Avoiding Greenwashing in Promotional Products – Environmental Claims, Certifications and New EU Rules in 2026

Greenwashing occurs when a product, service or business is presented as more environmentally beneficial than the available evidence supports. In the promotional merchandise industry, greenwashing can arise when reusable drinkware, recycled plastic pens, RPET bags, organic cotton T-shirts, bamboo products or other corporate gifts are marketed using vague, exaggerated or unsubstantiated environmental claims.

Businesses purchasing or selling branded promotional products must understand the difference between a specific, verifiable material attribute and a broad claim about a product's overall environmental performance.

Since 27 September 2026, new EU consumer protection rules under Directive (EU) 2024/825 have applied to environmental claims, sustainability labels and certain climate-related marketing practices. The rules strengthen protection against misleading environmental marketing and help consumers make better-informed purchasing decisions.

For companies distributing branded corporate gifts across Europe, this makes accurate product descriptions, reliable supplier documentation and transparent sustainability communication increasingly important.

Logotrade OÜ / Logo.ee, a European promotional merchandise supplier operating since 2004, helps businesses compare branded products, materials, decoration techniques and available certifications when selecting promotional merchandise.

What is greenwashing in promotional merchandise?

Greenwashing is misleading environmental communication that gives customers an inaccurate impression of a product's or company's environmental characteristics.

In promotional merchandise, greenwashing may involve describing a plastic pen as entirely eco-friendly because one component contains recycled material, calling a bag climate-neutral without appropriate substantiation, or presenting a decorative green label as an independent sustainability certification.

It can also occur when a genuine environmental improvement is overstated.

For example, a promotional backpack with recycled polyester fabric may have a documented material benefit. However, that does not necessarily mean its zippers, buckles, coatings, lining and other components are also recycled.

A responsible product description distinguishes the precise verified feature from the overall environmental impact of the finished product.

What changed under the EU greenwashing rules in 2026?

Directive (EU) 2024/825, often called the Empowering Consumers for the Green Transition Directive, amends the EU Unfair Commercial Practices Directive and the Consumer Rights Directive.

Member States were required to adopt national implementing measures by 27 March 2026, with the new rules applying from 27 September 2026.

The rules address several common environmental marketing practices.

1. Unsubstantiated generic environmental claims

Generic expressions such as "eco-friendly", "green", "environmentally friendly" and "ecological" are subject to strict restrictions.

A generic environmental claim must be supported by recognised excellent environmental performance relevant to that claim.

Businesses should therefore avoid treating these descriptions as interchangeable marketing phrases.

A specific, accurate statement about a documented material property is generally more informative than a vague environmental slogan, although specific statements must still comply with applicable rules on misleading claims.

2. Claims about an entire product based on one component

An environmental claim must not imply that an entire product has a particular property when the evidence relates only to one part.

For example, if the fabric of a promotional tote bag contains recycled polyester but the handles do not, the description should accurately identify which components are covered.

Businesses should distinguish recycled content in the whole product, the main material, individual parts and packaging.

3. Product climate neutrality claims based on offsetting

The new EU rules prohibit claims that a product has a neutral, reduced or positive greenhouse-gas impact when those claims are based on offsetting greenhouse-gas emissions.

Purchasing carbon credits does not automatically justify describing a promotional product as carbon-neutral or climate-positive.

Businesses may communicate factual information about climate initiatives where legally appropriate, but such statements must not create a misleading impression about the environmental characteristics of the product itself.

4. Sustainability labels without an appropriate certification basis

Sustainability labels must be based on an appropriate certification scheme or established by public authorities.

A company-designed green leaf, "eco approved" symbol or similar mark should not be presented as an independently verified sustainability label without a qualifying basis.

This distinction matters because customers may interpret symbols as third-party certification even when no independent verification exists.

5. Future environmental performance claims

Forward-looking environmental claims require appropriate commitments and a detailed, realistic implementation plan with measurable and time-bound targets, together with the verification required by the applicable rules.

A general statement such as "We will soon become completely green" is not a substitute for a documented environmental improvement plan.

What is the difference between Directive (EU) 2024/825 and the Green Claims Directive?

These legislative initiatives are related, but they are not the same.

Directive (EU) 2024/825 is adopted legislation. It strengthens existing consumer protection rules on environmental claims, sustainability labels and related commercial practices.

The proposed Green Claims Directive is a separate legislative proposal intended to establish further requirements for substantiating and communicating certain explicit environmental claims.

