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Open your own store and count. The collection called Eco. The badge with the leaf on it that your developer added to four hundred product tiles. The line about bio-acetate being plant-based. The carbon-neutral shipping widget at checkout. The sustainability page with the ocean photograph.
Since 27 September 2026, most of that has been illegal to say to a European consumer — not “risky”, not “you should be able to substantiate it”, but listed by name in a schedule of practices that are unfair in all circumstances.
The date has passed. What follows is what bit, and what two documents published since we first wrote this have clarified about it.
What actually changed
Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive, had to be written into national law by 27 March 2026 and has applied since 27 September 2026. It is not a new standalone regulation. It edits two of the oldest and most-used instruments in European consumer law: the Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU).
That editing choice is the whole story, and it is the part the sustainability-consultancy coverage keeps burying.
The UCPD has an annex — Annex I, the “blacklist” — of commercial practices that are prohibited outright. For everything else in that directive, a regulator has to show that a practice was misleading and that it distorted the behaviour of the average consumer. For a blacklisted practice, nobody has to show anything. It is banned as such. EmpCo adds a series of new entries to that list, and five of them describe things that are currently sitting on eyewear product pages.
Point 4a — generic environmental claims. Banned: “making a generic environmental claim for which the trader is not able to demonstrate recognised excellent environmental performance relevant to the claim.”
The directive’s recitals give the word list, and it reads like an audit of the average eyewear store: environmentally friendly, eco-friendly, green, nature’s friend, ecological, environmentally correct, climate friendly, gentle on the environment, carbon friendly, energy efficient, biodegradable, biobased — “or similar statements that suggest or create the impression of excellent environmental performance.”
There are two ways out, and for frames the important one is the second.
Route one — recognised excellent environmental performance. This can be shown by compliance with the EU Ecolabel regulation, by an officially recognised EN ISO 14024 ecolabelling scheme in a member state, or by top-class performance for a specific environmental characteristic under other EU law, such as class A on an energy label.
The EU Ecolabel has no product group for eyewear. The scheme currently covers eleven groups — cleaning, clothing and textiles, coverings, electronic equipment, furniture and mattresses, gardening, tourist accommodation, lubricants, paints and varnishes, paper, and personal and animal care products. Nothing optical. So that door is shut for frames, and a brand that wants to try a national Type I scheme instead should check that scheme’s own product-group list before assuming it is open either.
But here is the part that closes route one for almost everybody, and it comes straight from the directive’s own recitals: a trader “should not make a generic claim such as ‘conscious’, ‘sustainable’ or ‘responsible’ based exclusively on recognised excellent environmental performance, because such claims relate to other characteristics in addition to environmental characteristics, such as social characteristics.” Those three words are the vocabulary of contemporary eyewear marketing, and no certification fixes them, because they are not purely environmental words. They are a claim about how a company behaves.
Route two — say what you actually mean, in the same place. If the specification is given “in clear and prominent terms on the same medium — such as the same advertising spot, the product’s packaging or online selling interface” — it is not a generic claim at all. The directive’s own worked example: “climate-friendly packaging” is generic; “100% of energy used to produce this packaging comes from renewable sources” is specific.
“On the same medium” is doing real work. A qualifier behind a link, a tooltip or a QR code does not satisfy it. The specification has to be where the claim is.
Point 4b — a benefit for one aspect, sold as a benefit for the whole thing. Banned: claiming an environmental or social benefit for the product, or for the trader’s business as a whole, when it actually concerns only a particular aspect of the product or of the business.
This is the entry nobody in this category has thought about, and it is the one that best describes what eyewear brands actually do. Recycled acetate in the front, virgin metal in the temples and hinges, a virgin poly mailer, and a product page that reads as though the whole object were a sustainability story. A brand with one recycled component and a green homepage is exactly the fact pattern this point was drafted for.
Point 2a — sustainability labels you made yourself. Banned: “displaying a sustainability label that is not based on a certification scheme or not established by public authorities.”
The green badge, the leaf icon, the “Eco Choice” ribbon on the collection tile — if you made it up yourself, it goes. A permitted label rests on a third-party certification scheme or is established by a public authority. An internal marketing asset is neither.
Point 4c — neutrality bought with offsets. Banned: “claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.”
