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Sustainability & CSRD · Circulad'OR Blog

Greenwashing: from 27 September, "eco" without evidence is a banned commercial practice

Marius Cristian BrînzeaMarius Cristian Brînzea · Managing Partner 1 October 20263 min read
In shortFrom 27 September 2026 the new anti-greenwashing rules apply, introduced into Law no. 363/2007 by Emergency Ordinance no. 18/2026, which transposes Directive (EU) 2024/825. Generic environmental claims - "eco", "green", "environmentally friendly" - can no longer appear on packaging and in commercial communication without proven excellent environmental performance, sustainability labels need a certification scheme behind them, and "climate neutral" based on offsetting emissions is banned. Enforcement lies with the Romanian consumer protection authority, ANPC.

What is banned from 27 September

The list of commercial practices that are misleading "in all circumstances" - those no longer assessed case by case - has been extended with environment-related practices. A generic environmental claim is no longer allowed without proof of excellent environmental performance relevant to that claim: wording such as "ecological", "green", "natural" or "environmentally friendly" must either be dropped or backed by solid evidence. Likewise, a real but partial environmental quality can no longer be extended to the whole product - "100% recycled packaging" when only the cap is, for example.

Also banned are sustainability labels that are not based on a certification scheme and are not established by public authorities - "green" logos designed in-house by companies fall squarely into this category - as well as claims that a product has a neutral, reduced or positive impact on the environment based on offsetting emissions: purchased carbon credits can no longer support a "carbon neutral" on the label.

Who is concerned and what the risk is

The rules apply to any trader in its relationship with consumers, so they directly concern producers and importers of packaged products and retailers: texts on packaging and labels, product pages, campaigns and marketing materials. ANPC can sanction these practices with fines under Law no. 363/2007, and for large-scale infringements at EU level the maximum fine can reach 4% of annual turnover.

For packaging, the new rules meet Regulation (EU) 2025/40 (PPWR): claims about recyclability and recycled content will receive EU-harmonised labels, but until then any such statement must be provable with documents.

What to do now

The first step is an inventory of the environmental claims in the company's communication: packaging, labels, website, catalogues, social media. For every claim that is kept, a supporting file is built - tests, certifications, calculations, recyclability assessments - and sustainability logos are checked: is there a certification scheme behind them? Whatever cannot be proven is reworded or removed from the artwork at the next revision.

Key points:
Legal basis: Law no. 363/2007 on combating unfair commercial practices of traders in relation to consumers and harmonising regulations with European consumer protection legislation, as amended (including by Emergency Ordinance no. 18/2026); Directive (EU) 2024/825 as regards empowering consumers for the green transition; Regulation (EU) 2025/40 on packaging and packaging waste, as amended.

What we do

At Circulad'OR we check the environmental claims on packaging and in commercial communication and build the files that support them - from the recyclability assessment of packaging, documented in the Yvora platform, to aligning messages with PPWR labelling requirements. If your packaging says "eco", "green" or "100% recyclable" today, now is the time to check together whether you can prove it.

Want an answer for your specific situation?

The first conversation is free: you find out what applies to you, by when, and who does it - you, us, or the application.

Write to us / Call 031 9303 office@circulador.ro