The EU’s Green-Claims Ban Is Live. Thai Exporters’ English Labels Are What Gets Judged

Since 27 September 2026, a Thai manufacturer selling to European consumers can no longer call a product “eco-friendly”, “green” หรือ “climate neutral” on the strength of a good intention, a logo or a bundle of offset credits. That is the date the EU’s Empowering Consumers Directive, Directive (EU) 2024/825, known as EmpCo, began to apply in every Member State.

Most commentary treats EmpCo as a European marketing problem. For Thai exporters it is something more specific: a wording problem, and usually an อังกฤษ wording problem. The Thai packaging copy is rarely what an EU regulator reads. The English edition that goes onto the export carton, the marketplace listing or the distributor’s website is.

What changed on 27 September

EmpCo does not create a new regulator. It amends the EU’s existing Unfair Commercial Practices Directive (2005/29/EC), the law national consumer authorities already enforce. Article 4 gave Member States until 27 March 2026 to adopt the national measures, and requires them to “apply those measures from 27 September 2026.”

Two mechanisms matter. First, new practices are added to Annex I, the blacklist of practices that are unfair in all circumstances: no case-by-case test, no argument that consumers weren’t really misled. Second, Article 6 is widened so that claims about future environmental performance, such as “net zero by 2040”, are misleading unless backed by “clear, objective, publicly available and verifiable commitments” in a detailed implementation plan that is “regularly verified by an independent third party expert.”

EmpCo also defines an environmental claim broadly: any non-mandatory message or representation, “including text, pictorial, graphic or symbolic representation, such as labels, brand names, company names or product names,” that states or implies a product or trader is better for the environment. Recital 9 adds that written claims combined with implicit cues “such as colours or images” can amount to a generic claim. A leaf icon on a green carton can count.

The four claims now banned outright

EmpCo adds several points to Annex I. These four are the ones aimed at green claims, paraphrased closely from the directive text:

“Recognised excellent environmental performance” has a narrow legal meaning: compliance with the EU Ecolabel (Regulation 66/2010), with an EN ISO 14024 Type I ecolabel “officially recognised in the Member States,” or top performance under other EU law. Recital 12 lists offsetting examples that are now banned when they rest on credits from outside the product’s value chain: “climate neutral”, “CO2 neutral certified”, “carbon positive”, “climate net zero”, “climate compensated”, “reduced climate impact” และ “limited CO2 footprint”.

That last point lands directly on Thai companies that have bought T-VER or other credits to describe a product as carbon neutral. A Thai offsetting programme can be entirely legitimate at home, and an organisation-level offset statement in a Thai sustainability report is a different matter. But on a product sold to an EU consumer, an offset-based neutrality claim is now on the blacklist, whatever registry the credits came from. Recital 12 says such claims are only allowed when based on “the actual lifecycle impact of the product.”

Where Thai exporters get caught: the translation

Here is the practical trap. Thai marketing copy routinely describes products as เป็นมิตรกับสิ่งแวดล้อม. Translated faithfully, that is “environmentally friendly”, the very first example of a generic claim in recital 9. A translation can be perfectly accurate and still turn a Thai-market phrase into a prohibited claim in the export market.

The directive itself shows the way out. A claim is not “generic” when its specification is given “in clear and prominent terms on the same medium”: the same pack, ad or product page. Recital 9 gives its own example, set out in the first row below:

Specific claims are not a free pass, since the general misleading-practice rules still apply to them, but they are the defensible form. Producing them is a drafting job, not only a translation job: the translator has to know that a quantified, bounded statement is required, and the technical team has to supply a number that will survive a challenge. This is why we treat EU-facing English as regulated copy, under the same ISO 17100 Translate-Edit-Proofread discipline as a technical document, with a reviewer who knows the claim rules. Our note on where ESG translation goes wrong covers the same failure in disclosure documents.

Your EPD, CFP and ISCC certificate are not the problem

None of this makes quantified environmental information less useful. EmpCo pushes claims toward exactly the measured, verified data that many Thai exporters already produce. The International EPD System said so directly in guidance published on 21 September 2026:

The same guidance draws the line at presentation. It suggests neutral wording, that a product “has a published, independently verified Environmental Product Declaration” with a link to the EPD Library, and tells holders not to detach the programme logo and use it “as a product merit badge,” or describe it “as an ecolabel, quality seal or product certification.” The programme notes that its guidance is not legal advice.

In our reading, the same logic applies to a TGO carbon footprint of products (CFP) result or an ISCC certificate: the verified number or certificate is evidence, and a slogan built on top of it is a separate claim that must stand on its own. A TGO-certified footprint gives you a figure with a defined boundary, which is what a specific claim needs. For exporters already reporting embedded emissions to the EU, CBAM sets the one hard language rule: Implementing Regulation 2025/2547 requires the operator’s emissions report to be submitted in English.

Where the evidence runs out

The same caution applies to how we talk about ratings. EmpCo is a hard rule about claims and says nothing about ESG scores. On that side the facts are narrower: FTSE Russell scores from public disclosure only, Thai is not among the research languages it names in its ESG Scores FAQ, SET itself recommends English disclosure because FTSE assesses primarily from English, and CDP will not score a Thai-language response. None of that means a Thai report is penalised, only that the English edition is the one a global reader most likely sees.

What to do this quarter

EmpCo rewards companies that already measure. The exporters most exposed are not the ones without data; they are the ones whose English copy says more than their data does. If your product carbon numbers are ready, see how they carry through from TGO certificate to disclosure, browse our case studiesและ follow EU and Thai rule changes on our regulatory tracker →

Sources, read 14 October 2026: Directive (EU) 2024/825 of 28 February 2024 (OJ L, 6.3.2024), recitals 4, 9 and 12, Article 1 (new UCPD Art. 2(o)–(s), Art. 6(2)(d) and Annex I points 2a, 4a, 4b, 4c) and Article 4(1); International EPD System, “New guidance on communicating EPDs under the EU Empowering Consumers Directive” (21 September 2026); Commission Implementing Regulation (EU) 2025/2547, Art. 10(4); FTSE Russell ESG Scores FAQ v1.5 §1.8; SET, Questions from Q&A sessions, Q16; CDP Terms of Disclosure §12.3. The translation of the Thai phrase is our own.