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One packaging, multiple markets: the risk of environmental claims in food supplements across Europe
The same food supplement packaging is sold in Spain, France, Germany and the Netherlands bearing the environmental claim “sustainable packaging” on the front panel. In each market a different authority will read it, with a different administrative practice. The regulatory risk does not depend on which country has transposed Directive 2024/825, it depends on who acts and how.
The mistake: ranking risk by transposition dates
The usual response to Directive (EU) 2024/825 in a multi-country strategy is to check which Member States have transposed it and adjust packaging to the calendar. Germany and the Netherlands already apply the new rules. Spain and France had not transposed them as of May 2026. The conclusion seems clear: the risk is in the first two.
Yet the precedents from decided cases say the opposite.
Italy, August 2025. The AGCM fined Shein’s operator one million euros for misleading and omissive environmental claims. It applied the Italian Consumer Code in force, not the Directive.
Germany, June 2024. The Bundesgerichtshof (Katjes, I ZR 98/23) held that the meaning of “climate-neutral” must be explained in the advertisement itself. It applied the UWG, before any transposition.
Netherlands, April 2024. Following intervention by the ACM, Albert Heijn withdrew claims such as “the most sustainable supermarket.” There was no fine: the authority’s guidance on sustainability claims was sufficient.
France, since 2022. The AGEC Act already prohibits references such as “environmentally friendly” on products and packaging. The Climate and Resilience Act has regulated carbon neutrality claims since 2023.
Regulatory risk does not begin with transposition: the Directive harmonises a standard that the most active authorities were already applying.
Three enforcement channels that differ by country
Consumer and competition authorities. The Dutch ACM, the Italian AGCM and the French DGCCRF each have their own administrative practice on environmental claims. In Spain, consumer enforcement is devolved to the autonomous communities, which multiplies the criteria in play.
Competitors and associations. In Germany the out-of-court competitor warning notice (Abmahnung) is the standard route. The Wettbewerbszentrale and associations such as Deutsche Umwelthilfe use it systematically. A weak environmental claim can attract a notice within weeks, with no administrative intervention needed.
Official food notification and inspection. Directive 2002/46/EC requires notification of the food supplement together with its label. The receiving authority does not assess the environmental claim. But the claim goes on file, and it is the first thing an inspector looks at during an audit.
Translation is a regulatory decision
The Directive does not prohibit a specific and delimited claim, such as “cardboard box made with 80% recycled fibre.” It requires that the qualification be clearly and visibly stated on the same medium. In German, that qualification takes considerably more space. If the design team moves it to the back panel to make it fit, the front panel is left with a generic claim — and the claim changes legal category. The same phrase is valid in Spanish and prohibited in German because of a layout decision.
The supporting file
Every environmental claim needs a supporting file that identifies: the component or aspect it refers to; the method, certificate or certification scheme that proves it; the validity dates; and the approved wording in each language and its location on the packaging.
A cardboard certificate does not cover the capsule, the cap or the blister pack. If a translation broadens the promise, evidence based on the original text is no longer enough. For stock already printed, see the article on Spain.
A multi-country strategy is not about translating the same claim. Unlike health claims, environmental claims require deciding, before printing, whether each claim can be sustained in every market where the product will be sold. That decision calls for regulatory expertise on each country’s administrative practice, not a table of dates. At LegaleGo we do not file paperwork, we decide.
