Guide · Updated September 2026

Green claims rules for fashion: EU, UK and France

Three regulatory frameworks apply today to what a fashion brand may say about its environmental performance, one of them from 27 September 2026. A fourth, the Green Claims Directive, remains a pending proposal. This guide maps all of them in plain language and sets out the evidence-first practice that satisfies the three that apply. It is an editorial orientation, not legal advice.

~8-minute read · English · No email gate

Why this matters now

For years, environmental marketing in fashion ran ahead of environmental evidence, and regulators noticed. The EU's response is no longer a proposal on the horizon: the Empowering Consumers Directive applies from 27 September 2026, banning outright the kinds of generic claims ("eco-friendly", "conscious", "climate neutral" via offsetting) that fashion marketing has leaned on for a decade. The UK's competition authority can now fine greenwashing directly. France has been enforcing textile-specific disclosure since 2023.

The common thread is not a ban on talking about sustainability. It is a simple inversion: the claim is only as good as the evidence behind it, and the burden of producing that evidence is moving onto the brand.

Three frameworks that apply today, plus one proposal still pending

EU: Empowering Consumers Directive (2024/825)

Adopted law · applies from 27 September 2026

Amends the Unfair Commercial Practices Directive. Bans generic environmental claims ("eco-friendly", "green", "climate neutral") unless recognised excellent environmental performance can be demonstrated; bans sustainability labels that are not based on a certification scheme or established by public authorities; bans claims that a product has a neutral, reduced or positive environmental impact when based on offsetting. Member states had to transpose it by 27 March 2026: the measures apply from 27 September 2026.

EU: Green Claims Directive (proposal)

Proposal · remains pending

Proposed in March 2023, it would require explicit environmental claims to be substantiated against defined criteria and verified before publication by accredited third parties. The Commission announced in June 2025 that it intends to withdraw the proposal. It has not been formally withdrawn and remains pending. Whatever its fate, the substantiation logic it codifies is already arriving through the Empowering Consumers Directive and national enforcement.

UK: CMA Green Claims Code

Guidance since 2021 · direct CMA enforcement since April 2025

Six principles: claims must be truthful and accurate; clear and unambiguous; must not omit or hide important information; comparisons must be fair and meaningful; claims must consider the full life cycle; and claims must be substantiated. Under the Digital Markets, Competition and Consumers Act 2024, the CMA can now decide breaches itself and impose fines of up to 10% of global turnover. It no longer needs to go through the courts.

France: AGEC law

In force · textile disclosure obligations phased in since 2023

The loi AGEC (2020) and its implementing decree for environmental qualities and characteristics (décret 2022-748) require textile products to disclose attributes such as recycled-content percentage, recyclability, the presence of plastic microfibres and traceability information for key production stages, phased in by company size since 2023. AGEC also bans the terms "biodégradable" and "respectueux de l'environnement" on products and packaging, and France enforces greenwashing under consumer law independently of Brussels.

Selling in more than one of these markets? The rules stack: a claim published on one product page is typically visible in all of them at once.

What this means for fashion claims in practice

Across the three frameworks that apply today, and the proposal still pending, the same claim types recur as the highest-risk:

Generic and absolute wording. "Sustainable", "eco-friendly", "green", "kind to the planet", banned under the Empowering Consumers Directive unless recognised excellent environmental performance can be demonstrated, and flagged under the CMA Code as unclear and unsubstantiated.
Self-created sustainability labels. A leaf badge or "conscious" tag of your own design, without a certification scheme or public authority behind it, becomes a banned practice in the EU from September 2026.
Offsetting-based neutrality claims. "Carbon neutral" or "climate positive" claims that rest on purchased offsets rather than the product's own footprint are banned in the EU and have already been the subject of UK and French enforcement and litigation.
Range-wide claims from partial evidence. A certificate covering one fibre, one product, or one facility quietly extended to a whole collection: the most common gap we see in practice, and one every framework treats as misleading.
Channel blind spots. The rules cover everywhere the consumer meets the claim: product pages, hangtags, packaging, paid ads, social media, influencer content. A compliant product page does not neutralise a non-compliant Instagram caption.

