Study 161: What Are the Penalties for Greenwashing in the EU?

This study examines the enforcement architecture behind the EU ban on unsubstantiated environmental claims, which applies from 27 September 2026. Directive (EU) 2024/825 contains no penalties provision of its own; the widely cited four percent figure is Article 13(3) of the 2005 Unfair Commercial Practices Directive, inserted in 2019, which sets a floor under national maximums rather than a ceiling, is calculated on turnover in the affected member states, and applies only within coordinated cross-border actions under the Consumer Protection Cooperation Regulation. The record to date is dominat