EmpCo sustainability labels
Your own “eco” badge on a Shopify product page: the EU sustainability-label rule
Direct answer. From 27 September 2026, displaying a sustainability label that is not based on a certification scheme or established by public authorities is on the EU’s always-unfair list (Annex I, point 2a of the Unfair Commercial Practices Directive), so a leaf, seal or “planet-friendly” mark you designed yourself is a problem. A mark from a qualifying third-party certification scheme, or one established by a public authority such as the EU Ecolabel, is the route the directive leaves open.
Green Claims Guard (Shopify App Store) flags green-claim wording and names the exact provision it cites. This page covers the label rule that sits next to wording: what a sustainability label is, what a certification scheme has to be, and how to audit the badges in your theme. The app does not certify labels or decide whether a mark is lawful, and this page is not legal advice.
Related: CLPLens — Hazard pictograms on the product page, not only the parcel.
Free check first: Green claim wording self-check runs in your browser and sends nothing. Paste product copy and see which environmental wording to review.
What counts as a sustainability label
Directive (EU) 2024/825 defines a sustainability label as any voluntary trust mark, quality mark or equivalent, public or private, that aims to set a product, process or business apart and promote it by reference to environmental or social characteristics. A badge you made yourself fits that definition. Labels required by law do not.
Source: Directive (EU) 2024/825 on EUR-Lex, Article 1(1) (new definitions) and the Annex (Annex I, point 2a). The rules apply from 27 September 2026.
What a certification scheme has to be
The directive defines a certification scheme as third-party verification with publicly available terms. Those terms must meet four tests:
- The scheme is open to all traders willing and able to comply, on transparent, fair and non-discriminatory terms.
- The scheme owner developed the requirements in consultation with relevant experts and stakeholders.
- There are procedures for non-compliance, including withdrawing or suspending use of the label.
- Compliance checks are objective and carried out by a third party independent of both the scheme owner and the trader.
A badge you award yourself, or one a paid vendor hands out without independent third-party checks, does not meet the last test on its face.
Install Green Claims Guard → scan product copy → review flags
What stays possible
The directive’s recitals say labels established by public authorities can still be displayed without a certification scheme, and give the EU Ecolabel and EMAS logos as examples. Check the exact scheme and its current rules before you rely on a mark.
A badge audit for a Shopify store
- List every badge, seal, icon and “certified” line in your theme, product images, product descriptions, collection pages and footer.
- For each one, write down who awards it and where its terms are published.
- Check the four scheme tests above, or whether a public authority established the mark.
- Remove or replace marks that fail. Do not rename a self-made badge to make it look like a scheme.
- Run a Green Claims Guard scan on your product copy, review each flag and the provision it cites, and rewrite the wording around a label you keep.
The scan reads wording. Badges that exist only as images are outside what this page covers, so review those by hand.
Install Green Claims Guard and run the checklist
Where this sits next to the other green-claim rules
- A badge that implies “excellent environmental performance” can also be a generic claim: see the generic green claims ban.
- A badge that implies carbon neutrality through offsets is a different Annex I item: see carbon-neutral and offset claims.
- Dated proof for a specific claim you keep is a separate job: see dated evidence records.
Install Green Claims Guard → review the cited provision
Install Green Claims Guard, then re-scan
What this page is not
- Not legal advice or a ruling that a particular label is allowed.
- Not a certification service, and not an image scanner.
- Not a substitute for checking how your Member State transposed the directive.
Related pages
- EU generic green claims ban
- EmpCo carbon-neutral claims
- Flag wording and see which provision it cites
- Scan catalog and content for green claims
- Green Claims Guard
Not legal advice. Re-check the cited law and the current app page before you rely on this page.