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Directive (EU) 2024/825 bans vague climate claims like "climate neutral" or "eco-friendly" without proof, and it applies from 27 September 2026 to every business making a claim to a consumer — your menu included. Most owners have never heard of it, and a menu that already says "carbon neutral" today because the venue buys carbon credits is doing exactly what this law was written to stop.
Every EU directive that touches hospitality gets covered here somewhere — the AI Act, the EU Deforestation Regulation on coffee and chocolate, the packaging rules. This is the first one aimed straight at the WORDS on your menu rather than your stock, your till or your suppliers.
Directive (EU) 2024/825 — the "Empowering Consumers for the Green Transition" directive — amends the EU's unfair commercial practices rules. It has been in force since March 2024, member states must transpose it into national law by 27 March 2026, and it applies to every trader from 27 September 2026. That's this year.
The law touches three things that have become so ordinary in hospitality that nobody questions them any more: the phrase "climate neutral" on a menu or website because you buy carbon credits, a hand-drawn green leaf next to a dish, and the promise "climate neutral by 2030" with no plan behind it.
This article walks through the 4 rules exactly as the law states them, then gives the honest, still-allowed way to show a dish's climate impact — built on the most-cited scientific study on food's climate footprint, not a logo you drew yourself.
Why this lands on your menu, not just your marketing
A menu is a commercial claim the moment it says anything a guest might base a choice on. That's exactly how the law defines an "environmental claim": any message that gives the impression a product or a business has a favourable environmental impact. "Climate neutral dinner", a leaf icon next to the veggie option, "sustainably caught fish" — every one of those is an environmental claim, whether it's printed on paper, on your website or on Instagram.
That's what makes this different from most EU rules covered here. The Deforestation Regulation touches your coffee and chocolate supplier; the AI Act touches software you may not even use. This one touches the sentence you typed yourself the last time you reprinted the menu.
And enforcement isn't new or experimental — it runs through the EU's existing consumer-protection framework, which has allowed fines up to 4% of annual turnover in the member state concerned for widespread infringements since 2022. The odds of a single independent restaurant hitting that ceiling are extremely low — but the duty to have proof applies at any size, from day one.
The 4 rules, as they actually appear in the law
The directive adds four new practices to the EU's "blacklist" of commercial practices that are always considered unfair — no grey area, no "it depends". Here's what those four mean for a restaurant in practice, in the order a menu usually breaks them.
1. No generic claim without proof of genuinely excellent environmental performance
"Eco", "green", "climate-friendly", "conscious", "sustainable" — the law names these words directly as examples of a generic environmental claim. They're only allowed once you can demonstrate your business genuinely excels on that specific point, not just "better than before" or "we're trying".
The difference is specificity. "Our fish is sustainable" is a feeling. "Our fish carries the MSC label" is a fact a guest can check. The first sentence becomes a breach from 27 September 2026 the moment someone asks and you can't produce proof; the second never is.
2. Buying carbon credits is fine; calling the result "neutral" no longer is
This is the most specific of the four rules, and the most underrated: the law names, by name, the claim that a product or service has a neutral, reduced or positive climate impact BECAUSE its emissions are offset through carbon credits.
Buying carbon credits stays perfectly legal — funding reforestation is not the problem. The problem is the sentence that follows: "…so this dinner is climate neutral." That conclusion can no longer rest on an offset, however genuine the project behind it.
Below are five examples of what that looks like in practice: the claim many menus carry today, and the fact you can put in its place.
On the left, the phrase that becomes a breach from 27 September 2026. On the right, a specific, checkable fact that says the same thing — without the word "neutral" or an uncertified logo.
This is guidance, not legal advice — for a claim that needs to be watertight for your specific business, check with a consumer-law specialist.
3. A label with no real certification behind it is about to be banned — numbers are the alternative
A second blacklisted practice: displaying a sustainability label that isn't based on a certification scheme or set up by a public authority. The hand-drawn green leaf a chef once designed for the menu falls squarely under this, however well-intentioned.
