From 27 September 2026, new European Union (EU) rules on consumer protection in the green transition began to apply under the timeline set out in Directive (EU) 2024/825. The new rules tighten the use of claims such as “green”, “eco-friendly”, “carbon neutral” and “net-zero”, while also introducing stricter requirements for sustainability labels, product durability and reparability.
For Vietnamese goods entering the EU market, these changes are worth noting because product packaging, labels, websites, e-commerce listings, certifications and environmental messages directed at EU consumers may all fall within the scope of the new rules.
Overview of Directive (EU) 2024/825
1. What does Directive (EU) 2024/825 change?
Directive (EU) 2024/825 was adopted by the European Parliament and the Council of the EU on 28 February 2024. Its purpose is to empower consumers in the green transition through better protection against unfair commercial practices and better information.
The Directive amends two key pieces of EU consumer protection legislation: Directive 2005/29/EC on unfair commercial practices and Directive 2011/83/EU on consumer rights.
EU Member States were required to transpose the Directive into national law by 27 March 2026 and apply the transposed rules from 27 September 2026. According to the European Commission, the new framework is intended to strengthen consumer protection against greenwashing, unreliable sustainability labels and certain practices that contribute to the early obsolescence of products.
The rules primarily regulate business-to-consumer (B2C) commercial practices in the EU. The Directive does not impose direct obligations on Vietnamese businesses merely because they manufacture or export products.
However, when Vietnamese goods are placed on the EU market and marketed to EU consumers, importers, distributors, retailers or businesses selling directly in the EU must ensure that commercial information complies with the applicable rules. As a result, requirements concerning labelling, evidence supporting environmental claims and product data may be passed down to Vietnamese suppliers through the supply chain.
Key changes relevant to goods entering the EU market
2. Products cannot simply be labeled as “green”
One of the most notable changes is stricter control over generic environmental claims.
An environmental claim can be understood as information or a form of commercial communication that states or implies that a product, service or business has environmentally beneficial characteristics or impacts.
Terms such as “environmentally friendly”, “eco-friendly”, “green”, “climate friendly”, “carbon friendly”, “biodegradable” and “biobased” cannot be used as generic claims unless the business can demonstrate recognised excellent environmental performance that is relevant to the claim being made.
This means that having an environmental report, using some recycled materials or implementing an energy-saving measure does not automatically justify describing an entire product as “green” or “eco-friendly”.
The EU also distinguishes between generic claims and more specific information. For example, the phrase “climate-friendly packaging” may be considered too generic. By contrast, a more specific statement such as “100% of the energy used to produce this packaging comes from renewable sources”, if properly substantiated and clearly presented, does not automatically fall within the prohibition on generic environmental claims.
Businesses should therefore keep one important principle in mind: the scope of a claim should correspond to the scope of the evidence supporting it. If only the packaging has been environmentally improved, this should not be presented in a way that gives the impression that the entire product is “green”.
3. “Carbon neutral” claims based on carbon credits: a key point to note
The new rules also directly affect how businesses communicate about carbon credits and emissions offsetting.
Under Directive (EU) 2024/825, a product must not be presented as having a neutral, reduced or positive impact on greenhouse gas emissions if that claim is based on greenhouse gas emissions offsetting.
Examples cited by the EU include “climate neutral”, “CO₂ neutral certified”, “carbon positive”, “climate net-zero”, “climate compensated” and “reduced climate impact”.
For example, a business cannot simply calculate the emissions associated with a product, purchase carbon credits from a project outside the value chain to offset those emissions, and then advertise the product as “carbon neutral”.
However, this does not mean that the EU prohibits businesses from purchasing carbon credits or investing in carbon projects.
Businesses may still transparently disclose the purchase or retirement of carbon credits or investments in emissions-reduction initiatives, provided that the communication does not lead consumers to believe that the product itself has become “carbon neutral” as a result of that offsetting activity.
The key distinction is between actual emissions reductions within the product’s life cycle and value chain and emissions offsetting through carbon credits generated outside the value chain.
4. A “net-zero 2040” commitment needs an implementation plan
The rules are not limited to product claims. Forward-looking environmental targets such as “net-zero by 2040”, “climate neutral by 2035” or “100% sustainable by 2030” also need to be considered carefully.
Claims relating to future environmental performance should be based on clear, objective, publicly available and verifiable commitments. Businesses should have a detailed and realistic implementation plan setting out measurable targets, timelines, resources and the key elements needed to achieve the commitment.
Progress must also be regularly verified by an independent third-party expert, and the verification results must be made available to consumers.
This means that “net-zero” messaging can no longer be treated simply as a marketing slogan. Such commitments need to be supported by data, a roadmap and a sufficiently clear monitoring mechanism.
