EU directive 2024/825 and websites, what you can claim about eco-design

Key points

• The rules of directive 2024/825 apply from 27 September 2026, and France had not yet transposed it on 1 October 2026.
• "Eco-designed site" or "low-carbon website" with no proof look like generic claims, which French law can already sanction under article L121-2.
• A home-made badge presented as a label, with no certification behind it, falls under the ban on labels.
• What remains allowed is a precise, dated figure, on a clear scope, with a published method.

Many websites now carry a line such as “eco-designed site”, “low-carbon website” or “responsible hosting”, sometimes with a small logo next to it. Since the end of September 2026, that kind of sentence reads differently, because directive (EU) 2024/825 is aimed squarely at vague environmental claims and at labels that are not labels. This guide explains what the text says, where it stands in France (with what is established and what remains uncertain), and how you can keep talking about a site’s eco-design without taking a needless risk.

What the directive says, and its dates

Directive (EU) 2024/825 was adopted on 28 February 2024 and came into force on 26 March 2024. Member states had to transpose it into national law by 27 March 2026 at the latest, and its rules apply from 27 September 2026, according to the DREETS Nouvelle-Aquitaine (a French regional state office) and the Gossement law firm.

Technically, the directive amends annex I of directive 2005/29/EC on unfair commercial practices, which is the list of practices considered misleading in every case, without having to show that they influenced anyone.

What it prohibits

Three families of practices concern us. The first is generic environmental claims, such as “environmentally friendly”, “eco-friendly”, “green”, “good for the climate” or “low carbon intensity”, when they are not backed by recognised excellent environmental performance that is relevant to the claim, according to reglementation-environnement.com.

The second is sustainability labels that are not based on a certification scheme or that were not set up by public authorities. The third is statements that a product has a neutral, reduced or positive impact on the environment or the climate solely because of offsetting, such as a “carbon neutral” claim obtained by funding projects elsewhere (see the DREETS).

Where France stands on transposition

What is established is that, on 1 October 2026, France has not transposed the directive. The DDADDUE bill, whose articles 20 and 21 carry the transposition, was tabled in the Senate on 10 November 2025, adopted by the Senate on 18 February 2026 and sent to the National Assembly on 20 February 2026, with no follow-up since, and the European Commission sent France a formal notice on 28 May 2026, according to Village de la Justice. Article 20 amends the Consumer Code (new misleading practices, framework for labels) and article 21 the Environmental Code, according to the Senate report.

What remains uncertain is mostly the question of direct effect, which is debated between law firms. Gossement and Village de la Justice say the directive does not apply as it stands to consumers without a transposition law, while Kohen Avocats presents it as fully applicable, and that disagreement is not settled.

The law that already applies

Waiting for transposition to care about this would be a mistake anyway, since French law already punishes misleading commercial practices. Article L121-2 of the Consumer Code applies, and a vague or unverifiable environmental claim can fall under it. The penalties reported by Village de la Justice are two years in prison and a 300,000 euro fine, which can be raised to 10% of average annual turnover and, for an environmental claim, up to 80% of the advertising spend concerned (article L132-2).

Another directive, known as “Green Claims”, was meant to frame explicit environmental claims. The Commission announced on 20 June 2025 that it intended to withdraw it, but it is still in the 2026 work programme, so it is formally pending, although suspended (secondary source, Make Influence, to be checked on the Commission’s site).

What this changes for “eco-designed site”, “low-carbon site” or a badge

What follows is our reading of the facts above, not an established position, and a lawyer should validate it. A bare mention such as “eco-designed site”, “low-carbon site”, “ecological site” or “green site” looks a lot like a generic claim, so the risk is high once the directive is transposed, and it is already real under L121-2.

A home-made badge or logo presented as a sustainability label, when it rests on no certification scheme and no public authority, falls in the same way under the ban on labels. Whether a simple measurement badge counts as a “sustainability label” is a question that has not been settled. Lastly, “carbon neutral” through offsetting is prohibited.

What is still allowed

The directive does not stop you from talking about your site’s eco-design. What remains allowed is a claim that is specific, quantified, dated and verifiable, and that says what is measured, on which scope, on what date and with which method, for example “0.13 g CO₂e per page on average, measured on 29 September 2026, method published”. Here is how you can move from risky wording to more solid wording.

• “Eco-designed site” becomes “home page of so many KB, measured on a given date, method published”, using the figures from your own measurement.
• “Low-carbon site” becomes “about 0.13 g of CO₂ per page view on average, estimated with the Sustainable Web Design model, measured on 29 September 2026”.
• “Ecological site” or “green site” is simply removed, or replaced with a fact, for instance “hosted with a green host according to the Green Web Foundation”.
• “Carbon neutral” is removed when it rests on offsetting, and replaced by what you reduced, with the figure before and after.
• A home-made “eco-responsible” logo is withdrawn, or replaced with a link to the public measurement it sums up.

One point about scope to keep in mind. A measurement made on the home page says nothing about the whole site. It is better to write “home page” than “our site” until other pages have been measured.

Leaning on a public, attested measurement

A Grammage attestation gives a measurement signed by Grammage, with a public page where anyone can find the date, the scope and the figures, and the method that produces them is published. This looks like the specific, dated and verifiable claim described above, as long as you quote it as it stands, with its figure and its date, without adding a qualifier. What it covers and what it does not cover is explained on the attestation page.

To find out what you could write on your own site, the audit gives the measurement page by page. And if you are hesitating between several measuring tools, our comparison sets them side by side.

This guide is not legal advice

This guide gathers public information and readings of secondary sources, some of which disagree with each other. It does not replace the advice of a lawyer who specialises in consumer law, and it should not be the only basis for deciding on a communication. If you are unsure about a specific wording, that is who you should submit it to, after rereading the official texts.