The evidence-first response

The practical answer is the same whatever happens to the Green Claims Directive, because it is the logic shared by the three frameworks that apply today and by the proposal still pending:

Inventory your claims: List every environmental statement you make, everywhere it appears: product pages, hangtags, care labels, packaging, paid ads, social posts, press materials, investor communications. Most teams find claims they did not know they were making: a "conscious collection" filter, a leaf icon, a supplier's certificate quoted out of scope.
Map each claim to its evidence: For each claim, ask: what document substantiates this, who holds it, when was it produced, and does it cover this specific product or only part of the range? A claim whose evidence you cannot produce on request is a liability under every framework above, regardless of whether it happens to be true.
Rewrite or retire the unsupported: Vague and absolute wording ("sustainable", "eco-friendly", "kind to the planet") is the highest-risk category under the Empowering Consumers Directive and the CMA Code alike. Specific, qualified, product-level statements tied to verifiable attributes survive scrutiny; generic virtue language does not.
Document a review cadence: Evidence ages: certificates expire, supplier mixes change, methodologies update. A documented review, who checks what, how often, against which rules, is the difference between a one-off clean-up and a defensible practice. Regulators ask for the process, not just the proof.

Go deeper

This guide maps the territory. Two concrete ways to act on it:

Green Claims Risk Check FREE

12 questions (up to 21), 5 to 10 minutes: an indicative view of your exposure across the EU, UK and French rules, personalised to the markets you sell in. Results by email. Not legal advice.

Check my exposure

Green Claims Audit

Up to 25 claims reviewed one by one against the EU rules on unfair commercial practices as amended by the Empowering Consumers Directive, the UK CMA Green Claims Code, and French rules including AGEC and the Climate and Resilience law. Risk-rated claims register, evidence gap analysis and a prioritised action plan. €4,500 excl. VAT.

Explore the audit

Frequently asked questions

Is the Green Claims Directive dead?

Not formally. The Commission announced in June 2025 that it intends to withdraw the proposal. It has not been formally withdrawn and remains pending. More importantly: the Empowering Consumers Directive, which is adopted law and applies from 27 September 2026, already bans the highest-risk claim types. Waiting for the Green Claims Directive saga to resolve is not a compliance strategy.

We are not an EU company. Do these rules still apply to us?

They apply to claims made to consumers in the relevant markets, not to where your company is registered. If you sell into the EU, the Empowering Consumers Directive perimeter concerns you; if you sell in the UK, the CMA Code does; if you sell in France, AGEC does, in each case on top of the others.

Are recycled-content claims still allowed?

Yes, specific, accurate, substantiated claims remain legitimate under every framework. "55% recycled polyester, certified to [scheme], verified [date]" is a defensible claim if the chain-of-custody evidence behind it is real. What the rules target is the gap between what is said and what can be shown: the rounded-up percentage, the range-wide claim based on one product, the certificate that covers the fibre but not the garment.

Where should we start?

With a claims inventory and an honest look at the evidence behind each claim. Our free 5–10 minute Green Claims Risk Check gives you an indicative view of your exposure across the markets you sell in; the Green Claims Audit (€4,500 excl. VAT) reviews up to 25 claims one by one against the EU rules on unfair commercial practices as amended by the Empowering Consumers Directive, the UK CMA Green Claims Code, and French rules including AGEC and the Climate and Resilience law, with a written report and prioritised actions.

Sources

Directive (EU) 2024/825 (Empowering Consumers for the Green Transition), adopted 28 February 2024; transposition deadline 27 March 2026; application from 27 September 2026
Proposal for a Directive on Green Claims, COM(2023) 166. The Commission announced in June 2025 that it intends to withdraw the proposal. It has not been formally withdrawn and remains pending.
UK Competition and Markets Authority, Green Claims Code (September 2021); Digital Markets, Competition and Consumers Act 2024 (direct enforcement powers from April 2025)
Loi n° 2020-105 (AGEC, 10 February 2020); décret n° 2022-748 on environmental qualities and characteristics disclosure