5. Self-created “green” logos and labels also need to be reviewed
The new rules do not only cover wording; they also regulate sustainability labels.
In principle, a sustainability label must be based on a certification scheme that meets the requirements of the Directive or must be established by a competent public authority.
This is particularly relevant to labels such as “Eco Choice”, “Green Product” or “Planet Friendly” that are designed, assessed and applied by a business itself but may appear to consumers as though they were independently certified.
Businesses should also not assume that labels or certifications originating outside the EU can automatically be used as sustainability labels on the EU market. The certification mechanism, the independent assessment body and compliance with the relevant requirements should be examined carefully.
6. It is not only the wording on the packaging
The EU takes a relatively broad approach to the concept of an environmental claim. It can include not only direct advertising statements, but also images, symbols, labels, product names, brand names and the overall presentation of a product if these elements communicate an environmental benefit.
This does not mean that simply using the colour green, a leaf symbol or imagery of nature automatically constitutes a violation.
However, where these elements are combined with product names or wording in a way that leads consumers to believe that a product has significant environmental attributes, the overall message may be assessed as an environmental claim.
Businesses should therefore review not only the wording on labels, but also the overall way in which a product is presented to consumers.
7. The EU is also strengthening requirements on durability, reparability and guarantees
Directive (EU) 2024/825 does not focus solely on greenwashing. Another objective is to provide consumers with more information so they can choose products that are more durable and easier to repair.
Under the amended rules, sellers may be required, where relevant, to provide additional information on durability, reparability, the minimum period for software updates and guarantees.
From 27 September 2026, the EU also applies harmonised information tools relating to legal guarantees and commercial guarantees of durability.
For Vietnamese businesses selling directly to EU consumers through websites or e-commerce platforms, this is an area that deserves particular attention. For exporters selling through importers or retailers, EU partners may ask manufacturers to provide additional data so that they can fulfil their consumer information obligations.
8. Are existing stocks and previously printed packaging exempt?
A practical question is whether products or packaging manufactured before 27 September 2026 may continue to use existing claims.
According to the European Commission’s Q&A, there is no automatic exemption for old stock. The new rules on environmental claims and sustainability labels may also apply to products or packaging that were manufactured, ordered, distributed or placed on shelves before the application date.
Where existing information is no longer compliant, measures may be needed such as amending or covering wording on the packaging, applying supplementary labels or providing clarifying information at the point of sale.
Enforcement authorities may take into account proportionality and genuine transitional difficulties. Nevertheless, businesses are still expected to act proactively and in good faith to take the necessary steps towards compliance.
What should Vietnamese businesses consider when accessing the EU market?
9. What should Vietnamese businesses do?
Directive (EU) 2024/825 does not set out a separate list of obligations specifically for Vietnamese businesses. However, for companies whose products are sold or marketed to EU consumers, proactively reviewing product information may help them respond more effectively to the requirements of importers, distributors, retailers or e-commerce platforms in the EU market.
Key areas to review include:
- Product packaging and labels: check terms such as “green”, “eco”, “sustainable”, “environmentally friendly”, “carbon neutral”, “climate neutral” and “net-zero”;
- Websites, social media, catalogues and e-commerce listings: review wording, images, symbols and overall presentation;
- Labels and certifications: identify the certification mechanism, assessment body and basis for using the label in the EU market;
- Carbon claims: distinguish between actual emissions reductions within the value chain and emissions offsetting through carbon credits;
- Net-zero targets and other future environmental goals: review implementation plans, targets, timelines, resources and verification mechanisms;
- Old stock: identify existing product batches and packaging carrying claims that may need to be amended, covered or clarified;
- Product data: prepare information on durability, reparability, software updates and guarantees where required by partners or market rules;
- EU partner requirements: coordinate early with importers, distributors and retailers to agree on the information used in the destination market.
Before using an environmental claim, businesses may wish to ask three questions:
- What exactly does the claim say?
- What evidence supports it?
- Does the evidence match the way consumers are likely to understand the claim?
10. From “saying green” to “proving green”
Directive (EU) 2024/825 reflects an increasingly clear direction in EU green transition policy: an environmental claim must not only be appealing from a communications perspective; it also needs to be specific, substantiated and verifiable.
For Vietnamese businesses whose goods enter the EU market, this is not simply a matter of changing a few words on a package. Sustainability, environmental, marketing, legal, export and product management teams may need to work more closely together to ensure that environmental information provided to business partners or EU consumers is supported by appropriate data and documentation.
As environmental requirements become increasingly linked to trade and consumer protection, reliable data and the ability to substantiate claims are becoming important components of a company’s green competitiveness.
11. Stay Updated on the Green Transition with ESGreen
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