact wording and affected ASINs;

• the country and published language;

• the component or life-cycle stage concerned;

• the internal owner;

• the source: test, certificate, technical sheet, report, calculation or supplier declaration;

• the standard or methodology used;

• the validity period;

• limitations and conditions that need to be visible;

• the next review date.

A credible certification can help, but it does not replace checking the actual published sentence. A packaging certification may not substantiate a claim about the entire product.

5. Correct the copy without removing useful information

Good editing replaces a vague promise with verified, useful customer information.

For example:

• replace ‘better for the planet’ with the material, proportion and component concerned;

• replace ‘carbon neutral product’ with a genuinely measured reduction statement, where available and legally approved;

• replace ‘sustainable packaging’ with recycled content and end-of-life information, including relevant conditions, where you can demonstrate them.

Checklist: auditing Amazon listings before or after 27 September 2026

Use this checklist ASIN by ASIN, then apply it to broader brand content.

• I have identified every environmental word, statement and visual.

• I have reviewed the title, bullet points, description, images, A+ Content, videos and Brand Store.

• I know whether each claim concerns the whole product, a component, packaging or the company.

• Each benefit is specific, understandable and limited to its true scope.

• I do not use ‘eco-friendly’, ‘green’, ‘sustainable’ or equivalents as unsupported marketing adjectives.

• I do not claim ‘carbon neutral’ or ‘climate neutral’ solely because of carbon offsetting.

• I do not present a general legal requirement as a special product advantage.

• Labels and badges are based on a public authority or certification scheme and are valid for the product.

• Evidence is available, dated, linked to the right reference and ready to share if Amazon requests it.

• Content is consistent across languages and EU stores.

• Marketing, Legal, Sustainability, Quality and Amazon teams know who approves what.

• I monitor Account Health and Amazon compliance requests.

Conclusion

EU Directive 2024/825 does not ban environmental communication. It pushes brands to make it more specific, more verifiable and more honest about its scope.

On Amazon, the right response is not to rewrite every listing blindly. Start by finding generic terms, prioritise the most visible ASINs and retain clear evidence for every statement you decide to keep.

OKTee Marketing can help teams identify potential risks in Amazon titles, bullet points and descriptions automatically, so they can prioritise the corrections that need review and validation.

Frequently asked questions

Does EU Directive 2024/825 ban the word ‘sustainable’?

Not automatically. The problem is using a generic claim without a precise, demonstrable environmental benefit. ‘Sustainable’ used on its own should therefore be audited as a priority.

Can I say ‘biodegradable’ on an Amazon listing?

Not without context. Check the material, conditions of degradation, necessary environment or treatment route, and available tests or certification. Quality or legal review may be needed.

Is a certification enough to use an environmental logo?

No. The logo must be based on a certification scheme or public authority, valid for the relevant product and used in line with its rules. The accompanying wording must remain accurate as well.

Can I say a product is carbon neutral if we fund offset projects?

The directive expressly targets neutral, reduced or positive impact claims based on greenhouse-gas offsetting. Do not treat offsetting alone as sufficient grounds to say a product is carbon neutral.

Will Amazon deactivate every listing that contains the word ‘green’?

Amazon has not announced an automatic word-by-word rule. It has said, however, that non-compliant products may be identified in Account Health and deactivated. Review the context and evidence, then remove generic claims.

Which Amazon areas should I review?

At a minimum, the title, bullet points and description. A thorough review also covers images, A+ Content, videos, Brand Stores, catalogue attributes and localised versions.

Will Amazon ask for documents?

Yes. Amazon says sellers will need to provide documentation supporting environmental claims and that it will communicate process instructions. Prepare evidence by ASIN and claim now.

Does this affect sellers based outside the EU?

Amazon’s announcement applies to products sold in EU stores. A brand located outside the EU that sells in those stores should therefore review customer-facing content for European shoppers.

Official sources

• Directive (EU) 2024/825 — EUR-Lex, official text

• EUR-Lex summary: unfair commercial practices and application timeline

• Amazon Seller Central: substantiating environmental claims for EU green-transition compliance

• Amazon Seller Central: new consumer-rights information on EU listings

• Amazon: product compliance for sellers in the EU and UK