Split the claim into the words that promise something and the words that specify it, and if the second set is missing, the claim is generic. From 27 September 2026 that distinction is law across the EU: the European Commission puts the application date of Directive (EU) 2024/825, adopted on 28 February 2024, at 27 September 2026 (sustainable consumption). The condition that changes it: a claim carried on a sustainability label backed by an officially recognised scheme is judged against that scheme instead.

The list the regulator already wrote

The Commission's questions-and-answers document on the directive quotes Recital 9's own examples of generic environmental claims — "environmentally friendly", "eco-friendly", "green", "nature's friend", "ecological", "environmentally correct", "climate friendly", "gentle on the environment", "carbon friendly", "energy efficient", "biodegradable" and "biobased" — and states they sit on the Unfair Commercial Practices Directive's list of practices banned in all circumstances, at point 4a, where recognised excellent environmental performance cannot be demonstrated (Q&A on the ECGT Directive).

Print that list of twelve and keep it by the kettle. One person reads a pack, an advert or a product page aloud; the other marks every word that appears on the list. A pack with three marked words and no specification beside any of them is not a subtle case.

Visual claims count too. The same Commission document says green leaves, water drops and similar nature icons, and green or blue backgrounds, can be read as implicit environmental claims depending on the commercial context (Q&A on the ECGT Directive). So the second reader marks the artwork as well as the text.

Two real sentences, side by side

Example. The Commission's own document contrasts two packaging claims. "Climate-friendly packaging", with no further specification, is a generic environmental claim and falls under the prohibition unless recognised excellent environmental performance is shown. "100% of energy used to produce this packaging comes from renewable sources" is a specific claim and does not fall under that prohibition, although it still has to be presented accurately and backed by evidence (Q&A on the ECGT Directive).

Read them in turn and name the difference out loud. The second sentence states what is measured (energy for production), the share (100 percent) and the boundary (the packaging, not the product inside it). The first states a direction of travel and nothing measurable at all. That is the whole test, and it takes about fifteen seconds per claim once you have said it once.

Enforcement has already run ahead of the directive in one member state. The Netherlands Authority for Consumers and Markets published on 13 September 2022 that Decathlon and H&M would adjust or stop using sustainability claims after its investigation found general terms such as "Ecodesign" and "Conscious" used without clearly specifying the sustainability benefit, and that the two chains would donate 400,000 euros and 500,000 euros respectively to sustainable causes, with ACM enforcing the commitments for two years (Decathlon and H&M will provide better information about sustainability). "Conscious" is a brand word doing the work of a specification, which is exactly the pattern the twelve-word list describes.

Five checks a shopper can run without a lawyer

The UK's Competition and Markets Authority published its Green Claims Code for shoppers on 13 October 2021, setting out five checks: do not just trust slogans or vague terms, look for evidence to support a claim, look past appearances, do not forget the disposal, and think about the bigger picture — naming "all natural", "green" and "eco" as phrases that sound good without carrying clear meaning (Green claims code for shoppers).

Run them as a two-person pass. One takes checks one to three at the shelf; the other takes disposal and the bigger picture at home, where the recycling collection rules and the actual use of the thing are known. Disposal is where a strong claim most often thins out, because the promise attaches to the material and the answer attaches to your street. The difference between a repairability promise, a reuse promise and a recycling promise is set out in repairable, reusable, recyclable: different promises, and a claim printed as a regulated scale rather than a slogan behaves differently again, as read an energy label together shows.

Finish by writing the supported part in one sentence with its boundary attached, the way a chart headline gets rewritten in read a chart before debating its headline. If nothing survives the rewrite, that is the finding.

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