Note the shape of it precisely, because the scope is narrower than the summaries suggest: it is about greenhouse gas emissions, and it is about offsetting as the basis of the claim. This is the one that will cost the most stores the most money anyway, because carbon-neutral shipping is a widget almost every direct-to-consumer eyewear brand installed and then forgot about. You can still say what you have actually reduced in your own operations and value chain. You cannot describe the product or the delivery as neutral because a certificate was purchased.
Point 10a — presenting a legal requirement as a distinctive feature. Banned: “presenting requirements imposed by law on all products within the relevant product category on the Union market as a distinctive feature of the trader’s offer.”
This one is quietly aimed straight at sunglasses. UV protection to the relevant standard is not a feature of your sunglasses; it is a condition of them being sold at all in Europe, where non-prescription sunglasses are personal protective equipment under Regulation (EU) 2016/425 — category I, harmonised standard EN ISO 12312-1, CE marking mandatory. Marketing mandatory UV400 filtering as though it were a differentiator is now a blacklist item, and it is on a very large number of listings.
The Commission updated its Q&A, and three answers change what you should do
On 18 May 2026 the Commission published an updated Questions and Answers document on this directive. Three of its answers matter more to an online eyewear store than anything else published this year — and two of them are softer than what we originally wrote here, which is worth saying out loud rather than quietly editing.
One: an image on its own is not a generic environmental claim. The Q&A states that “implicit claims (colours or images) on their own, without written or spoken text, cannot be considered generic environmental claims.” That is narrower than the alarm most coverage raised, and narrower than our own first pass implied. But read the next part before you relax: traders “should be mindful that certain visual elements, such as green leaves, water drops, or similar nature-related icons, may be interpreted by consumers as implicit environmental claims, that in combination with a claim made in written form or with a logo… could be subject to the requirements.”
The practical rule for a product tile: a leaf on its own is probably not a claim. A leaf sitting next to the word “Eco” is the claim, and the leaf is part of it. Almost nobody ships the icon without the word.
Two: a name is assessed in context, against the average consumer. The Q&A says using terms like “green” or “eco” in a brand, product or company name “does not automatically constitute an environmental claim… where, in the relevant commercial context, those terms or colours are unlikely to lead the average consumer to expect environmental benefit.” The test it applies is whether “the presentation is likely to lead the average consumer to believe the product or brand has a positive or zero impact on the environment.”
So a long-established house name is not automatically fatal. But “EcoLine Bio-Acetate Round — Sustainable Tortoise” is not a house name being assessed in context. It is a claim wearing a product title. The concession is real and it is narrow, and it will not carry a range that was named last season to sell an environmental story.
Three — and this is the one that settles the feed problem below. On what to do when there is no room for the qualifier, the Q&A is flat: “If there is no space to specify the environmental claim, then the claim should generally not be made.”
That sentence is worth more than any amount of advice about how to compress a disclaimer. There is no shortened form, no asterisk, no link-out. If the surface will not hold the specification, the claim comes off the surface.
The problem nobody had thought about: your product feed
Auditing a website is a finite job. Auditing a feed is not, and this is where the operational pain actually lands.
Your Google Shopping feed, your Meta catalogue and your marketplace exports pull titles, descriptions and attributes automatically. A product titled “EcoLine Bio-Acetate Round — Sustainable Tortoise” carries a generic environmental claim into three channels that have no room for a clear and prominent qualifier and no field designed to hold one. Fix the site and the claim keeps going out anyway, in a rendering you do not control.
The Commission has now answered what to do about that, and the answer is not “shorten it”. If the channel has no space for the specification, the claim should not be made in that channel. For a product feed that means the word comes out of the title and the structured attributes, not just out of the body copy on your own site. Which means renaming products, which means touching SKUs, which is exactly the kind of job that takes four weeks rather than an afternoon. The 27th did not move, and it has now gone.
The part that isn’t about claims at all
EmpCo also amends the Consumer Rights Directive, which means new pre-contractual information duties — the things a consumer must be told before they buy, on the product page.
Where the producer makes them available, you must inform consumers about the availability and cost of spare parts, about a repairability score where harmonised EU requirements produce one, and about the minimum period for which software updates will be provided.
