Green Claims and New Rules: What Changes from 27 September 2026

On 27 September 2026, new provisions on green claims will come into force in Italy, introduced by Legislative Decree of 20 February 2026, No. 30, transposing Directive (EU) 2024/825.

The topic was also at the centre of the seminar “Green Claims and the Empowering Directive: Regulatory Impacts and Corporate Compliance Strategies”, organised by Deloitte Legal as part of the “Law Takes a Coffee Break” series; we thank Dr. Michela Turra for the invitation and for the opportunity to discuss a subject that will become increasingly central for businesses.

The regulation amends the Consumer Code, strengthening the framework on unfair commercial practices in environmental communication. It applies to all companies that communicate environmental benefits of products, services or activities: not only advertising campaigns, but also packaging, labels, websites, e-commerce and social media posts. Any message capable of making consumers perceive an environmental advantage falls within its scope.

What Changes 

The main development is the end of generic claims: expressions such as “green”, “sustainable”, “eco-friendly” or “climate neutral” become risky unless they specify, with precision, what the benefit is and what it refers to.

A statement can be technically true and still be misleading if it implies more than the company can demonstrate. The scope must always be made explicit: if the benefit relates only to the packaging, it cannot appear to refer to the entire product; if it relates to one product line, it cannot be extended to the whole company.

Future commitments are also subject to specific rules. Targets such as “net zero” or “carbon neutral by 2030” are permitted only if accompanied by a verifiable plan with intermediate milestones, deadlines and periodic oversight by an independent third party. Statements based solely on emissions offsetting are not sufficient: offsetting is not the same as reducing impact across the product lifecycle.

Permitted and Non-Permitted Claims

Type
PermittedNot permitted
Climate impact / CO₂
Measured data using a certified method and documented offsets
“Zero impact”, “Carbon neutral” without full evidence
Generic claims
Verifiable percentages with evidence (e.g. 80% recycled, -20% consumption)
“Green”, “eco-friendly”, “sustainable” without data
Sustainability labels
Independent, recognised certifications with number and scope
Company self-created “green” labels
Comparisons
 Comparisons with declared methodology, products and up-to-date data
Comparisons without criteria or methodology
Future commitments
Commitments with a plan, measurable targets and deadlines
“Zero emissions by X” without a concrete plan.

 

Operational Implications

The core of the change is proof. Every environmental claim must be traceable to data, certifications and verifiable evidence. Non-compliance exposes companies to sanctions by the AGCM and to challenges under unfair commercial practices rules. Green claims can no longer be managed by marketing alone: they involve quality, supply chain, legal and compliance functions.

The period leading up to September 2026 should be used to map existing claims, identify the most exposed ones, and establish an internal verification process before publication.

Our support 

Analytical supports companies in verifying compliance with Directive (EU) 2024/825 and applicable regulations on green claims.

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