The EU’s consumer law reform has moved from the Omnibus Directive (EU) 2019/2161, applicable since 28 May 2022, to the Empowering Consumers for the Green Transition Directive (EU) 2024/825, which will apply from 27 September 2026. While Omnibus focused on pricing, online marketplaces and digital transparency, the next phase targets environmental marketing, green claims and product transparency.
For businesses, this means compliance is no longer only about how products are sold, but also about what is claimed, how those claims are substantiated and whether internal processes can withstand scrutiny. Consumer transparency, sustainability messaging and product-related claims should now be treated as one compliance agenda.
Environmental claims and labels will require a much higher level of substantiation
One of the biggest changes is the stricter approach to environmental marketing. Generic claims such as “eco-friendly”, “green” or “climate neutral” will be high-risk unless they are clearly specified and supported by recognized evidence. Businesses should therefore review claims used on packaging, websites, advertising, product names and even trademarks, and remove or revise those that are too broad, aspirational or weakly substantiated.
The same applies to sustainability labels. Labels that are not based on recognized certification schemes or public authorities will face much closer scrutiny, so self-created badges and vague visual sustainability cues should be assessed with particular care.
Pricing and online sales practices transparency remain core compliance issues
Even as attention shifts to green claims, existing Omnibus obligations remain important. Pricing transparency continues to be actively enforced, especially where discounts are advertised without properly identifying the lowest price applied during the previous 30 days.
Online sales practices also remain in scope. Marketplaces and digital sellers must be transparent about whether the seller is a trader or a private individual, how rankings are determined, whether reviews are verified and whether personalized pricing is used. Regulators increasingly assess these practices together rather than as separate issues.
Durability and repairability of products are moving to the forefront
Another clear shift is the stronger focus on durability and repairability. Businesses should review product information, warranty communication and after-sales messaging together, and ensure that claims about lifespan, long-lasting performance, spare parts and repair options reflect the product’s actual characteristics.
The rules also look beyond marketing language to product design choices that may affect lifespan or repairability. Companies should be transparent about relevant limitations, including software updates, functionality restrictions and design features that may shorten useful life or limit repair.
Internal governance will be just as important as external messaging
Compliance will depend not only on consumer-facing wording but also on what happens behind the scenes. Marketing, legal and product teams need shared processes for approving claims, campaigns and product messaging.
Enforcement risk is also a practical business issue. Cross-border enforcement and consumer claims remain central to the EU approach, and serious infringements may lead to significant penalties. Businesses active in several EU markets should aim for a consistent compliance model rather than fragmented local fixes.
About packaging claims, where PPWR meets EmpCo
A brief note should also be made about the PPWR, which is not part of the Omnibus or Empowering Consumers framework, but in practice the regimes overlap. PPWR governs packaging design and labelling requirements, while consumer law governs how packaging-related claims are communicated. Any environmental statement, recycling symbol or sustainability message should therefore be reviewed from both a product-regulatory and a consumer-protection perspective.
Key takeaways
The key message is that consumer protection and sustainability compliance are now closely intertwined. Our advice to businesses navigating this evolving regulatory landscape is not to panic but to prepare in a structured and timely manner. In particular, businesses should maintain a clear documentation trail showing how claims were substantiated and approved. Companies that start now by auditing claims, reviewing labels, aligning pricing and online practices, and strengthening internal approval and documentation processes will not only mitigate legal risk but also build consumer trust in an increasingly scrutiny-driven market.