Greenwashing after 27 September 2026: Are You Prepared for the New Rules on Environmental Claims Under Greek Law 5317/2026?

Any supplier with consumer-facing communications relating to sustainability such as sustainable beauty products, or eco-friendly cars, will be prohibited from continuing these communications unless they comply with the conditions of Greek Law 5317/2026¹. The new provisions apply as of 27 September 2026. There is no transitional or grandfathering period, and the rules apply to both new and existing products (old stock)².

The rules apply to any supplier (’trader’ under the Directive), i.e. any natural or legal person, whether governed by private or public law, acting for business or professional purposes, directly or through any person acting on its behalf, in its business-to-consumer (B2C) commercial practices.

Scope is determined by the claim itself, not by company size or CSRD³ status. Companies outside the CSRD and non-EU traders selling to consumers in Greece or the EU are also covered. 

All channels are covered from packaging, labels and websites to advertising and social media, including implicit claims through images, colors and brand or product names, regardless of intellectual property protection.

Business-to-business (B2B) claims fall outside the UCPD⁴, but remain exposed under advertising and unfair competition law and contractually where they reach consumers through customers' marketing.

Greek Law 5317/2026 introduces new key definitions which set the framework for assessing compliance, such as environmental claim, generic environmental claim, sustainability label, certification scheme, recognized excellent environmental performance, durability and reparability score⁵.

Environmental and social characteristics, as well as circularity aspects (durability, reparability and recyclability), are now expressly listed among the main product characteristics for assessing misleading commercial practices.

Claims about future environmental performance (e.g. net zero by 2030) may only be made where supported by clear, objective, publicly available and verifiable commitments, set out in a detailed and realistic implementation plan that includes measurable, time-bound targets and resource allocation, and is regularly verified by an independent third-party expert whose findings are made available to consumers.

The following are unfair commercial practices prohibited in all circumstances, with no need to prove that a consumer was actually misled:

1. Displaying sustainability labels not based on a certification scheme or not established by public authorities.
2. Making generic environmental claims (e.g. green, eco-friendly, ecological, sustainable) without recognized excellent environmental performance relevant to the claim.
3. Making an environmental claim about an entire product or the supplier's entire business when it concerns only a certain aspect of the product or a specific activity of the supplier's business.
4. Claims that a product is ‘climate neutral’, or has reduced or positive environmental impact, based on the offsetting of greenhouse gas emissions.
5. Presenting legally mandated requirements on all products within the relevant product category on the EU market as a distinctive feature of the supplier's offer.
6. Concealing from consumers that software updates will negatively affect digital goods, or presenting updates as necessary when they merely enhance functionality.
7. Any commercial communication in relation to goods containing features introduced to limit their durability.
8. Making false durability claims or presenting goods as repairable when they are not.
9. Inducing premature replacement of consumables.
10. Withholding information about impairment of goods when third-party spare parts or consumables are used.

Suppliers offering product comparison services covering environmental, social or circularity aspects must disclose the comparison method, the products and suppliers compared, and the measures in place to keep the information up to date.

Businesses face administrative fines ranging from €5k to €1.5m or even €3m for repeat offenders. Decisions imposing fines over €50k (or any fine for repeat breaches) are published online, naming the product. Non-compliant distance contracts may also be void, and competitors and consumer associations can take action.

1. Map and inventory all environmental claims, sustainability labels and old stock across all channels.
2. Review and substantiate each claim against evidence, and check that each sustainability label relies on a certification scheme.
3. Establish internal policies and a pre-publication sign-off process.
4. Train your in-house teams.

This Briefing was prepared with the assistance of Trainee Attorney Maria Triantafyllopoulou.