Greenwashing Under Legal Scrutiny. How Are the Rules for “Green” Communication Changing?
Until recently, discussions around greenwashing focused primarily on brand reputation. Today, that is no longer enough. Environmental claims increasingly need to be treated in the same way as other information about a product’s characteristics: they must be precise, substantiated and consistent with the scope actually supported by the available evidence.
The year 2026 is particularly important in this respect. The PPWR has applied since 12 August 2026, while 27 September 2026 marks the EU deadline for the application of the rules resulting from Directive (EU) 2024/825, known as Empowering Consumers for the Green Transition – or EmpCo for short. The Directive expands the list of practices considered unfair and introduces much more specific rules governing the use of environmental claims and sustainability labels.
27 September 2026 – Much Less Room for General “Eco” Claims
Directive 2024/825 introduces new definitions into EU consumer law and expands the so-called blacklist of commercial practices prohibited in all circumstances.
One of the most important changes concerns generic environmental claims, such as “eco-friendly”, “green”, “environmentally friendly”, “ecological”, “climate-friendly”, “biodegradable” or “bio-based”, where the message is not appropriately qualified. Such a generic claim may only be used where the trader can demonstrate recognised excellent environmental performance relevant to the claim – for example through the EU Ecolabel, an officially recognised national or regional EN ISO 14024 type I ecolabelling scheme, or the highest level of environmental performance for a specific characteristic under other applicable EU law. Importantly, the underlying basis must correspond to the content of the claim being communicated – simply holding an environmental label does not automatically justify every generic environmental claim.
A separate prohibition applies to climate neutrality claims: stating that a product has a neutral, reduced or positive impact on the climate may not be based solely on offsetting greenhouse gas emissions outside the product’s value chain, for example through the purchase of carbon offsets or tree-planting schemes.
The way in which a claim is qualified is also important. Under the Directive and the latest guidance from the European Commission, the qualification should appear next to the claim or form part of it and should be presented clearly and visibly on the same medium. This means that a detailed explanation available only, for example, on a website does not replace the qualification required on the medium carrying the claim itself. Moreover, the Commission indicates that limited space on packaging does not in itself justify omitting such information – if a claim cannot be adequately qualified, it should generally not be used.
The law also looks beyond words alone. The definition of an environmental claim covers textual, graphic and symbolic communication, including labels, trade names, product names and brand names. The Commission also points out that visual elements may be relevant when assessing communication if, together with the wording, they create a particular environmental impression for consumers. Simply removing the word “eco” may therefore not solve the problem if the overall communication still suggests environmental characteristics that the company is unable to substantiate.
A Proprietary “Green Certificate” Is Becoming a Serious Risk
Separate rules apply to sustainability labels – voluntary trust marks, quality marks or equivalent labels that distinguish a product, process or business activity on the basis of its environmental or social characteristics. The new rules prohibit the use of such labels unless they are based on a certification scheme meeting the requirements of the Directive or have been established by a public authority.
This does not, however, mean that every specific environmental claim placed on packaging requires external certification. Such claims are subject to separate rules concerning their truthfulness, precision and ability to be substantiated.
This is particularly important when designing packaging. A symbol resembling an independent quality mark, a proprietary “green badge” or a graphic label created solely for the purposes of a particular brand may be assessed not only in terms of what the company intended to communicate, but also in terms of how such a symbol may be understood by consumers.
Environmental Targets Must Also Be Substantiated
The regulations also cover forward-looking claims.
Claims concerning future environmental performance – for example, commitments to reduce a specific environmental impact over the coming years – must be based on clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan. The plan should include measurable targets, timelines and the resources required to achieve them, while progress towards the commitments must be regularly verified by an independent third-party expert whose findings are made available to consumers.
This represents an important change for ESG and marketing strategies. A claim relating to 2030 or 2040 can no longer function merely as a statement of intent. If it is used in commercial communication, the company should be prepared to demonstrate a concrete mechanism for achieving it.
PPWR: For Packaging, the Bar Is Set Even Higher
For the packaging industry, greenwashing regulations need to be analysed together with Regulation (EU) 2025/40 on packaging and packaging waste – the PPWR.
Article 14 of the PPWR is particularly important. Where an environmental claim concerns a packaging property for which the Regulation establishes legal requirements, the claim may refer only to performance that exceeds the applicable minimum requirements under the PPWR. In addition, the trader must specify whether the claim relates to the entire packaging unit, only part of it, or all packaging placed on the market by the trader. Compliance with these conditions must be demonstrated in the technical documentation for the packaging referred to in Annex VII of the PPWR.
This provision may have a significant impact on the future marketing language used by the packaging industry. Merely complying with a mandatory legal minimum should not be presented as a particular environmental benefit of a product. If a specific parameter becomes a legal requirement for an entire category of packaging, presenting it as a distinctive advantage of a particular solution may also be problematic under the new consumer protection rules, which prohibit presenting a legal requirement applicable to all products within a given category as a distinguishing feature of one’s own offer.