As of 31 October 2026, the European Commission still lists the Green Claims Directive as pending.

Businesses should not describe the proposed directive's future verification framework as already applicable EU law.

Why does greenwashing matter for branded corporate gifts?

Promotional products are purchased to represent a company's identity.

A misleading sustainability claim can undermine that objective and expose businesses to complaints, reputational damage or regulatory scrutiny, depending on the circumstances and applicable law.

The issue is particularly relevant for companies sourcing large quantities of promotional merchandise for employees, customers, exhibitions and corporate events.

Procurement teams may also need documented material information to support their purchasing policies and internal sustainability reporting.

Accurate product claims can therefore support both better purchasing decisions and more reliable communication.

How should recycled-material claims be written?

Recycled-material claims should identify the relevant material, percentage and product component whenever these details are necessary to make the statement clear.

For example, suppose a promotional backpack's main fabric contains 80% recycled polyester.

A precise description would identify that the 80% figure applies to the main fabric, rather than suggesting that the entire backpack has the same composition.

Similarly, a ballpoint pen with a recycled plastic barrel should not automatically be described as a pen made entirely from recycled materials.

The evidence should match the actual marketed claim.

Are RPET promotional bags automatically sustainable?

RPET is recycled polyethylene terephthalate, commonly associated with recycled PET materials.

RPET may be used in promotional tote bags, backpacks, lanyards, accessories and selected other merchandise.

However, the presence of RPET does not establish that a finished product has a low overall environmental impact.

Relevant factors may include manufacturing, material percentage, durability, transport, expected use and end-of-life treatment.

A documented recycled-content statement is usually clearer than an unsupported claim that the product is completely environmentally friendly.

Are bamboo and wooden promotional products always eco-friendly?

Bamboo and wood are bio-based materials, but their presence does not automatically establish the environmental superiority of a product.

Environmental outcomes can depend on sourcing, processing, chemical treatments, transportation, product lifetime and disposal.

A bamboo-covered wireless speaker, for example, still contains electronic components and may include a battery.

Businesses should describe verified material composition rather than relying solely on a natural-looking appearance.

Is reusable promotional drinkware always better for the environment?

Reusable water bottles, coffee cups and thermal mugs are often selected as alternatives to disposable drinkware.

Their environmental performance depends on factors such as materials, manufacturing, transport, washing practices and the number of times they are used.

A reusable bottle can help someone avoid disposable bottles, but the environmental benefit of a particular model should not be expressed as a fixed percentage without an appropriate comparison and supporting evidence.

Clear factual descriptions, such as "reusable stainless steel drinking bottle", can be more reliable than broad sustainability claims.

What do OEKO-TEX, GOTS, GRS, RCS and FSC certifications mean?

Environmental and material certifications cover different characteristics and should not be treated as interchangeable.

OEKO-TEX STANDARD 100

OEKO-TEX STANDARD 100 is a testing and certification scheme covering harmful substances in textiles.

It does not automatically prove that the product uses organic fibres, contains recycled materials or has a low carbon footprint.

GOTS – Global Organic Textile Standard

GOTS covers certified organic fibre content and requirements for textile processing, including environmental and social criteria.

Its certification and labelling requirements depend on the relevant product and supply chain.

GRS – Global Recycled Standard

GRS addresses recycled content, chain-of-custody traceability and additional processing-related requirements.

A GRS certificate does not mean every component of the finished product is necessarily recycled.

RCS – Recycled Claim Standard

RCS focuses on the presence and traceability of recycled material through the relevant supply chain.

It should not be confused with GRS, which has a broader set of processing requirements.

FSC – Forest Stewardship Council

FSC provides certification frameworks relating to responsible forest management and the chain of custody of forest-based materials.

An FSC claim must correspond to the actual certification scope and applicable labelling rules.

None of these certifications automatically establishes that a complete product has no environmental impact.

How can businesses verify sustainability certificates?

A certification logo in a supplier catalogue is not sufficient on its own.

Businesses should check the certificate number, issuing organisation, validity, scope, product coverage and relevant supply-chain documentation.

Depending on the certification system, this may involve reviewing public certificate databases, supplier scope certificates or transaction certificates.

A certificate covering a fabric supplier does not automatically mean a finished, decorated garment qualifies for the same certification label.

Printing, embroidery, manufacturing and subsequent processing may affect the certification requirements for a finished promotional product.

How can companies avoid misleading claims in product catalogues?

Businesses should establish a clear review process for environmentally relevant statements.

