In June last year the European Commission announced it intended to withdraw the Green Claims Directive. A good number of people in this industry read the headline, concluded the crackdown on environmental marketing had been called off, and went back to writing whatever they liked. It has not been called off. A different law, already adopted and already on the books, does most of the same work, and it applies from 27 September 2026.
That law is the Empowering Consumers for the Green Transition Directive. It amends existing consumer protection rules rather than creating a new regime, which is precisely why it drew less attention and why it is much harder to stop.
What becomes unlawful in September
The substance is narrower than the headlines suggested and sharper than most suppliers realise. Generic environmental claims become prohibited where excellent environmental performance cannot be demonstrated, which covers a great deal of ordinary brand language. Sustainability labels not based on a certification scheme, or not established by a public authority, are out, so an in-house green badge invented by a marketing team no longer works. Claims about a whole product where the benefit concerns only one aspect are prohibited. So are claims of neutrality built on offsetting, and claims about future environmental performance without a detailed, realistic and independently verified plan behind them.
None of this is exotic, and Spain has not been waiting for it. The CNMC has already been acting against unsubstantiated environmental claims under existing unfair competition rules, which is worth knowing if you assume enforcement begins the day a directive applies. It does not. The directive mostly writes down, at EU level, a standard that national regulators had started applying anyway.
There is one point of confusion I would clear up, because I have heard it repeated in rooms full of people who should know better. The withdrawn proposal and the applying directive were never the same instrument doing the same job. The one that was shelved would have added a mandatory verification procedure before a claim could be made. The one that applies in September sets out what may be said. Losing the first makes substantiation less bureaucratic. It does not make a vague claim lawful.
We had to edit our own website
I say this because we were not clean either. Going through our own material, we found plenty that would not survive the test: the friendly compound adjectives everyone in this trade reaches for, green standing alone as though it were a measurement, sustainable doing the work of an argument in places where we had no evidence to put behind it. Removing them was uncomfortable, because the replacement sentence is always longer and colder. Organic cotton, GOTS certified, certificate number, expiry date, does not sing. It does survive scrutiny, and it is the only version I am willing to sign.
The harder discipline was deciding what to do with claims we believed but could not prove. We settled on marking them self-declared. It is a deflating label to put on your own product, and it is the difference between an opinion and a finding. After September that difference is legal rather than stylistic.
What it means for a school
Schools and organisations are rarely the party making the original claim, but they repeat it. A uniform policy, a newsletter to parents, a line on the website about the school's sustainable uniform. Those are the sentences that get quoted back when a supplier's evidence turns out to be a brochure, and it is the school standing in front of the parents at that point, not the supplier.
So the procurement question is not whether a supplier uses the right words. It is whether, for each claim, they can name the standard, the certificate, the test or the dataset behind it, and whether they will tell you plainly when there is none. A supplier who finds that request awkward in July is going to find September considerably harder.
Why I welcome it
For twenty years the reward in this trade has gone to whoever wrote the warmest sentence, because writing it cost nothing. Anyone doing the slow, expensive work of verifying a supply chain was competing against language, and language is cheaper. From September the language costs something. That is the first structural advantage evidence has been given in my working life, and my only complaint is that it took this long.