New marketing and consumer protection requirements call for action

Don’t delay in reviewing product packaging and marketing materials with environmental claims or sustainability statements

On 27 September 2026, the much-discussed amendments to the Consumer Protection Act concerning environmental and sustainability marketing, based on the EmpCo Directive (EU) 2024/825, will enter into force together with the new Government Decree (664/2026) concerning unfair commercial practices in marketing and customer relations.

It is not enough for businesses to ensure the compliance only of new products under these new regulations – they must also actively review existing products and their packaging, revise packaging and marketing materials, draft new guidelines, and potentially remove products from their range.

In practice, businesses will need to add the required new information to product packaging and remove or replace prohibited statements, symbols and logos. Other marketing and communications materials must also be reviewed accordingly. In addition to goods, the regulations apply to consumer services and their marketing materials.

General and exaggerated environmental claims prohibited

The new regulation will prohibit companies’ own and other uncertified sustainability labels. General environmental claims, such as ‘green’ and ‘ecological’, will in practice be eliminated entirely, as such claims will be permitted only in very limited circumstances. Similarly, exaggerated environmental claims will also be prohibited; for example, marketing an entire product as ‘made with recycled material’ constitutes an exaggeration if the claim applies only to the packaging.

As a result, products packaged or labelled under previous practices may become unsaleable once the new regulations enter into force, for example due to prohibited environmental claims or insufficient labelling.

There will be a partial six-month national transition period, during which the new rules on sustainability labelling and general and exaggerated environmental claims will not apply to marketing relating to a product or its packaging placed on the market before the new regulations enter into force. Traders therefore have until 27 March 2027 to review the compliance of their product range and marketing in respect of products that were already on the market before 27 September 2026.

It is worth noting, however, that products already on the market must comply with the new legislation in all other respects from late September onwards. For example, aspirational environmental claims will no longer be permitted in marketing or customer relations without clear, objective, publicly available and verifiable commitments.

Mandatory withdrawal function for online contracts entered into force in June 2026

Another reform requiring action from businesses is the new mandatory withdrawal function, which entered into force this summer. Under the new regulation, traders must enable consumers to withdraw from a contract using a dedicated function whenever consumers have the right to withdraw from a contract concluded via an online interface.

Online retailers, for example, have been required since 19 June 2026 to provide consumers with a separate, clear and easily accessible withdrawal function through which consumers can exercise their statutory right of withdrawal. This requirement is based on an amendment to the Consumer Protection Act, which transposes the revised EU Consumer Rights Directive (2011/83/EU) into national law.

This requirement applies to contracts for goods and services concluded through online interfaces such as websites or applications. The withdrawal function must be easy to find and use – the aim of the amendment is to allow consumers to withdraw from a contract just as easily as they can conclude one, and the function should be designed with this in mind. The new function is intended to complement existing withdrawal methods, such as a withdrawal form or a free-form notification, and does not restrict their use.

Traders should bear in mind that compliance with the mandatory requirements concerning the withdrawal function requires more than simply building the function itself. Contracts, terms and conditions, and the information provided to customers must also be updated to reflect the new regulation.