Unadhi Guides

Green claims check sheet for EU web shops: "eco-friendly", "climate neutral" and own eco badges after 27 September 2026 (Directive (EU) 2024/825) for accountants and web agencies

Updated 28 Oct 2026 · Disclosure: the Apify Actor mentioned below is built and published by Unadhi. Legal facts come only from Directive (EU) 2024/825 on EUR-Lex, read on 28 Oct 2026. This guide is for information only, not legal advice.

Partner programme opening soon: join the free waitlist. Planned terms are 50% of each referred sale (75% once you have 5+ paying customers), single level, paid through Gumroad only from revenue received.

What you get: a finished green claims check sheet in three tabs: a products tab (one row per product, the scraper fills title and description, formulas flag generic green words, offset-based "climate neutral" wording and "net zero by 20xx" promises, and name each row OK, REWRITE OR REMOVE, REMOVE LABEL, CHECK PLAN or CHECK BY HAND); a labels tab for every eco logo or badge the shop shows; and a fix note to send to the shop owner. Five made-up example rows show how it fills in.

Short answer: since 27 September 2026 EU Member States must apply the national rules transposing Directive (EU) 2024/825 (Article 4(1)). It adds four green practices to the list of commercial practices that are unfair "in all circumstances" in Annex I to the Unfair Commercial Practices Directive 2005/29/EC: a sustainability label not based on a certification scheme or not established by public authorities (point 2a); a generic environmental claim such as "eco-friendly" or "green" where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim (point 4a); a claim about the whole product or business when it concerns only one aspect (point 4b); and a claim, based on offsetting greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of emissions (point 4c). Future claims such as "net zero by 2030" need a detailed, realistic, regularly verified plan (new Article 6(2)(d)). Check your national law for the exact wording and penalties.

The pain this page is about

An accountant or bookkeeper with web-shop clients, or a web agency that built and maintains 20 Shopify and WooCommerce shops, gets asked: "our product pages say eco-friendly and climate neutral, is that still allowed?" Reading every product description by hand takes days. A product scraper exports every title and description in one run; the sheet searches the text for the words the Directive names and lists only the rows a person needs to look at.

Step 1: export every product with the scraper

Run our E-commerce Product Data Scraper on the shop's homepage or category pages with includeDescription switched on. It returns one row per product with url, shop, title, brand, description, price and images, from Shopify products.json, the WooCommerce Store API or schema.org data on the page. Before fetching anything it checks the shop's robots.txt and scans its Terms of Service, and skips the shop if they forbid scraping; a SHOPS_SUMMARY record tells you which shops were skipped. For your own client's shop, ask the owner for a product export instead if the scraper skips it.

{ "startUrls": [{ "url": "https://client-shop.example" }], "maxProductsPerShop": 500, "maxListingPages": 20, "includeDescription": true }

Actor fee: free during launch · you pay only Apify usage

Export every product title and description (free during launch)

Limits to know: the scraper reads text, not pictures, so logos and badges inside product images go in the labels tab by hand. Its Terms of Service check is an automated, English-only heuristic, not legal advice.

Step 2: tab 1, products (one row per product)

Paste the export into a Google Sheet. Columns A to E come from the scraper; F to I are formulas; J to L you fill in by hand only for flagged rows. The word lists and the result order are our working rule, built from the examples in Recitals 9 and 12 of the Directive; they find wording for a person to review, they do not decide what is lawful.

ColumnWhat to writeSource
A–Eurl, shop, title, brand, descriptionscraper
F Text=LOWER(C2&" "&D2&" "&E2) (brand names count too: the definition of environmental claim includes "brand names, company names or product names")Art. 2(o) UCPD as inserted
G Generic word=IFERROR(REGEXEXTRACT(F2,"eco-friendly|environmentally friendly|climate[- ]friendly|carbon[- ]friendly|nature's friend|gentle on the environment|environmentally correct|ecological|energy efficient|biodegradable|bio-?based|\bgreen\b|sustainable|conscious|responsible"),"")Recitals 9 and 10
H Offset word=IFERROR(REGEXEXTRACT(F2,"climate[- ]neutral|carbon[- ]neutral|co2[- ]neutral|net[- ]zero|climate[- ]compensated|carbon[- ]positive|reduced climate impact|limited co2 footprint|offset"),"")Recital 12, Annex I point 4c
I Future promise=IFERROR(REGEXEXTRACT(F2,"(?:net[- ]zero|neutral|carbon[- ]free)[^.]{0,30}by 20[0-9]{2}|by 20[0-9]{2}[^.]{0,30}(?:net[- ]zero|neutral)"),"")Art. 6(2)(d), Recital 4
J Specified on the same page?Y if the page says exactly what the claim means in clear and prominent terms (for example "100% of the energy used to make this packaging comes from renewable sources"), N if notArt. 2(p), Recital 9
K Proof of excellent performanceEU Ecolabel / officially recognised EN ISO 14024 type I label / top class under other EU law (for example energy class A) / noneArt. 2(s), Recital 10
L Whole product or one part?WHOLE if the claim is about the whole product or business, PART if the evidence covers only one part (for example only the packaging)Annex I point 4b
M Result=IF(I2<>"","CHECK PLAN (6(2)(d))",IF(H2<>"","REWRITE OR REMOVE (4c)",IF(AND(G2<>"",J2="N",K2="none"),"REWRITE OR REMOVE (4a)",IF(AND(G2<>"",L2="WHOLE",K2="none"),"CHECK BY HAND (4b)",IF(G2<>"","CHECK BY HAND","OK")))))our working rule

Why the result says "check by hand" so often: "green" also matches a green T-shirt, and "responsible" matches "responsible person". A keyword hit is a reason to read the sentence, nothing more. Shops writing in other languages: add your own words to columns G to I (our suggestions, not from the Directive: umweltfreundlich, nachhaltig, klimaneutral in German; écologique, neutre en carbone in French; milieuvriendelijk, klimaatneutraal in Dutch).

