The European Union (Empowering Consumers for the Green Transition) Regulations 2026 implement at Irish level the EU’s Empowering Consumers for the Green Transition Directive, which amends the Unfair Commercial Practices Directive (UCPD) and the Consumer Rights Directive (CRD) to tackle “greenwashing” and improve the quality of sustainability information provided to consumers. Member States were required to transpose by 27 March 2026, with national rules applying from 27 September 2026.
What do the Irish Regulations do?
The Regulations update Irish consumer protection law to reflect the EU changes aimed at enabling consumers to make informed, sustainable choices. In practice, they do three things.
Expansion of the List of Prohibited Commercial Practices
First, the Regulations expand the list of commercial practices which are deemed unfair in all circumstances under the Unfair Commercial Practices Directive. This expansion is directed, in particular, at forms of greenwashing and durability-related misrepresentations. With effect from 27 September 2026, traders will be prohibited from engaging in the following practices:
- Deploying generic environmental claims — such as "eco-friendly", "green" or "climate-friendly" - where the trader is unable to demonstrate the validity of such claims by reference to recognised and robust evidence available at the time the claim is made.
- Making claims regarding future environmental performance — for example, commitments to reduce emissions or environmental impact by a specified date — in the absence of clear, verifiable and time-bound commitments supported by an independent monitoring mechanism.
- Displaying sustainability labels which are not grounded in an approved certification scheme or established by a public authority, or representing that a label carries official endorsement where no such endorsement exists.
- Relying on carbon offsetting as a basis for claiming that a product has a neutral, reduced or positive environmental impact, unless the claim accurately reflects the product's own lifecycle impact and the role of any offsetting arrangement is explained in a clear and non-misleading manner.
- Exaggerating repairability, longevity or other durability characteristics, or omitting material information concerning software updates or consumables which may adversely affect a product's durability or functionality.
Enhanced Pre-Contractual Information Requirements
Second, the Regulations amend the Consumer Rights Directive so as to strengthen the pre-contractual information to be provided to consumers. Where relevant, traders will be required to furnish accessible information on durability and repairability, including the following:
- The existence and duration of any commercial guarantee of durability offered by the producer and, where that guarantee exceeds two years, a clear statement to that effect together with the key terms applicable to consumers.
- The availability of software updates that affect functionality, security or durability, and any limitations of which consumers should reasonably be made aware prior to purchase.
- The availability of spare parts, repair services and repair instructions.
Alignment of Irish Enforcement with the EU Framework
Third, the Regulations align Irish enforcement mechanisms with the broader EU framework, thereby ensuring that misleading sustainability claims and prohibited commercial practices may be investigated and sanctioned by the CCPC.
Scope and Applicability
The Regulations apply to business-to-consumer practices across products and services offered to consumers within the European Union, including online interfaces and digital marketplaces. They do not amend sector-specific product rules, eco-design requirements or corporate sustainability reporting obligations. However, any sustainability-related information used in consumer-facing marketing or sales journeys must comply with the consumer protection standards set out in the Regulations with effect from 27 September 2026. Accordingly, both Irish-established traders and non-Irish traders targeting consumers in Ireland fall within scope.
What should businesses do now?
In our experience, the most effective compliance programmes are founded on three pillars: robust governance, rigorous substantiation and disciplined execution across the consumer journey.
We would recommend that businesses consider the following steps as a priority:
- Conduct a comprehensive audit of all sustainability-related claims and visual representations deployed across Irish consumer-facing channels, including the website, mobile application, product packaging, point-of-sale materials and customer support scripts. Any generic, ambiguous or unsubstantiated wording should be identified and withdrawn.
- Establish or update a substantiation library in respect of all current and proposed claims, prescribing minimum evidentiary standards and designating clear ownership for internal sign-off. In respect of forward-looking claims, the library should document the relevant baseline, the methodology to be applied, interim milestones, arrangements for independent verification and the triggers for corrective action in the event that targets are not being met.
- Review all sustainability labels presently in use. Where a label is not administered by a public authority, it is essential to confirm that it forms part of a robust, independently verified certification scheme. Proprietary or in-house "eco badges" should be discontinued.
- Revise pre-contractual disclosures to address durability, repairability, the provision of software updates and the terms of any commercial guarantees of durability. Such disclosures must be given due prominence and expressed in clear, plain-English language, with particular attention to readability on smaller screens.
- Align the governance framework for environmental marketing with the functions responsible for product stewardship and ESG reporting, so as to ensure that consumer-facing statements are consistent with lifecycle assessment data and do not extend beyond what the underlying evidence can support.
- Deliver targeted training to marketing, product and legal teams on the CCPC's published guidance, establish defined escalation paths for higher-risk campaigns and embed pre-launch legal review as a standard step in the approvals process.
For further information, please contact David McMunn, John Gaffney or your usual contact in Beauchamps LLP.