The EU Ecolabel

Visual referenceSource-linked artwork

Marks are shown for identification, research and commentary. Certification and scheme artwork may be protected; consult the issuing body's current rules before reproducing it on products or packaging.

What the label certifies

The EU Ecolabel is an official voluntary Type I environmental label. It is awarded to products and services that fall within an established product group and meet the life-cycle criteria for that group. Award is not self-declared: a competent body designated by the Member State verifies the application and grants a licence to use the Flower logo. The scheme identifies environmental performance associated with the better-performing share of products on the European Economic Area market, assessed across the life cycle. It does not certify a single characteristic such as recyclability, recycled content or compostability.

Two consequences follow for packaging. The first is scope. Packaging does not appear as a standalone product group in the Commission’s current list of groups and criteria. A manufacturer cannot therefore submit an ordinary empty package for an EU Ecolabel merely because it is recyclable, lightweight or made in part from recycled material.

The second concerns the more common case, in which packaging is not the certified product but a criterion within the award made for something else. Criteria decisions for detergents, personal-care products, paints and other covered groups typically contain packaging requirements addressing matters such as material composition, weight-to-content ratios, dosage devices or the recyclability of components. Compliance with those requirements is a condition of the award for the product; it is not a separate certification of the packaging, and it does not generate an entitlement to describe the packaging as certified.

On-pack use and obligated party

The obligated party is the licence holder. Only a valid licence holder, together with persons authorised under the terms of the licence and the applicable logo rules, may display the EU Ecolabel on the certified product, on its packaging or in promotional material. The mark identifies the certified product; presentation which suggests that the packaging has itself received a separate award misstates the basis of the licence. Packaging used for promotional samples is not excluded from the criteria, and must still satisfy the packaging requirements of the relevant product group.

Licences are conditioned on the continued accuracy of the application. Changes to the product name, trademark, formulation or packaging that could affect compliance fall to be notified to the competent body, so that the body can determine whether the licence continues to be supported.

Supervision is provided for by Article 10 of Regulation (EC) No 66/2010, which is headed "Market surveillance and control of the use of the EU Ecolabel" and requires competent bodies to verify on a regular basis that a product bearing the label complies with the criteria and assessment requirements published under Article 8. The Article also prohibits false or misleading advertising and the use of any label or logo leading to confusion with the EU Ecolabel, and provides for investigation including spot checks and, where required, on-site inspection. Competent bodies may request documentation, suspend or terminate the right to use the label, and address improper use. National consumer-protection and trade-mark remedies operate in addition. No sanction attaches to a decision not to seek the voluntary label; exposure arises from unauthorised or misleading use.

Scope of the recognition under Directive (EU) 2024/825

Directive (EU) 2024/825, which amends Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition, increases the significance of the EU Ecolabel for claims purposes. Member States were required to transpose the Directive by 27 March 2026 and to apply the transposing measures from 27 September 2026.

The Directive prohibits the display of sustainability labels that are neither based on a certification scheme meeting the specified conditions nor established by a public authority. It identifies the EU Ecolabel as a label established by a public authority, and treats compliance with Regulation (EC) No 66/2010 as recognised excellent environmental performance for the purposes of the regime governing generic environmental claims.

That recognition operates as a limited and conditional protection rather than as a general authorisation for environmental statements. A generic environmental claim is permitted only where the recognised excellent environmental performance is relevant to the claim being made. The Directive's own illustration is that a product cannot rely on an EU Ecolabel to describe itself as "biodegradable" where the applicable Ecolabel criteria do not test biodegradability. The same reasoning applies to packaging-specific assertions: an EU Ecolabel awarded in respect of a packaged product does not, without more, substantiate a claim that the packaging is "recyclable", that it is "plastic free", or that it possesses any other property which the relevant criteria decision does not address. The relationship between the criteria actually applied and the claim actually made is therefore the operative question, and it must be established criterion by criterion rather than by reference to the award as a whole.

Interaction with PPWR claims rules

Regulation (EU) 2025/40 adds a packaging-specific constraint through Article 14. Where the Regulation lays down a legal requirement in respect of a property of packaging, an environmental claim relating to that property may be made only in respect of performance exceeding the applicable minimum requirement, and the claim must specify whether it relates to the packaging unit, to a part of the unit or to the operator's packaging portfolio. Compliance is to be demonstrated in the technical documentation.

An EU Ecolabel may contribute evidence towards such a claim where the criteria applied address the property in question directly, but it does not displace Article 14, and it does not answer the questions Article 14 poses about the level of performance claimed or the object to which the claim attaches. Two distinct regimes therefore operate in parallel from late 2026 onwards: the unfair-commercial-practices regime as amended by Directive (EU) 2024/825, which governs whether an environmental claim may be made to consumers at all, and Article 14 of Regulation (EU) 2025/40, which governs the form and substantiation of claims about regulated packaging properties.

The scope for accurate use of the mark in a packaging context is correspondingly narrow but well defined. Material identifying which product is licensed, which criteria decision applies and which property that decision tests remains within the scope of the licence. Presentation of the Flower as a general packaging or recycling mark does not.

Primary sources

• Regulation (EC) No 66/2010 on the EU Ecolabel — Open source
• Directive (EU) 2024/825 on empowering consumers for the green transition — Open source
• Regulation (EU) 2025/40 on packaging and packaging waste (Article 14) — Open source
• European Commission, EU Ecolabel home page, with links to product groups and criteria and to branding guidance — Open source

Note on sources and verification

The text of Article 10 of Regulation (EC) No 66/2010 was consulted directly and supports the account of market surveillance, the prohibition on confusing labels and logos, and the competent bodies' investigative powers. The full title and date of Directive (EU) 2024/825 were confirmed from EUR-Lex; its operative provisions on sustainability labels, on the EU Ecolabel as a public-authority label, on recognised excellent environmental performance and on the biodegradability illustration were not retrieved in text form for this page, and are carried from the draft material underlying it. The transposition date of 27 March 2026 and the application date of 27 September 2026 are stated on the same basis and were not read from the Directive's final provisions.

The statement that no product group for packaging as such exists in the Commission's current list is established negatively, by reference to the published list of product groups, and would require revision if a group were adopted. The examples of paper carrier bags and wrapping paper as items falling within existing groups, and the description of packaging requirements within criteria decisions for detergents, personal-care products and paints, are given at the level of generality found in the draft material; no individual criteria decision was consulted, and no specific criterion is cited here.

The account of Article 14 of Regulation (EU) 2025/40 reproduces the draft material's summary of the provision and was not verified against the Regulation's text for this page.

The analysis would change on adoption of an EU Ecolabel product group covering packaging, on publication of Commission guidance on the interaction between the Ecolabel and the amended unfair-commercial-practices regime, or on adoption of implementing measures under Article 14 of Regulation (EU) 2025/40.

Last verified: 19 August 2026.