Step 3: tab 2, labels (one row per eco logo, badge or seal)

Open the shop's homepage, footer, one product page per category and the checkout, and list every trust mark that refers to environmental or social characteristics. Labels required by law are not "sustainability labels" under Article 2(q), so leave mandatory marks out.

ColumnWhat to write
A Label nameas shown, for example "EU Ecolabel" or "Our Planet Promise" badge
B Where shownpage URL or "all product pages"
C Basispublic authority (for example EU Ecolabel under Regulation (EC) No 66/2010, or EMAS under Regulation (EC) No 1221/2009, Recital 7) / certification scheme / own logo / unknown
D Scheme terms linkthe public page with the scheme's requirements (only for "certification scheme")
E Third-party monitoring?Y only if the scheme's terms say compliance is monitored by a third party independent from both the scheme owner and the trader (Art. 2(r)(iv))
F Result=IF(C2="public authority","KEEP",IF(AND(C2="certification scheme",D2<>"",E2="Y"),"KEEP: file the scheme terms","REMOVE LABEL (2a)"))

The four tests a certification scheme must meet (Article 2(r)): open to all traders on transparent, fair and non-discriminatory terms; requirements developed with experts and stakeholders; procedures for non-compliance, including withdrawal or suspension of the label; and objective third-party monitoring. A logo the shop designed itself fails all four.

Step 4: tab 3, fix note (one per shop)

Subject: Green wording on your shop: [n] product pages to change Hello [name], EU rules on green claims (Directive (EU) 2024/825, applied in [country] from 27 September 2026 if national law is in place) ban some wording outright. We exported your [n] product pages and checked the text: 1. [n] pages say "[word]" without saying what it means and without an official ecolabel behind it. Please either replace it with the specific fact (for example "outer box made from 80% recycled cardboard") or remove it. 2. [n] pages say "[climate neutral / CO2 neutral]" on the basis of offsetting. Please remove this wording; you may still describe the offset projects you support, as long as it is not misleading. 3. The "[badge name]" badge is your own logo, not an ecolabel or a third-party certification scheme. Please remove it. 4. The "net zero by [year]" statement needs a published plan with measurable targets, checked regularly by an independent expert. Please send us the plan, or remove the statement. 5. Please check you do not present something every product must have by law as a special feature of yours (Annex I point 10a). The list of pages is attached. This is a wording check, not legal advice; for anything uncertain please ask your consumer authority or a lawyer. [your name]

Made-up example (five rows, tab 1 results only)

These rows are invented to show how the formulas behave. They are not real shops or products.

Title (made-up)G / H / I foundJKLM Result
Eco-friendly bamboo toothbrusheco-friendly / – / –NnoneWHOLEREWRITE OR REMOVE (4a)
Climate neutral coffee 500 g (we offset all emissions)– / climate neutral / ––––REWRITE OR REMOVE (4c)
Washing machine, energy efficient (class A)energy efficient / – / –Nenergy class AWHOLECHECK BY HAND
Green linen shirtgreen / – / –Nnone–REWRITE OR REMOVE (4a): reading shows it is the colour, so mark it OK by hand
Candle, "carbon neutral by 2030"– / carbon neutral / carbon neutral by 2030–––CHECK PLAN (6(2)(d))

Try it on one client shop first

Run the scraper on one shop with up to 100 products, open five flagged rows on the live site, and confirm the sheet found the same words you see. Then run the rest of your client list. Related free sheets: GPSR product page check · unit price check · 30-day lowest price log · website legal notice check.

Frequently asked questions

What counts as a "generic environmental claim"?

Under Article 2(p) of Directive 2005/29/EC, as inserted by Directive (EU) 2024/825, it is an environmental claim, in written or oral form, that is not on a sustainability label and whose specification is not given in clear and prominent terms on the same medium. Recital 9 gives examples: "environmentally friendly", "eco-friendly", "green", "nature's friend", "ecological", "environmentally correct", "climate friendly", "gentle on the environment", "carbon friendly", "energy efficient", "biodegradable" and "biobased". It also says "climate-friendly packaging" is generic, while "100 % of energy used to produce this packaging comes from renewable sources" is specific.

When can a shop still say "eco-friendly"?

When it can demonstrate recognised excellent environmental performance relevant to the claim (Annex I point 4a): performance under the EU Ecolabel Regulation (EC) No 66/2010, a national or regional EN ISO 14024 type I ecolabel officially recognised in a Member State, or top performance under other EU law (Article 2(s)). Recital 10 adds that "energy efficient" could rest on class A under Regulation (EU) 2017/1369, and that "sustainable", "conscious" or "responsible" should not rest only on environmental performance because they also cover social characteristics.

Can we still say "climate neutral" because we buy carbon credits?

No for the product: Annex I point 4c bans claiming, based on offsetting greenhouse gas emissions, that a product has a neutral, reduced or positive impact in terms of emissions. Recital 12 says such claims are allowed only when based on the actual lifecycle impact of the product, and that companies may still advertise investments in environmental initiatives, including carbon credit projects, if the information is not misleading.

Does this apply to shops selling only to businesses?

Directive (EU) 2024/825 amends Directive 2005/29/EC, which concerns unfair business-to-consumer commercial practices. A shop selling only to businesses should check its national law, which may go further.

Not legal advice. The sheet only finds wording for a person to review; it does not check whether a claim is true, national transposition, sector rules (for example food or cosmetics labelling) or penalties. When in doubt, ask your consumer authority or a lawyer. Spotted an error? Write to mininglife7@gmail.com and we correct it.

Sources

← All guides

Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.