Finland transposes the Empowering Consumers Directive – New obligations for traders on environmental claims

Insights|July 6, 2026

The amendments to the Finnish consumer protection legislation, implementing Directive (EU) 2024/825 on empowering consumers for the green transition (the “Directive”) have been approved on 26 June 2026 (Consumer Protection Act, 38/1978, as amended) and on 2 July 2027 (The Government Decree on Unfair Commercial Practices in Marketing and Customer Relationships). The amendments will enter into force on 27 September 2026.

Background

The Directive aims to promote green transition, particularly by advancing the circular economy and a clean and green economy. The objective of the Directive is to ensure that consumers are provided with better information at the point of sale on the durability and repairability of goods and the consumers’ legal guarantee rights. The amendments to Finnish consumer protection legislation focus on information provided in marketing and the trader’s pre-contractual disclosure obligations, with the dual aim of increasing consumer awareness of the environmental impact of goods and of more effectively addressing the presentation of false or misleading environmental claims.

Key changes

1. New prohibitions on misleading claims

The amendments include new prohibitions on presenting misleading environmental or otherwise irrelevant claims in marketing. The following new prohibitions are introduced in Chapter 2 of the Consumer Protection Act:

• Prohibition on false or misleading information about environmental properties: a prohibition concerning the provision of false or misleading information about a product’s durability, repairability and recyclability, as well as other environmental, social and circular economy characteristics of consumer goods.
• Prohibition on irrelevant claims: aprohibition of marketing a consumer good on the basis of characteristics that are irrelevant and not based on the properties of the product, the trader or the trader’s business, if such marketing is likely to lead the consumer to make a purchasing or other decision they would not otherwise have made. An example of such irrelevant claim would be advertising that bottled spring water is gluten-free, or that sugar is lactose-free.
• Prohibition on unsubstantiated future environmental claims: a prohibition of the use of an environmental claim regarding a future level of environmental performance in marketing or in a customer relationship, unless it is supported by clear, impartial, publicly available and verifiable commitments, where the claim is likely to influence a consumer’s purchasing decision. Such claim could concern, for example, future carbon or climate neutrality. It is required that the commitments are set out in a detailed and feasible implementation plan whose progress is regularly verified by an independent third party.

2. New pre-contractual disclosure obligations

The following pre-contractual obligations are added to Chapters 2 and 6 of the Consumer Protection Act:

• Obligations concerning the harmonized notice on statutory liability for defects: traders are required to provide the harmonized notice on statutory liability for defects, as defined and illustrated in the European Commission Implementing Regulation (EU) 2025/1960 on the content and format of the harmonized notice and harmonized label. In in-store sales, the notice may be displayed, e.g., near the checkouts. In an online store, a general reminder is sufficient. Personal notification of each consumer is not needed in either case.
• Obligations concerning the commercial guarantee of durability: if the producer of a product offers, without additional charge, a guarantee covering the product for more than two years, traders are required to disclose such commercial durability guarantee in a format provided in the European Commission Implementing Regulation (EU) 2025/1960. The label may be attached to the product or its packaging or placed in a clearly visible manner on the product shelf where goods covered by such a guarantee are displayed. In an online store, the label may be placed next to the image of the product. However, the label may not be located inside the product’s packaging, as in that case it would no longer constitute pre-contractual information provided to consumers.
• Obligations concerning free software updates: traders are required to disclose the minimum period during which a producer or service provider will supply free security and other updates necessary to maintain the conformity of goods with digital elements, digital content and digital services (provided this information is available to the trader).
• Obligations concerning the product’s repairability score: traders must disclose the product’s repairability score, or, if no such score exists, information on the availability of repair and maintenance manuals, repair restrictions, and the availability, estimated costs, and ordering procedures for spare parts necessary to maintain conformity.
• Obligations regarding environmental comparison services: if a trader offers a service that compares consumer goods and provides consumers with information on their sustainability, repairability, recyclability or other environmental, circular economy or social characteristics, the trader must disclose the comparison methodology used, the goods and their suppliers being compared, and how the information is kept up to date.
• Obligations concerning eco-friendly delivery options: traders are required to inform consumers of any available eco-friendly delivery options, where such options exist. If information on eco-friendly delivery is provided, the trader must also comply with the rules on general environmental claims.

