Review environmental claims before advertising in the EU

Review environmental claims that appear in your campaigns, product information, and landing pages. In particular, pay attention to the following types of claims:

If you advertise in the European Union, review environmental claims across your full campaign experience, including:

• Product feeds

• Product titles and descriptions

• Badges and sustainability labels

• Ad copy and creative assets

• Landing pages

• Claims generated or adapted through advertising tools

Review campaigns targeting European Union markets even when your business is based outside the European Union. The Directive does not itself extend to non-European Union markets, but campaigns shown to people in the European Union may be in scope.

Understand your responsibility as an advertiser

You are responsible for the environmental claims associated with your products and business, including the evidence supporting those claims.

If you work with an agency, review the claims and supporting evidence together. Agencies can help identify claims across feeds, campaigns, and creative assets, but the advertiser remains responsible for substantiation.

Criteo’s advertising guidelines already require advertising to comply with applicable law. Criteo does not replace your legal review of individual claims.

If Commerce Growth, GO Campaigns or another advertising workflow generates or adapts consumer-facing copy from your product feed, instructions, or other content, review the final version before publication.

Make sure that:

• Environmental claims in the final copy match claims you have approved.

• Each claim is supported by appropriate evidence.

• The claim does not become broader or more general than the original product information.

• Any unsupported claim is edited or removed before the ad runs.

You can use available previews and instructions to shape generated copy. If a generated variation contains a claim you cannot support, do not publish it.

Use this checklist to prepare:

1. Identify your environmental claims. Search your product feeds, titles, descriptions, badges, creatives, and landing pages for environmental or sustainability-related language.

2. Check the evidence. Confirm that each claim has a documented basis and that the evidence supports the exact wording used.

3. Review broad claims. Give additional attention to terms such as “green,” “eco-friendly,” “sustainable,” and “climate neutral.”

4. Check environmental labels. Confirm that labels are connected to a public-authority scheme or a compliant certification scheme.

5. Review carbon-related claims. Check whether claims about climate impact or greenhouse gases rely on carbon offsetting.

6. Review future commitments. Confirm that commitments such as “net zero by 2030” have a detailed, realistic, measurable, and verifiable implementation plan.

7. Check the scope of each claim. Make sure a benefit relating to one material, component, process, or product feature is not presented as a benefit of the entire product or business.

8. Review AI-assisted variations. Check any copy generated or adapted from your product information before it is published.

9. Update or remove unsupported claims. Do not use a claim if you cannot substantiate it for the market where the campaign runs.

10. Confirm your European Union campaigns. Include campaigns targeting European Union markets, regardless of where your business is based.

Does this mean you cannot use “sustainable” or “eco-friendly”?

No. The Directive does not prohibit environmental marketing as a category.

The practical requirement is that claims must be accurate, specific, and supported by appropriate evidence. Generic claims without a clear basis may create compliance concerns, particularly when they imply a broad environmental benefit.

Can you use claims based on carbon offsetting?

Claims that a product or service is “climate neutral,” or that it has a reduced or positive greenhouse-gas impact, may be prohibited when that conclusion is based on carbon offsetting rather than the product’s own footprint.

Ask your legal counsel to review the wording, evidence, and basis for any carbon-related claim before using it in an advertisement.

Can you use future commitments such as “net zero by 2030”?

A future environmental commitment should be supported by a detailed, realistic, measurable, and verifiable implementation plan.

A statement without a documented plan behind it may not meet the requirements that apply from September 27, 2026. Consult your legal counsel about the requirements for your specific commitment and target market.

The EmpCo Directive is implemented and enforced through national consumer-protection rules. Enforcement details may vary by country.

Potential consequences can include:

• Orders to stop or correct a practice

• Consumer remedies

• Fines

In some circumstances, national rules may allow fines of at least 4% of a company’s annual turnover in the affected European Union member state or states. The exact consequences depend on applicable national law and the circumstances of the case.