In practice, this changes the question that should be asked before publishing a claim. It is no longer only: “Is this information true?”, but also: “Does it represent a genuine advantage above the applicable minimum, what exactly does it refer to, and where is the documentation that substantiates it?”
How to Prepare for the New Rules
The safest approach is not to abandon environmental communication. On the contrary, a well-documented and specific claim can be far more credible than a broad, generic statement. What is changing is the way such claims need to be prepared.
Before publication, it is worth verifying five key elements:
1. Scope of the claim – does it refer to the product, the entire packaging, a specific component, the production process or the company’s activities?
2. Evidence base – which documents, studies, calculations, certificates or supplier data substantiate the exact wording being used?
3. Point of reference – if an improvement, reduction or advantage is being communicated, what is it being compared against, and can the method of comparison be reproduced?
4. Overall context of the communication – do the text, symbols, names, colours and graphics together create a broader environmental promise than the available data can support?
5. Documentation validity and traceability – can the company demonstrate not only the source of the claim, but also the date of the data, the calculation method, the relevant product or SKU scope and the history of changes?
Reliable environmental communication begins with facts – and in the case of packaging, with a precise understanding of its construction, materials and technical parameters. This is the basis on which brands can assess which statements about a given solution are justified and can be properly substantiated.
At Polpak Packaging, we focus on what is within our area of responsibility: providing packaging solutions together with reliable technical information about the products we offer. If you are looking for an experienced packaging partner, contact us – we will help you select a solution tailored to the requirements of your project.
biuro@polpak.pl
+48 22 752 34 23
This material is provided for informational purposes only and does not constitute legal advice.
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Less is more
All business branches and almost all people are in one way or another affected by the outbreak of the pandemic. Market analysts, psychologists and other experts prepare studies or speculations as to what and how has changed, how bad it is and how worse it is going to get.
Although at first glance the above motto may be a little baffling and one could wonder: 'What does that have to do with the price of tea in China?', there exists a deep connection between production and recycling.
Reduction of waste has long been a hot topic, discussed not only by the environmental organizations, but also politicians all over the world. The issue covers already existing waste, waste that is being introduced to the market, as well as future waste generation. Laws, directives and restrictions shed light on the problem and force entrepreneurs to take preventive measures in order to reduce to minimum the landfill sites that are scattered al
Over the centuries of the human existence on Earth, people’s needs have steadily increased. In ancient times, a fireplace, own cave, a piece of leather as clothing and hunting for wild animals was enough to survive. However, increased appetite, the desire for comfort and the need for an easier life were an impulse for ongoing improvements.
The very first and important stage of the recycling process is sorting waste at home. But what happens later?
Where does the waste end up and how does a PET bottle transform into a fleece sweatshirt?
The “zero waste” philosophy has recently gained great popularity. More and more followers try to live by its rules. We don’t fall behind either – we’ve already written about its multidimensionality and the fact that “zero waste” is not only about groceries and not wasting food, to which it is very often reduced. If it’s called a “philosophy”, it should apply to wider aspects of life and general lifestyle.
We often bring up the subject of ecology, sustainability, as well as care and respect for our planet. When we started introducing products made from plastic to the market, we took upon the responsibility to inform our customers and end-consumers how to deal with the packaging after use, once our products become waste.
May these Easter holidays fill your hearts with hope, faith and joy.
We wish you good health, peace and optimistic views on the future.
All the best,
Polpak Packaging Team
Aluminium can be processed an infinite number of times!
Aluminium is lightweight, which means it’s cheaper to transport!
Aluminium is solid and elegant, boosting edgy or vintage look!
Have a look at our 10 to 350 ml jars!
Starting on Monday, March 16th, we are joining the #StayHome campaign.
We are switching to remote working mode.
We will meet on 24-25 June at EXPO XXI centre in Warsaw!
We should always plan our holiday trips ahead. Not only our destination, but also items that we want to take with us!
In 2018 the Polish Ministry of Environment launched the electronic database on waste. The aim of the register is to control waste introduced to the market, its circulation and disposal.
POLPAK Sp. z o.o.
Kabrioletu 4
03-117 Warsaw
Poland
The new year is associated with new resolutions, plans and dreams that we wish to fulfil with a new beginning. Sadly, according to the statistics most of these exciting promises go up in flames already mid-January.
Even though December is the last month of the year, devoted to important summary of the past twelve months, it is also a promising beginning of the upcoming year. During this time international analytic companies publish the results of their research and set new trends for 2020.
Twisted!
According to the Internet wisdom “simple solutions are the simplest”. We truly believe it and our offer reflects it. We care for our customers, hence instead of complicating their decision-making process, we try to simplify it. Sometimes less is more and a narrow selection of the finest products is the key to success. Our long experience and sales analysis show that three types of bottle caps for white co
Light as a feather!
What comes to our minds when we think of chocolate mousse, meringue or Marshmallows? Lightness and treat for the palate. But foamy texture is not only desired in the kitchen – we also love it in cosmetics.
Meet the airless packaging and its magic!
No air, full functionality!
Not long ago we described essential functions of a packaging. It should mainly protect the cosmetic product, provide easy application, be appealing to the eye and eco-friendly.
