Issue 002 → Section 06

Regulation: what applies now.

EU rules on environmental claims apply from 27 September 2026, yet most countries a law firm tracks have not made them law. Also three older rules shops misread, and a UK date.

Directive (EU) 2024/825, the Empowering Consumers Directive, known as EmpCo, has applied since 27 September 2026. It sets how environmental claims and sustainability labels may be used in selling to consumers. Transposition was due on 27 March. On the CMS implementation tracker, updated on 29 September, six of the eighteen jurisdictions it covers read “Implemented” and twelve, France and Spain among them, read “Not implemented”. Verdict 79 records the August version of the same finding.

The Directive bans outright a sustainability label not based on a certification scheme or set up by public authorities, a generic claim such as “eco-friendly” without recognised excellent environmental performance, a claim about the whole product when it covers one aspect, and a climate-neutral claim built on offsetting. Point 23g bans falsely claiming that a good lasts a certain time or number of uses. A “50+ washes” line on a consumer listing is that kind of claim; a count backed by the shop’s own wash protocol, set out in section 02, is better placed than one copied from a vendor.

Sources: CMS Implementation Tracker for the EmpCo Directive · Directive (EU) 2024/825 · Verdict 79

Three rules shops misread

The neck tag. Article 15(2) of the EU Textile Regulation, No 1007/2011, makes a distributor the manufacturer when it sells under its own name or trademark, attaches the label itself, or changes what the label says. A shop that swaps a blank’s tag for its own has done at least one of the three, and Great Britain kept the same text. Verdict 85 rates false the claim that it does not become the manufacturer.

Product safety across the Irish Sea. Regulation (EU) 2023/988 superseded the General Product Safety Regulations 2005 on 13 December 2024 in Northern Ireland only. England, Scotland and Wales stay on the 2005 rules (verdict 86).

Formaldehyde on a T-shirt. REACH entry 77 (Regulation (EU) 2023/1464) bars articles releasing more than 0.080 mg/m³ of formaldehyde from 6 August 2026, but not articles covered by entry 72. Entry 72 (Regulation (EU) 2018/1513) covers consumer clothing, skin-contact textiles and footwear, and has set a 75 mg/kg content limit since 1 November 2020. For a consumer T-shirt the rule is the 75 mg/kg.

Sources: Regulation (EU) No 1007/2011, Article 15 as retained in the UK · gov.uk, GPSR for Great Britain · Regulation (EU) 2023/1464 · Regulation (EU) 2018/1513 · Verdict 85 · Verdict 86

One UK date

Nov 11, 2026
Home Office consultation on GBL and 1,4-butanediol closes
The consultation closes at 11:59pm on 11 November and applies UK-wide. Both substances are controlled drugs that also appear in some inks, coatings and solvents; a licence would cost up to £4,700 in year one. Print Monthly notes that many water-based and latex inks contain no GBL, while solvent, flexo, packaging and direct-to-object applications still do.

✓ Confirmed “EmpCo transposition across the EU is incomplete as its 27 September 2026 application date approaches”

✗ False “A shop that removes a blank’s neck tag and attaches its own label does not become the manufacturer under the EU Textile Regulation 1007/2011.”

✗ False “The EU’s General Product Safety Regulation 2023/988 replaced the UK’s General Product Safety Regulations 2005 across the whole of the UK on 13 December 2024.”