Environmental wording on food packaging is becoming a compliance issue rather than a branding detail. From 27 September 2026, EU Member States must apply national measures implementing Directive (EU) 2024/825. The rules strengthen consumer protection against vague environmental claims, unsupported sustainability labels and statements that make one packaging feature sound like a benefit of the entire product.
Quick answer: paper food packaging buyers should replace broad words such as “eco-friendly,” “green” or “sustainable” with specific, verifiable statements. Claims should identify the exact packaging component, material, percentage, certification, test method or disposal condition involved. Artwork approval should include a claim-evidence review before printing plates or production files are released.
What Changes on 27 September 2026?
Directive (EU) 2024/825 required Member States to adopt and publish national measures by 27 March 2026 and to apply those measures from 27 September 2026. Because enforcement occurs through national law, buyers selling across several EU countries should confirm local implementation and language requirements rather than assuming one artwork statement will be interpreted identically everywhere.
The Directive adds practices to the EU list of commercial practices considered unfair in all circumstances. Packaging teams should pay particular attention to four areas:
- generic environmental claims without recognised excellent environmental performance;
- sustainability labels not based on a certification scheme or established by public authorities;
- claims about an entire product or business when the benefit concerns only one aspect; and
- product climate-impact claims based on offsetting greenhouse-gas emissions outside the product value chain.
Why Generic Green Words Are High Risk
The Directive identifies examples of generic claims such as “environmentally friendly,” “eco-friendly,” “green,” “climate friendly,” “biodegradable” and “biobased.” A generic term may be prohibited when the trader cannot demonstrate recognised excellent environmental performance relevant to that claim.
A specific statement is different. The official text contrasts “climate-friendly packaging” with a precise statement that 100% of the energy used to produce the packaging comes from renewable sources. The second statement describes a measurable fact, although it still must be accurate, documented and presented without creating a misleading overall impression.
Claim the Packaging Feature, Not the Whole Product
A paper container may include board, coating, adhesive, ink, label and a plastic or fibre lid. A claim about one component should not imply that every component has the same property. For example, “made with recycled material” can mislead when only the outer sleeve contains recycled fibre.
Use component-level wording where appropriate:
- “Outer paper sleeve contains 80% recycled fibre by weight.”
- “Paperboard sourced from an FSC-certified supply chain,” when certification and licence rules are satisfied.
- “Industrially compostable paper bowl certified to [named standard and certification scheme], where accepted.”
- “Remove the PET window before recycling the paperboard box,” when supported by the actual construction and local collection route.
Do not copy these examples directly onto artwork without confirming that the finished pack, evidence and target-market infrastructure support them.
Sustainability Labels Need a Recognised Basis
A leaf icon, circular logo or self-created “green choice” badge can function as a sustainability label even when it contains few words. Under the new rules, displaying a sustainability label that is not based on a certification scheme or established by public authorities is prohibited.
Before accepting a label on printed packaging, record the scheme owner, certification scope, certificate number, validity dates, chain-of-custody requirements, approved logo artwork and rules governing product claims. A supplier’s general factory certificate may not automatically authorise a product-level claim.
Carbon-Neutral Wording Requires Special Care
The Directive prohibits claims that a product has a neutral, reduced or positive greenhouse-gas impact when the claim is based on offsetting emissions. Examples in the official text include “climate neutral,” “CO2 neutral certified” and similar wording. Companies may still communicate investments in environmental projects when the information is accurate and not presented as proof that the packaged product itself has no climate impact.
Packaging buyers should separate three subjects: measured product emissions, verified reductions within the value chain and financing outside projects. Combining them into one front-of-pack badge can create an inaccurate message.
Evidence File for Every Printed Claim
Create a claim register before artwork approval. For each statement or symbol, include:
- the exact claim as printed;
- the packaging component covered;
- the market and language version;
- the evidence source and calculation method;
- certificate validity and scope;
- conditions or disposal limitations;
- the person responsible for approval; and
- a review date when materials or suppliers change.
Keep supplier declarations, specifications, bills of material, certificates, test reports and calculation files together. Evidence should match the mass-production construction, not only a development sample.
Artwork Review Checklist for Paper Food Packaging
- Remove unsupported “green,” “eco” and “planet friendly” language.
- Specify whether a claim covers the board, coating, lid, window or complete pack.
- Check that percentages identify the correct basis, such as weight or fibre content.
- Verify certification logos against current licence rules.
- Avoid disposal claims that ignore local collection and treatment conditions.
- Review colours, imagery and symbols as well as written text.
- Reapprove claims after material, coating or supplier changes.
Build Compliance into the Packaging Brief
Claim review should begin before quotations are compared. Ask potential suppliers to identify the evidence they can provide for fibre sourcing, recycled content, coatings, compostability or other requested attributes. If a claim cannot be supported, change the wording or the material specification before production.
EcoGreenPack can support packaging projects with construction details, material specifications and production samples for buyer review. Contact EcoGreenPack with the target product, destination markets and proposed artwork claims so the packaging brief can be evaluated before mass production.
Official Source
See Directive (EU) 2024/825 on EUR-Lex. This article is general procurement information and is not legal advice; confirm national implementation for each target market.
