TEYING BUYER GUIDE · UPDATED OCTOBER 1, 2026

Green Claims You Can and Can't Make on EU Jewellery After 27 September 2026

EmpCo, Directive (EU) 2024/825, applies from 27 September 2026 and bans generic environmental wording, offsetting-based climate neutrality claims on products, and self-created sustainability labels. This sets out the claims that survive, with jewellery examples, and what the Green Claims Directive's withdrawal did and did not change.

By Qiu Qiu, Founder and Design Lead at TEYING · October 1, 2026

The short answer: specific beats impressive

Directive (EU) 2024/825, known as EmpCo, applies from 27 September 2026. It bans generic environmental words such as eco-friendly and sustainable unless they are specified in the same place, bans product-level climate neutrality claims built on offsetting, and bans sustainability labels a brand invents. What survives is the specific, checkable statement: a material, a figure, a standard, a document.

General guidance, not legal advice, and the enforcement position described here is stated as of October 2026. Enforcement sits with national consumer authorities, and the reading of a claim is judged from the average consumer's view rather than the brand's intention, so have the wording of a high-profile claim checked before it goes live.

What EmpCo is, and when it bites

Directive (EU) 2024/825 amends the Unfair Commercial Practices Directive and the Consumer Rights Directive to bring environmental claims inside consumer protection law. Member states had until 27 March 2026 to transpose it, and it applies from 27 September 2026. There is no transition period, and it reaches products already manufactured, distributed or on shelves.

Two details surprise brands. It covers brand names, trademarks, logos and visual presentation, not only product page copy, so a leafy badge in a logo lockup is in scope. And an unspecific claim cannot be rescued by a footnote, because the specification has to be clear and prominent on the same medium as the claim. If there is no room to specify it, the answer is to drop the claim rather than shrink the type.

The claims that are now prohibited

The fifth row is the one that catches jewellery most often, because metal content limits are legal requirements rather than features. Nickel release sits under REACH Annex XVII entry 27, at 0.5 µg/cm²/week for prolonged skin contact and 0.2 for items inserted into pierced ears. Lead is entry 63, at 0.05% by weight in any individual part of a jewellery article, and cadmium is entry 23, at 0.01%. Those numbers are the floor a piece has to clear. Marketing them as a differentiator is the practice the rules are aimed at.

The substance of a claim still needs evidence behind it, and the entry-level figures are set out in lead, cadmium and nickel limits for EU jewellery. When a supplier sends a test report, the buyer side of the check is straightforward: report number, issue date, testing laboratory, test method, the material tested, and the SKU or batch the report covers. A report that does not name the SKU it belongs to is not evidence for that SKU.

What the withdrawal of the Green Claims Directive changed

In June 2025 the Commission signalled it would withdraw the proposed Green Claims Directive, which would have required independent verification of environmental claims before they were used. The final trilogue scheduled for 23 June 2025 was cancelled, and the file has been on hold since, without being formally terminated.

What that leaves is a practical position rather than a legal vacuum. There is no pre-approval regime for every claim, no prescribed life-cycle assessment method, and no badge to buy. EmpCo is the binding text, and it still requires that a claim can be substantiated and that it is specific. Enforcement does not wait for the file to be revived: national consumer authorities act, and in several member states competitors and consumer organisations can pursue injunctions, with penalties in some countries set at a percentage of the related turnover.

One consequence is worth stating plainly. The withdrawal removed the cost of a formal verification step, not the obligation to hold the documents. A brand that keeps its test reports, material declarations and supplier statements in the order file is in a better position than one that relied on the proposal being dropped.

Rewriting the usual jewellery lines

The pattern in every row is the same: name the specific thing, then confirm it for the destination. A reader can verify "0.5 to 2.5 µm in 18K gold" against a plating specification. A reader cannot verify "sustainable".

How TEYING states it

The packaging option on our own pages is written as a materials list rather than a benefit. TEYING can build packaging around reduced-plastic materials: recycled paper boxes and cards, kraft or fabric pouches and paper-based inserts, with material options confirmed per project and destination market, since some regions require specific labelling or materials for retail.

Read that sentence as a template. It names materials, it makes no certification claim, and it ends by confirming the detail for the destination instead of promising it in advance. The same approach applies to material claims. Applicable testing and documentation are confirmed by material, destination market and order scope, and lead-free, nickel-free and cadmium-related requirements can be discussed before production rather than asserted on a product page.

If you are writing material or packaging copy for an EU launch, send the product type, the markets and the claim you want to make through the TEYING quote form. We will state the base material, finish and plating thickness per SKU so the wording you publish has a specification behind it.

FAQ

What counts as a generic environmental claim under EmpCo?

Words such as eco-friendly, green, environmentally friendly, climate friendly and sustainable are treated as generic. From 27 September 2026 they are banned unless the claim is specified clearly and prominently in the same place, or supported by recognised excellent environmental performance under a scheme such as the EU Ecolabel. If there is no room to specify it, do not make the claim.

Can I say my jewellery is carbon neutral?

Not at product level if the neutrality comes from offset credits outside the product's value chain. Claims that a product is neutral, reduced or positive in impact on that basis are prohibited outright, and the same applies to wording such as carbon positive or climate compensated. A claim based on the product's actual life-cycle impact is a different case, and it needs the data behind it.

Do I need a sustainability label for my packaging?

Only one issued by a certification scheme or a public authority. A leaf mark, a "green range" badge or a collection seal created in-house is prohibited, and holding a label does not protect the underlying claim, which still has to be specific and substantiated. The practical test is whether the scheme is independently monitored and publicly documented, and whether you can name it in the same sentence as the claim.

What happened to the Green Claims Directive?

The Commission signalled its withdrawal in June 2025, the final trilogue was cancelled that month, and the proposal has been on hold since without formal termination. EmpCo applies regardless, so the working requirement today is unchanged: every environmental claim has to be specific, checkable, and supported by a document the brand actually holds.