ATTENTION!
The annual factory closedown is close by!
Special order products with longer lead times!
The turn of September and October was a very intense time since we visited the industry trade fairs in the country and abroad.
Autumn is for us the beginning of a new season that we’ve been diligently preparing for for a few months now. We’ve observed the market and analysed orders made by our customers. Therefore, we’ve decided to add 9 new products to our standard, permanent distribution.
Our favourite subject is of course… packaging.
It’s our passion, job, reality and entertainment.
From dusk till dawn our Polpak team members dose, pack, send packaging and receive new inventory. We send e-mails, make phone calls and gossip about one thing only.
Total look, also known as mono look, is a timeless elegance. It applies not only to clothing or interior design elements in mono-colours, but also to cosmetic packaging. Monochromatic designs are chic and tasteful, no matter the trends or passing fads.
Dressing tables full of multicoloured bottles, dispensers, sprayers or jars may be charming, but to truly bring out elegance, they should match the interior.
The beginning of the year brought new recycling rules – what used to be three different recycling receptacles have now become six.
According to a survey conducted by Kantar TNS on behalf of the ProKarton Foundation, Poles are paying less attention to sorting waste.
For many of us summer is the most beautiful season. High temperatures, long days and sunny mornings power us up and boost us with energy for action. Vitamin D, the sunshine vitamin, charges our batteries for the rest of the year.
Every year in June we join the CosmeticBusiness trade fair in Munich and present our products to the industry members from the Western Europe.
We are living in a time when information appears in an instant and it circles the world even faster. We are flooded by news coming from each and every direction, some of which is so-called 'fake news', i.e. untrue information, the purpose of which is to be sensational, cause outrage, controversy or generate traffic to the website on which it was published. It is up to us to separate truth from falsehood, because official refutation either does
Let‘s meet us on CosmeticBusiness - International trade fair of cosmetics supplying industry in Munich, Germany.
This spring trade fair in Warsaw is an opportunity every year to meet our regular customers, to get to know new companies and to establish interesting business contacts. It gives us an opportunity to present our new products and the entire spectrum of ways in which they can be modified, something that is of vital importance to us!
Let’s meet at the trade show in Warsaw!
On 2nd and 3rd April, the Warsaw exhibition and trade centre EXPO XXI is hosting another annual Packaging Innovations event. Our team will be waiting for you in the Green Hall at stand A11.
Another spring is around the corner, and we are all taking off our heavy clothes to be able to enjoy the sun, which is getting warmer every day.
Does all packaging have the chance of a second life?
We would like to thank all our Clients and Partners for their trust and we sincerely wish you a happy Christmas with your family.
In response to the countless discussions and books that address the present condition of our natural environment, all kinds of measures and solutions that address the problem are proposed, some of which do not even require much effort and can be implemented by just about anyone.
Minimalist lifestyle: what does zero waste mean?
The pollution of our oceans, seas, rivers and forests is a topic that each of us encounters daily. Despite how much the issue is discussed, the countless conversations and conferences on it, it is still difficult to deal with it effectively. So, it is worth stressing how crucial it is that absolutely every single inhabitant of our planet is committed to tackling it. The every day choices and decisions of each individual not only have specific
Autumn is always a busy time in the packaging business, with numerous industry events to attend. This year is no different. Those interested in cosmetics packaging products and closures are in for a treat with a number of important events, where they will be able to see the latest and the most innovative developments in the field
A major part of it is plastic and unfortunately a lot of it is still stored in landfills. Recycling and ecology are recently one of the main topics discussed internationally, primarily because of the fact that waste production is a growing issue. How does that all relate to packaging products? Has the present situation been caused by plastics as such, or is the consumers' missing awareness to blame?
Packaging products suitable for pharmacy shelves
Protection, safety, hygiene of application – these are the essential features of a good packaging product
“Fine feathers make fine birds”, or fashion and trends in packaging design.
Have you checked out the new products in our permanent range yet?
Polpak Packaging invites you to CosmeticBusiness 2018!
Thank you for participating in Packaging Innovations fair!
Airless packaging solutions for special assignments.
We would like to invite you to the Packaging Innovations International Trade Show.
Airless packaging – calculating the print area.
We are expanding the range of products available on stock.
How to measure the dip tube length with a ruler – quickly and simply.
From the series: A little „know-how” – How to choose an optimum dosing mechanism for the product?
Big possibilities of a small packaging closure.
A little bit of 'know-how' - What kind of tube should be used in packaging?
Interesting application of closures and packaging in food industry.
Already in the second half of October new products will appear in regular distribution in Polpak Packaging. This time we are offering you two new models of trigger sprayers and one model of foam sprayer.
Danish Beauty Award 2017 - packaging and cosmetics nominated for an award!!!
Made for each other – how to choose the packaging for a cosmetic product?
Natural, ecological and innovative cosmetics – current trend in cosmetic industry.
Thank you for visiting Polpak Packaging at the Cosmetic Business fair!
New products from Polpak Packaging on Cosmetic Business fair 2017!