The safe route is a real label (EU Ecolabel, MSC, ASC, the EU organic leaf) with a certificate number. But not every venue can, or wants to, get every dish certified. The alternative that survives the law: don't show a label at all — show a number, sourced to published science rather than a design someone drew.
That's why the section below builds a climate-band system on the most-cited global study of food's climate footprint (Poore & Nemecek, Science, 2018): no claim, no label, just a figure with a source.
Global averages from Poore & Nemecek (Science, 2018), the largest meta-analysis ever done on food's climate footprint (almost 40,000 farms across 119 countries). These are broad, widely-cited rules of thumb — not a certificate for your specific supplier.
Worth knowing: farmed shrimp sits in the same high band as beef, because of the mangrove-forest destruction cleared for shrimp ponds — a figure no menu ever prints, but one that's well documented in the science.
4. A future promise needs a plan, not a slogan
The fourth rule targets the sentence "climate neutral by 2030". A claim about future environmental performance is only allowed if it rests on a clear, publicly available and verifiable implementation plan with interim targets — not an ambition that's written down nowhere.
That plan doesn't need to be complicated. "We cut the beef share of our menu by 10% every year, and publish that figure on our website" is specific, checkable and achievable at any size. "Climate neutral by 2030" with nothing behind it is exactly the kind of claim the law now blocks.
Estimate one dish's climate band
This is exactly the kind of figure rule 3 above allows: no label, no claim of "neutral", just an estimate with a source attached. Pick a main ingredient and a portion weight, and the tool shows the estimated footprint, its band, and one concrete comparison.
Important: this is an estimate from global averages, not a life-cycle analysis of your specific dish. Use it to understand where the impact actually sits — not as the exact figure you print on a menu with no further backing.
Climate-band estimator
Pick a main ingredient and a portion weight.
Estimated impact of this portion
Global average from Poore & Nemecek (2018), not certified for your specific supplier.
If you put this figure on a menu, be as specific about the source as you'd be about a price: "± {x} kg CO2e, global average (Poore & Nemecek, 2018)" is a checkable fact. "Climate-friendly dish" with no source is exactly the generic claim rule 1 bans.
The reverse lesson is at least as useful: a menu that shows, this way, that the plant-based option carries a fraction of beef's footprint persuades a guest better than any green leaf icon ever could — without claiming a single word a lawyer would need to check.
Your rollout before the two 2026 dates
You don't need to reprint anything before 27 September 2026 — the law targets the wording, not the paper. What you CAN do today, for free: fix your website and social media. The printed menu can follow at your next reprint.
Before 27 March 2026 — audit what's already out there
- Go through your menu, website, packaging and social media for every use of "eco, green, sustainable, climate-friendly, neutral"
- Flag every claim you don't have concrete proof for
- Check every logo or icon: is there a real certification scheme behind it, or was it drawn in-house?
Before 27 September 2026 — replace or substantiate
- Rewrite every vague claim into a specific, checkable fact (see the 5 examples above)
- Gather the proof for the claims you keep: supplier certificates, certificate numbers, your own measurements
- Drop "climate neutral" from any claim that rests on offsetting, even where the credits are genuine
- Replace an uncertified logo with the climate-band figure above, or with a real certificate
If you still want to say something about climate impact
- Use the ingredient-based banding system instead of an expensive per-dish life-cycle analysis
- Frame it as a positive choice ("lower footprint"), not a warning — it performs better and it's more accurate too
- Keep the underlying source handy in case a guest — or an inspector — asks
This isn't about saying less — it's about saying something more specific
This law doesn't ban a single genuinely sustainable practice. It bans the vague sentence that says nothing the moment someone asks a follow-up question. A venue that genuinely sources locally, genuinely sorts its waste, or genuinely serves less beef still has just as much to say after 27 September 2026 — only more concretely than before.
If your menu already says "climate neutral" today because the venue buys carbon credits, you don't need to wait for an inspection to fix it: the website copy can change this week, and the printed menu at your next reprint.
And if you've said nothing about climate impact so far, you now have an honest way to start: no logo, no promise, just a figure with a source — exactly what the law still allows.