For a plain acetate frame this is smaller than it sounds and more interesting than it looks. Temples, screws, nose pads and hinges are spare parts, and telling a customer that a frame can be re-hinged rather than replaced is a durability claim you are allowed to make and probably should. For the connected end of a catalogue — audio frames, smart eyewear, anything with firmware — the software update period is now a mandatory disclosure. Notice how many places that one number has to appear: it is the support period the Cyber Resilience Act makes you maintain, it is part of what the EU Data Act makes you disclose before the contract, and it is what the new Product Liability Directive can hold against you afterwards. Three regimes, one figure, and it comes from your supplier. If they will not commit to it in writing, you have a problem that is now visible on the product page rather than buried in a contract.
And there is a second half of the Consumer Rights Directive limb, which most coverage of this directive leaves out — including, until recently, ours. The same amendments insert a new Article 22a, and under it two pieces of prescribed EU artwork became mandatory on the same date, 27 September 2026: a harmonised notice about the legal guarantee of conformity, which every trader selling goods to consumers in the EU has to give, and the GARAN label for a producer’s commercial guarantee of durability, which is subject to four cumulative conditions an optical store will usually fail the moment it fits lenses. The designs are fixed by Commission Implementing Regulation (EU) 2025/1960. It is a separate job from anything on this page, and we gave it its own piece: the guarantee notice, the GARAN label, and why the label will not fit a glazed pair. If you spent this month only fixing the claims on your product pages, you did half of one directive.
Old stock: there is a concession, and it was not written for you
In June 2026 the Consumer Protection Cooperation (CPC) Network published a Common Understanding on “old stock situations” — products or packaging displaying environmental claims or sustainability labels “which were manufactured, ordered, distributed or placed on retailers’ shelves before the ECGT application date, namely 27 September 2026”.
Read it in the order it is written, because the order is the point.
It opens by refusing the premise: “Old stock situations do not exempt traders from complying with the new ECGT rules”. It then allows discretion — authorities “may take a phased approach where old stock situations give rise to genuine and specific transitional difficulties” — and declines to put a clock on it: “The exact duration of such transitional period cannot be determined as it may depend on specific circumstances”. And it is careful about what it is: the document “does not constitute a formal position of the CPC network or a legally binding interpretation of the ECGT Directive”, but sets out principles that authorities “are expected to consider when exercising their enforcement powers”.
Now the sentence that decides whether any of this helps you. The document distinguishes online claims from offline ones on the footing that online claims “do not face the same challenges as offline claims”.
That is the whole logic of an old-stock concession, stated plainly. Ink printed on ten thousand cartons in March cannot be recalled in September. A line of copy on a product page can be changed this afternoon, and everybody knows it. An online eyewear store is the trader this concession was least written for — and the parts of your operation it might actually reach, the printed case insert and the branded mailer, are the cheapest parts to reprint.
So: a genuine, sourced concession exists. It is not law, it has no end date, and it points away from the surface where you sell.
Who this reaches
The directive covers commercial practices relevant to consumers in the single market regardless of where the trader or the product comes from. A store in Ohio shipping frames to Lisbon is inside it. This is the same extraterritorial pattern as GPSR, PPWR and the rest of the European cluster, and the answer is the same: the market you sell into sets the rules, not the market you sit in.
Penalties are set nationally, with coordinated cross-border enforcement able to reach up to 4% of annual turnover in the member state or states concerned, and national law can go higher. That 4% is the coordinated-enforcement ceiling rather than a universal tariff, so do not quote it as your exposure — check the transposing law where you sell. Because these are UCPD breaches, they also fall inside the collective redress machinery of the Representative Actions Directive — a consumer organisation can bring them on behalf of a class, which is a materially different threat model from a regulator writing you a letter.
The honest open question: is “bio-acetate” a claim?
We are not going to pretend this is settled.
A statement of what a material is made from is a factual product description. “Cellulose acetate produced with plant-based plasticisers” is a specification. The trouble starts at the adjective and at the implication: bio, plant-based, natural and biodegradable attached to a frame that will not biodegrade in any bin a customer has access to are doing persuasive work that the underlying material may not support. Note that biodegradable and biobased are both named in the directive’s own list of generic claims, which narrows the argument considerably.
