Labels and badges
Will your sustainability label or eco badge still be usable after 27 September 2026?
The new rule is not limited to well-known ecolabels. A trust mark, seal or badge created by a brand can itself fall within the definition of a sustainability label.
Updated 8 August 2026
Short answer
From 27 September 2026, displaying a sustainability label in B2C marketing is prohibited in all circumstances unless the label is established by public authorities or based on a certification scheme that meets the Directive’s requirements.
A certification scheme is more than a logo
Directive 2024/825 defines a certification scheme as a third-party verification scheme that certifies compliance with specific requirements and allows the use of a corresponding sustainability label.
The scheme’s terms and requirements must be publicly available, and compliance monitoring must be carried out by a competent and independent third party using appropriate procedures.
- Third-party verification.
- Publicly available scheme requirements.
- Appropriate monitoring of compliance.
- Independent and competent verification body.
- Transparent and non-discriminatory access conditions.
Self-created badges are the obvious risk area
A green leaf, “Eco choice” seal or “Planet approved” badge can function as a voluntary trust mark even if the brand never calls it a label. If it distinguishes a product or business by reference to environmental or social characteristics, it may meet the legal definition of a sustainability label.
Visual design therefore matters. Symbols and trust marks can communicate an environmental message without using a full sentence.
A valid label does not justify a broader claim than it certifies
Even a compliant certification scheme has a defined scope. It may relate to a product, one component, a process, a site or a business system.
Marketing should not turn a narrow certification into a broad statement of overall environmental superiority.
Old stock: there is no blanket exemption
The Directive does not create a general transition period beyond 27 September 2026 for packaging or stock printed under the old rules. In June 2026, CPC authorities published a common understanding supporting proportionate enforcement where genuine and specific transitional difficulties exist.
That enforcement approach should not be described as an automatic legal right to sell through non-compliant stock.
Quick label audit
- Who created the label?
- Who independently verifies compliance?
- Are the criteria publicly available?
- Is the verifier sufficiently independent and competent?
- What exactly does the label certify?
- Does the surrounding marketing promise more than the label itself?