Green claims, the guarantee notice and the cancel button
As reported, since 27 September 2026 a claim like "climate neutral" needs recognised excellent performance and the guarantee notice must be shown; since 19 June 2026, a two-step cancel function without login.
As of 15 October 2026. This guide is general information, not legal advice.
Most of the EU rules a brand meets land in the warehouse or at the border. These four reach the product page and the checkout, which is where a brand's own words are. Three of them apply already. The dates below are as reported; the texts linked at the end are where to confirm them.
Environmental claims, since 27 September 2026
Directive (EU) 2024/825, usually called EmpCo, applies from 27 September 2026, as reported. It bans generic environmental claims such as "climate neutral" or "recyclable" unless the product has recognised excellent environmental performance behind the claim. It also requires that a sustainability label rests on a certification scheme or on a public authority; a label you designed yourself no longer counts. For each environmental word on the product page, check which document stands behind it and whether it is ready to send.
The Green Claims Directive, proposal COM(2023) 166, is not law. The Commission has announced its intention to withdraw the proposal, as reported. Directive (EU) 2024/825 is the rule that applies.
The legal guarantee notice, since 27 September 2026
Implementing Regulation (EU) 2025/1960 sets a harmonised notice on the legal guarantee of conformity, to be shown online and offline from 27 September 2026, as reported. The notice is a fixed text set by the regulation, to be shown as given. It belongs on the store, in the place where a buyer looks for it, and in the shop if you have one.
Every environmental word on a product page now needs a document behind it.
The cancel function, since 19 June 2026
Directive (EU) 2023/2673 requires, since 19 June 2026, as reported, a clearly labelled online withdrawal function: two steps, accessible without login. The consumer finds the function, confirms, and the withdrawal is made. A function that needs a login does not meet it. If your store runs on a standard store system, check the function your theme provides against the two-step, no-login test; the obligation sits with you as the seller, whatever the theme ships.
The right to repair and the passport
Directive (EU) 2024/1799 on the repair of goods is the longer-term one. Its repairability elements are to be disclosed in the passport, product group by product group, as the delegated acts arrive, as reported. Repairability and durability are among the expected passport fields, so for a covered product the claim you make today is expected to become a passport field, with its evidence behind it. Passport contents lists those fields, with the evidence that counts for each.
Store checks this month
Read every product page for environmental words and attach a document to each or remove the word. Replace any label you drew yourself with a certified one or with nothing. Add the harmonised guarantee notice where the store shows its terms. Test the cancel function as a customer who is not logged in. You can start all of this without a lawyer. If an environmental claim is central to your brand, have one check the substantiation before you rely on it.
Questions we get asked.
Can we still say "recyclable" on a product page?
As reported, not as a generic claim, unless the product has recognised excellent environmental performance behind it.
Is the legal guarantee notice something we write?
No. It is a harmonised text set by Implementing Regulation (EU) 2025/1960, shown online and offline from 27 September 2026, as reported.
Our store has a returns form in the account area. Is that the withdrawal function?
Not if it needs a login. The function must be clearly labelled, two steps, and reachable without logging in, since 19 June 2026, as reported.
Is the Green Claims Directive in force?
No. It is a proposal, and the Commission has announced its intention to withdraw it, as reported. The rules that apply are the ones in Directive (EU) 2024/825.
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