The nearest thing to a warning shot came from the UK. On 24 June 2026 the Advertising Standards Authority upheld complaints against adidas, Uniqlo and Calvin Klein over recycled-content claims in fashion advertising. The Uniqlo ruling is the instructive one for eyewear: a “Recycled Materials” label on a garment was read as an absolute claim — the consumer takes it to mean the whole thing — and evidence that the products contained some recycled material did not save it. Britain is outside the EU and the ASA is not a EU regulator, but the reasoning is the same reasoning EmpCo has now written into the blacklist as point 4b, and it was applied to exactly the kind of part-recycled product an eyewear brand sells.
Our reading is that the composition statement survives and the eco-framing around it does not, and that a brand which describes the material precisely and drops the halo will be fine. But no regulator has ruled on eyewear specifically, and anyone telling you otherwise is guessing. Get the exact wording from someone who will put their name on it.
What to do now
Run a word search on your own store. Sustainable, conscious, responsible, eco, green, environmentally friendly, climate neutral, carbon neutral, planet, ocean, natural, biodegradable, biobased, plant-based. Product titles, collection names, meta descriptions, image alt text, image overlays, email templates. Most stores are surprised by the count.
Kill or qualify — and put the qualifier in the same place. Either delete the word or say the specific thing next to it. “Frames made from 62% recycled acetate offcuts” is a better sentence than “sustainable frames” in every way, including commercially. Where the surface has no room for the specification, the Commission’s answer is that the claim should not be made there at all.
Check whether your claim is about one part or the whole product. If the recycled content is in the front and the temples are virgin, say so. A whole-product story built on one component is its own blacklist entry now.
Delete the badges you invented. If nobody certified it, it is not a label, it is a graphic, and it is now a blacklist item. An icon with no words next to it is a narrower problem than we first wrote — but an icon with a word next to it is the claim.
Turn off offset-based neutrality language. Keep the offsetting programme if you believe in it. Stop describing its output as neutral.
Take mandatory UV protection out of your feature bullets. Describe the lens category and the standard as a specification, not as a reason your sunglasses are special.
Add the durability information. Spare parts and their cost, repairability where a score exists, software update period for anything connected. This is a product-page content job, not a legal one.
Put up the guarantee notice. It was due on the same day and it is not optional. See the separate piece linked above.
Fix the feed last and check it first. Whatever you change on site, re-export and read the feed with your own eyes.
Where none of this reaches
Step back and notice which half of an eyewear store this lands on.
Every item above attaches to how the frame is described — the adjective, the badge, the collection name, the shipping widget, the feed attribute. The European regimes we have written about all year do the same thing from other directions: GPSR attaches to the imported object, PPWR to the box it ships in, the Cyber Resilience Act to the firmware inside it, the new Product Liability Directive to what happens when it hurts somebody.
The prescription step makes no environmental assertion at all. Sphere, cylinder, axis, add, PD; single vision or progressive; index, coating, tint. It is a specification a customer fills in about their own eyes. There is no claim in it to substantiate, no badge to certify, no offset to disclaim — and it is the step that decides whether the order is £95 or £280.
There is a version of this autumn that is spent deleting the word “sustainable” from four hundred products and replacing it with nothing, which leaves a store that has lost its differentiation and gained no revenue. There is another version that does the deletion in an afternoon, says something specific and true instead, and spends the rest of the quarter making the configuration step work properly. The second one is the one that pays for itself.
Frequently asked questions
Does this apply to me if I’m not in the EU?
Yes, if you sell to consumers in the EU. The directive covers practices relevant to consumers in the single market regardless of where the trader is established.
Is it a directive or a regulation? Does that matter?
It is a directive, which matters a great deal. It had to be transposed into twenty-seven national laws by 27 March 2026 and has applied since 27 September 2026, but the penalties, the enforcement bodies and some of the detail are national. Some member states were late. Do not assume one country’s guidance is the whole picture.
Can I still say “recycled”?
Yes. A specific, substantiated, verifiable claim about actual recycled content is exactly what the directive wants instead of the generic ones. Be able to prove the percentage and say what it applies to — the frame, the temples, the case, or the mailer. Saying which part is not a nicety; claiming a whole-product benefit on the strength of one component is separately blacklisted.
Can I still say “sustainable” if I get certified?
