How to verify environmental claims, labels, evidence, and the effective date of the law.
Status checked: November 2, 2026. We are not a law firm. This guide is for informational and educational purposes; it is not individual legal or tax advice. Regulations and drafts may change. Before making decisions regarding your business, check the current text of the law and consult the matter with the appropriate specialist.
Legal Status and Main Principles
The Act of September 4, 2026, amending the Act on Counteracting Unfair Market Practices and the Act on Consumer Rights was announced on October 19, 2026. The main effective date is September 27, 2027. The information that the act is still awaiting signature and announcement is now outdated. Dziennik Ustaw, item 1353.
The changes relate to practices towards consumers. They concern, among other things, general environmental claims without demonstrating recognized outstanding results in ecology, certain sustainable labels, and claims about the neutral or limited impact of a product on the climate based on compensating greenhouse gas emissions. The specific assessment depends on the wording of the declaration, its context, and statutory conditions.
Not every use of the word “eco” is automatically prohibited, and simply having any certificate does not guarantee the legality of every claim. It is necessary to check whether the message is general or explains a specific feature, what the evidence pertains to, and whether the recipient will not relate it to the entire product when it just justifies one part. Similarly, declarations about future environmental outcomes require particular diligence.
Example: the statement “packaging contains 80% recycled material” may be more specific than just “eco-friendly product,” but only if the percentage is correct, the method of calculation is documented, and the recipient knows which part of the packaging it refers to. Also verify the messages from the manufacturer repeated in their own store.
What to do: collect claims from packaging, advertisements, websites, product descriptions, and social media. For each, note the content, product, source, and current evidence. Request documentation from suppliers, determine who is responsible for approving changes, and check the risk with a lawyer before the next print run of packaging. Currently, general regulations also prohibit misleading consumers.
Where the Company Submits Environmental Declarations
It is not only the product label that matters. The declaration can appear in online descriptions, advertisements, customer materials, names, logos, or markings. When assessing the message, one should look at the whole: text, image, color scheme, and the impression made on the average consumer. It is important whether it refers to the entire product, its part, packaging, or the entrepreneur's activities.
How to Build a Register of Claims and Evidence
- Write down the claim and indicate the product and channels where it is used.
- Establish the exact scope of the claim and check whether the recipient might understand it more broadly.
- Record the source of the evidence, date, method of calculations, and limitations. Check whether the document pertains to the current product.
- For labels, verify who grants them, what the conditions are, and whether the product actually meets them.
- Plan to remove or improve messages before ordering the next batch of packaging.
Do Not Confuse Emission Reduction with Compensation
If the claim of climate neutrality is based on compensation, check the detailed prohibition and scope resulting from the amendment. Information about the company's environmental activities may require a different assessment than a claim regarding a specific product. Do not replace legal analysis with the simple assumption that purchasing compensation allows you to label the product as neutral without restrictions.
In relations with the manufacturer or wholesaler, determine who has the documentation and to what extent marketing materials can be used. The seller should know the basis of their own product description, even if they received it from the supplier.
Sources
| Document | Scope |
|---|---|
| Dziennik Ustaw: Act of September 4, 2026 | Regulations, draft, or official explanations. |
| Senate: legislative process of the act | Regulations, draft, or official explanations. |
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