3. Expansion of the “black list” of prohibited commercial practices

The Government Decree on Unfair Commercial Practices in Marketing and Customer Relationships (the “Decree”), which contains the so-called “black list” of practices that are always prohibited, is expanded. The following are among the new prohibited practices of particular relevance to traders making sustainability or environmental claims:

• Presenting a sustainability label that is not based on a certification scheme or has not been approved by a public authority;
• Presenting a generic environmental claim without the trader being able to demonstrate a recognized excellent environmental performance level relevant to the claim;
• Making an environmental claim about an entire product or the trader’s entire business where the claim only concerns a specific part or aspect of the product or a specific activity of the business;
• Claiming that a product has a neutral, reduced or positive environmental impact where the claim is based on greenhouse gas emission offsetting.

For the purposes of the Decree, a “sustainability label” means a voluntary label concerning the environmental or social characteristics of a consumer good, process or undertaking, designed to promote the good’s sale by distinguishing it from others. Sustainability labels exclude any mandatory label required under EU or national law.

Further, a “generic environmental claim” means an environmental claim not included in a sustainability label that is presented in writing or orally and is not specified in a clear and prominent manner in the same medium. Examples of general environmental claims include “environmentally friendly”, “eco-friendly”, “green”, “nature’s friend”, “ecological”, “environmentally correct”, “climate friendly”, “gentle on the environment”, “carbon friendly”, “energy efficient”, “biodegradable”, “biobased” or similar statements that suggest or create the impression of excellent environmental performance

A “recognized excellent environmental performance level” refers to the level corresponding to the EU Ecolabel Regulation (EC) No 66/2010 or to officially recognized national or regional type I ecolabel schemes under EN ISO 14024 standard, or the best available level under other applicable laws.

4. Administrative sanctions imposed on the trader

The new prohibitions and the pre-contractual obligations will be brought within the scope of the administrative sanction regime of the Consumer Protection Act. This means that, as the most significant financial consequence, the Consumer Ombudsman will be able to propose an administrative fine to be imposed on a trader.

Transitional period for products placed on the market

A notable feature of the Finnish implementation concerns the transitional period for goods already on the market (concerning Section 2, Subsections 4, 29 and 30 of the Decree). The Decree provides for a national six-month transitional period for sustainability labels and environmental claims contained in goods already placed on the market before the Decree’s entry into force. This transitional period is not provided for in the Directive. Nevertheless, it is considered necessary given the length of supply chains and the risk of unnecessary product wastage.

Under this arrangement, the abovementioned provisions of the Decree relating to sustainability labels and environmental claims do not apply until 27 March 2027 to marketing conducted by means of markings on goods or their packaging placed on the market before 27 September 2026.

What does this mean for businesses?

The most significant changes relate to the sustainability label requirements and presenting environmental claims, since the new rules will materially change the current use of environmental and sustainability labels.

The new rules on sustainability labels and environmental claims will require traders to review their marketing materials and prepare new guidelines. Products packed or labeled under previous practices that contain, for example, prohibited environmental claims or inadequate labels may need to be withdrawn from the market or relabeled to comply with the new requirements once they start to apply.

Businesses should review their marketing materials, sustainability labels and product information practices in advance of the 27 September 2026 application date. In particular, traders should assess whether their current sustainability labels comply with the new certification requirements, whether any forward-looking environmental claims meet the substantiation requirements under the amended provisions, and whether their pre-contractual disclosure processes are updated to reflect the new harmonized notices and labels.