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
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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.
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.
| Column | What to write | Source |
|---|---|---|
| A–E | url, shop, title, brand, description | scraper |
| 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 not | Art. 2(p), Recital 9 |
| K Proof of excellent performance | EU Ecolabel / officially recognised EN ISO 14024 type I label / top class under other EU law (for example energy class A) / none | Art. 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.
| Column | What to write |
|---|---|
| A Label name | as shown, for example "EU Ecolabel" or "Our Planet Promise" badge |
| B Where shown | page URL or "all product pages" |
| C Basis | public 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 link | the 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)
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 found | J | K | L | M Result |
|---|---|---|---|---|---|
| Eco-friendly bamboo toothbrush | eco-friendly / – / – | N | none | WHOLE | REWRITE 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 / – / – | N | energy class A | WHOLE | CHECK BY HAND |
| Green linen shirt | green / – / – | N | none | – | 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
- Directive (EU) 2024/825 of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition (OJ L, 2024/825, 6.3.2024): Recitals 4, 7, 8, 9, 10 and 12; Article 1 (new Article 2(o) to (s) and Article 6(2)(d) of Directive 2005/29/EC); Article 4(1); Annex points 2a, 4a, 4b, 4c and 10a — eur-lex.europa.eu, CELEX 32024L0825 (read 28 Oct 2026)
- Unadhi Actor on Apify Store: E-commerce Product Data Scraper (README read through the Apify API on 28 Oct 2026)
Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.