Eco-Labels and Green Claims on Imported Goods in the EU, UK and Australia

Clorox's GLAD bags in Australia said they were made with 50% ocean plastic. The plastic actually came from communities without formal waste collection up to 50 kilometres from a shoreline, and the back of the pack said something close to that. The Federal Court still ordered an $8.25 million penalty in April 2025, because a true sentence in the fine print doesn't fix a misleading headline on the front (ACCC v Clorox Australia [2025] FCA 357, read via Moray & Agnew (opens in a new tab)).

That case is the whole topic in one picture. Green claims aren't a certificate you buy, they're words you're legally responsible for. This guide is in our certifications and compliance hub, with one half for the importer who prints the claim and one for the Indian exporter who has to prove it.

1. Claims, Labels and Certificates Are Three Different Things

• A claim is any message that a product is better for the environment - "biodegradable", "made with recycled cotton", "plastic-free".
• A label is a logo or mark that says the same thing visually.
• A certificate is a third party's statement that something was checked against a standard. GOTS, GRS, FSC and the EU Ecolabel are certification schemes.

A certificate can support a claim, but only the claim it covers. A GRS scope certificate proves recycled content was tracked, not that the product is "sustainable". We cover the textile schemes on textile certifications and timber on FSC and PEFC.

2. The EU Rules From 27 September 2026

Directive (EU) 2024/825 amends the EU's unfair commercial practices law and applies across the EU from 27 September 2026 (member states had until 27 March 2026 to write it into national law, and Italy, for one, did it through Legislative Decree 30/2026). It covers business to consumer sales. The main bans, read via Coslaw's summary (opens in a new tab) since EUR-Lex blocked our reader -

• Generic claims like "eco", "green", "environmentally friendly" or "climate friendly" without recognised excellent environmental performance relevant to the claim.
• Sustainability labels not based on a certification scheme or set by public authorities.
• Whole-product claims when the benefit covers only one part ("recycled packaging" is fine, "recycled product" is not if only the box is).
• Offset-based climate claims that a product has a neutral, reduced or positive impact because credits were bought. Our carbon guide explains why.

A separate Green Claims Directive was proposed to set out how claims must be checked before use. It stalled in 2025, and we couldn't confirm its status on 17 October 2026, so treat it as not in force and check with your adviser.

The EU Ecolabel (the flower) counts as recognised excellent performance where the product group has criteria. It's awarded by the competent body of an EU member state, and non-EU producers apply to the body in a country where the product is or will be sold. We couldn't read the Commission's application page in full, so check the current product groups and fees on the EU Ecolabel site (opens in a new tab).

3. The UK and Australia

The UK

The CMA's Green Claims Code has six principles. Claims must be truthful and accurate, clear and unambiguous, must not omit or hide important information, must make fair and meaningful comparisons, must consider the full life cycle, and must be substantiated (GOV.UK (opens in a new tab)). Since 6 April 2025 the Digital Markets, Competition and Consumers Act lets the CMA decide breaches and fine directly, up to 10% of global turnover, without going to court first (read via KPMG (opens in a new tab)). Nobody expects maximum fines for a swing tag, but the power is real.

Australia

Australia uses general consumer law against misleading conduct, and the ACCC has made greenwashing an enforcement priority. The Clorox case shows the test - the overall impression of the front of the pack. New Zealand's Commerce Commission applies the Fair Trading Act in the same spirit.

The UAE, US and others

The US relies on the FTC's Green Guides, and the UAE on general consumer protection. Neither has a rule as sharp as the EU's list. If you sell into several markets then write to the strictest one, which today is the EU.

4. What an Importer Should Check

You're the seller to the consumer, so you carry the claim. Here's the order of work.

1. Before artwork. List every green word, logo and number on the product, swing tag, carton and listing. Most brands are surprised how many there are.
2. Match each to evidence. For each claim, name the document - a certificate, a test report, a lab result, a footprint. If there's no document then the claim comes off. "Biodegradable" needs a test to a named standard under named conditions, not a supplier's word.
3. Check certificates are real. GOTS, GRS, OEKO-TEX and FSC have public databases. Look up the licence number and check the scope covers your exact product and your supplier's site.
4. Check the logo is permitted. Certification logos come with use rules. Many need the licence number printed next to them, and some need a transaction certificate per shipment.
5. Rewrite vague words as specific facts. "Made with 60% recycled polyester (GRS certified)" is defensible. "Eco tee" isn't.
6. Keep the file. Store the evidence by SKU for as long as the product is on sale.

Red flags from suppliers - a homemade "eco" logo, "biodegradable" on a plastic polybag, a certificate in the factory's name that doesn't cover the product, or "100% organic" on a blend.

5. How an Indian Exporter Supports a Buyer's Claims

Most Indian factories don't make the claim, they supply the proof. These steps work for any product.

Step 1 - Ask the buyer which claims it plans to print. Get the exact wording in writing at sampling stage. A day's wait for the answer saves a re-print.

Step 2 - Map claims to evidence you already have. Organic and recycled content need scope and transaction certificates. Recycled packaging needs your packaging supplier's declaration. Chemical claims need test reports from an accredited lab (NABL-accredited labs in India can be searched on nabl-india.org (opens in a new tab)). Allow one to two days.

Step 3 - Fill the gaps or drop the claim. If a claim needs a certificate you don't hold then tell the buyer early. Getting GOTS or GRS takes months, which we cover in getting GOTS, OEKO-TEX and GRS certified.

Step 4 - If the buyer wants the EU Ecolabel. Check whether criteria exist for your product group (textiles, footwear and several household goods have them). The application usually goes to a member-state competent body, often through the brand. Expect test reports, supplier declarations and an assessment that can take several months.

Step 5 - Don't print what you can't prove. Indian printers will happily add a leaf icon "for the look". Brief them that no green mark goes on artwork without the buyer's written approval.

Step 6 - Send an evidence pack with the first shipment. One PDF per SKU with each claim, its document and the document's validity date. Buyers' compliance teams love this, and it puts your factory ahead of the others on their list.

Step 7 - Renew on time. Certificates lapse, test reports age. Track expiry dates and send updates before the buyer asks.

Chasing certificates from four tiers of a supply chain is slow work. SourcingSync (opens in a new tab) can manage that verification for buyers.

6. A Worked Example

This example is an illustration built from the rules above, not a real firm.

A German homeware brand buys jute shopping bags from Kolkata. The draft artwork says "Eco bag, 100% natural, biodegradable, plastic-free packaging".

Under the new EU rules, "Eco bag" goes, since there's no recognised excellent performance behind it. "100% natural" needs checking because the bag has a laminated inner coating, so it becomes "Jute outer, laminated inner". "Biodegradable" goes, because nobody tested it to a standard. "Plastic-free packaging" stays only after the exporter confirms the inner polybag has been replaced with paper and sends its packaging supplier's declaration.

The final tag is shorter and less exciting, and every word on it is true. More on the product in our jute bags guide, and on the packaging side in EPR for packaging.

FAQ

Next Steps

• List every green claim on your product and match each to a document.
• Check certificate numbers in the scheme's public database.
• See textile certifications for what each textile mark proves.
• Read carbon footprints and credits before any climate claim.
• Plan for the digital product passport, which will carry some claims as data.