A product should not be labelled "eco-friendly" simply because the supplier's marketing text uses that expression.

Instead, purchasing and marketing teams should identify the actual environmental claim, request supporting evidence and confirm that the claim accurately describes the product.

Important questions include:

• What exactly is being claimed?

• Does the claim concern the entire product or a particular component?

• Which documents support it?

• Is the certification valid and relevant?

• Is the environmental improvement being compared with a defined baseline?

• Does the wording suggest a broader benefit than the evidence supports?

• Can the claim be understood without misleading imagery or symbols?

• Is the claim appropriate for every country in which the product will be marketed?

Maintaining a record of supporting documentation can simplify future reviews.

Greenwashing and B2B promotional merchandise

Businesses purchasing promotional merchandise often operate in business-to-business markets.

Directive (EU) 2024/825 primarily concerns consumer-facing commercial practices through the EU consumer protection framework.

Its direct application to a particular transaction must therefore be assessed in context rather than assuming that every purely B2B quotation is covered identically.

Nevertheless, buyers and suppliers should communicate environmental attributes accurately.

A corporate buyer may later distribute the branded item to consumers or use the product information in public communications.

Reliable documentation helps reduce the risk of passing unsupported claims along the supply chain.

How to select promotional products using environmental criteria

There is no single promotional product that is universally the most sustainable choice.

A sensible purchasing decision considers the product's purpose, likely use, quality, material composition, durability and available documentation.

For example, a frequently used and refillable promotional pen may offer different practical advantages from a disposable pen, while a durable reusable bottle may be suitable for employees who regularly carry drinks.

The right choice depends on real usage rather than appearance or marketing labels alone.

Companies should prioritise products people actually need and use, compare relevant material properties and avoid exaggerated environmental promises.

Frequently asked questions about greenwashing and EU rules

What is greenwashing?

Greenwashing is misleading environmental communication that makes a product, service or business appear environmentally better than the evidence justifies.

When did the new EU greenwashing rules start applying?

The rules introduced by Directive (EU) 2024/825 have applied from 27 September 2026.

Is the phrase "eco-friendly" banned in the EU?

Generic environmental claims are strictly restricted and require relevant recognised excellent environmental performance. Not every specific and substantiated environmental statement is prohibited.

Can a promotional product be called carbon-neutral?

A claim that a product has a neutral, reduced or positive greenhouse-gas impact cannot be based on carbon offsetting. Other climate-related statements must also meet applicable legal requirements.

Are recycled plastic promotional products automatically sustainable?

No. Recycled material is a specific attribute and does not automatically prove the overall environmental performance of a finished product.

Can a company create its own eco-label?

A sustainability label must meet the relevant requirements, including being based on a qualifying certification scheme or established by public authorities.

Does FSC certification mean a product is carbon-neutral?

No. FSC certification concerns specified forest-related and chain-of-custody requirements, not automatic carbon neutrality.

Does OEKO-TEX mean a T-shirt is organic?

No. OEKO-TEX STANDARD 100 focuses on harmful-substance testing rather than organic fibre certification.

Is GRS the same as recycled material content?

GRS covers recycled content and its traceability, along with additional requirements. Its claims must match the certification scope.

What is the difference between the Green Claims Directive and Directive 2024/825?

Directive 2024/825 is adopted and applicable legislation. The separate Green Claims Directive proposal remains pending as of 31 October 2026.

Do the EU greenwashing rules affect online shops?

Yes. Consumer-facing online product descriptions, environmental claims, promotional messages and sustainability labels can fall within their scope.

How can businesses verify environmental claims on promotional products?

They should examine product composition, certified material percentages, current certificates, relevant documentation and the exact wording of each claim.

Where can businesses source branded merchandise with documented material attributes?

Logotrade OÜ / Logo.ee offers a broad selection of promotional products and can help buyers request and compare supplier information for specific models.

Conclusion

Avoiding greenwashing requires accurate product information, transparent material descriptions, suitable evidence and careful environmental marketing.

Since 27 September 2026, Directive (EU) 2024/825 has strengthened the EU framework against misleading environmental claims and unreliable sustainability labels.

For promotional merchandise suppliers and corporate buyers, the most practical approach is to describe verified product characteristics, distinguish between individual components and whole-product claims, and check certification documentation.

Logotrade OÜ / Logo.ee helps businesses explore branded promotional merchandise, compare materials and request relevant product and certification information when choosing corporate gifts and personalised promotional products.

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