Probably not. The directive’s recitals single out “conscious”, “sustainable” and “responsible” as claims that cannot rest on recognised excellent environmental performance alone, because they reach beyond environmental characteristics into social ones. Certification does not rescue those words.
What about “carbon neutral shipping”?
If the neutrality rests on offsetting, no. Claiming a neutral, reduced or positive impact in terms of greenhouse gas emissions on the basis of offsetting is blacklisted.
Do I need to remove the leaf icon from my site?
This is narrower than we first wrote it, and the Commission’s updated Q&A is the reason. An image or colour on its own, with no written or spoken text, cannot be a generic environmental claim. But a nature-related icon in combination with a written claim or a logo can be part of one, and if the thing functions as a sustainability label without a certification scheme or public authority behind it, that is a separate blacklist entry regardless. In practice the leaf almost never travels alone on a product tile. Look at what is beside it.
Do I have to rename my “Eco” range?
Probably, though not automatically. The Q&A says an environmental term in a brand, product or company name is not automatically a claim where, in context, it is unlikely to lead the average consumer to expect an environmental benefit. That protects an established house name better than it protects a range named to sell a green story last season. And if the name travels into a feed with no room for a qualifier, the Commission’s position is that the claim should not be made there.
Is there a grace period for existing stock and packaging?
There is a concession, it is real, and it was not written for an online store. The CPC Network’s June 2026 Common Understanding on old stock says outright that old stock does not exempt traders, allows authorities a phased approach for genuine transitional difficulties, sets no end date, and is expressly not binding. It also distinguishes online claims on the ground that they “do not face the same challenges as offline claims”. Printed cartons may get some latitude. Your product pages will not — they can be changed this afternoon, and that is precisely the reasoning.
Is this the whole of Directive (EU) 2024/825?
No, and that is worth saying plainly. The directive amends two instruments. Everything above is the Unfair Commercial Practices limb plus the spare-parts and software-update duties. The other limb inserts Article 22a into the Consumer Rights Directive and makes the harmonised guarantee notice and the GARAN durability label mandatory. Both halves landed on 27 September 2026.
Didn’t the EU drop its green claims rules?
That headline is about a different instrument, and it is the most common misunderstanding in this area right now. The Green Claims Directive — a separate proposal about how environmental claims must be substantiated and verified — never became law. In June 2025 the Commission announced its intention to withdraw the proposal, that withdrawal has still not been formally completed, and lawyers disagree about whether it can be, given that Parliament and Council had already taken first-reading positions. None of that touches EmpCo, which was adopted in 2024, is in force, and has applied since 27 September 2026. The rules that bind you are these ones. A merchant who reads “the EU dropped its green claims rules” and does nothing has read about the wrong directive.
This article is general information about regulatory developments as they stood on 27 September 2026, not legal advice, and it does not describe VisioncarePro’s own compliance status. Rules of this kind apply differently depending on your catalogue, your suppliers and where you sell. The Commission’s Q&A and the CPC Network’s Common Understanding are guidance documents, and the Common Understanding states in terms that it is not a legally binding interpretation; neither displaces national transposing law. Take advice on your own position before acting.
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Sources: Directive (EU) 2024/825 of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU, Annex and recitals 9 and 10 (EUR-Lex, OJ L, 2024/825) · European Commission, Questions and Answers on the Directive on empowering consumers for the green transition, updated 18 May 2026 (Q2, Q3, Q4 and Q5) · Consumer Protection Cooperation Network, Common understanding on old stock situations, June 2026 · European Commission, EU Ecolabel product groups and criteria · Regulation (EU) 2016/425 on personal protective equipment; EN ISO 12312-1:2022 · Commission Implementing Regulation (EU) 2025/1960 · ASA rulings A26-1327727 (Uniqlo (UK) Ltd) and A26-1327724 (Calvin Klein Europe BV), upheld 24 June 2026 · Latham & Watkins, “European Commission Announces Intention to Withdraw EU Green Claims Directive Proposal” · Cooley, “Empowering Consumers for the Green Transition Directive: check your sustainability claims and warranty information” (16 March 2026) · Irish Department of Enterprise, Tourism and Employment, guidance page on Directive (EU) 2024/825 · Freeths, “ASA cracks down on recycled claims: key lessons for fashion retailers” (2026) · Stevens & Bolton, “ASA cracks down on greenwashing in fashion advertising”.
