Green Claims Have Become an Inventory Problem

The European Commission records 27 September 2026 as the application date for Directive (EU) 2024/825. Its September Q&A says environmental claims and sustainability labels on existing products and old stock also need attention. It discusses practical corrective measures and proportionate enforcement; it does not provide a universal sell-through exemption. The Q&A is non-binding interpretation.

An outdated claim can exist on a printed carton, marketplace listing, retailer feed, advert and translated product page at the same time. Fixing the brand website alone does not reconcile that network. Claims therefore need to be managed as records linked to a SKU, pack version, geography, channel and evidence.

The rules do not justify a simplistic universal list of forbidden words. Meaning, qualifications, evidence and context matter, and this enacted directive must not be confused with the separate Green Claims proposal. Brands should prioritise high-volume inventory and prominent language, then monitor national implementation and actual decisions before forecasting penalties or naming supposed offenders.