The European Union (Empowering Consumers for the Green Transition) Regulations 2026 (S.I. No. 124/2026) (“Regulations”) apply from 27 September 2026 to traders selling products, services or digital content to consumers in the EU, whether instore or online. While the Regulations focus on consumer-facing practices, they will affect the wider supply chain, including retailers, manufacturers, online marketplaces and service providers.

The Regulations introduce important changes and update two key pieces of Irish consumer law, namely the Consumer Protection Act 2007 (governing unfair and misleading commercial practices) and the Consumer Rights Act 2022 (setting out information requirements for consumer contracts).

From 27 September 2026, all traders must provide clearer, more accurate pre-contractual information, particularly regarding environmental claims and product durability.

Key Changes

1. Consumer Notices and Labels: All traders must display an official EU “Harmonised Notice” in a prominent position at points of sale, both instore and online. This notice alerts consumers to their statutory rights under the mandatory two-year legal guarantee of conformity with the sales contract, for goods sold in the EU. It informs consumers of their rights regarding refunds, repair and replacement of goods. There are strict requirements about not altering the standard format of the “Harmonised Notice”. In addition to this, where a product has a free commercial guarantee of durability, exceeding the minimum two-year period, that applies to the whole product and the producer/manufacturer has made that information available, a separate official EU “Harmonised Label” must also be clearly displayed.
2. Environmental Claims: Any environmental claim about a product or service must be factual, verifiable and backed up by evidence. Generic environmental claims that a product is “eco-friendly” or “100% recyclable” are automatically prohibited unless it can be demonstrated that the product or service has recognised excellent environmental performance to substantiate these claims. This extends to future environmental performance claims. For example, claiming a product “will be carbon neutral by 2035”, is misleading unless there is a clear and measurable implementation plan, that is realistic, publicly available and verified by an independent third-party. Any false or unsubstantiated claims about a product’s environmental performance, social characteristics, durability, or recyclability will be misleading and, therefore illegal.
3. Sustainability Labels: Any sustainability labels, such as a quality mark that aims to set apart and promote a product by reference to its environmental or social characteristics, must be based on a recognised certification scheme or a public authority label with independent verification.
4. Goods with Digital Elements: The Regulations bring “goods with digital elements” firmly within the rules on misleading commercial practices. It will be a prohibited commercial practice for a trader to withhold information from a consumer about the fact that a software update will negatively impact on the functioning of goods with digital elements or the use of digital content or digital services.
5. Consumer Information: The Regulations expand pre-contractual information requirements. Traders must now actively provide consumers with clear details regarding product durability, repairability and availability of software updates.

Enforcement

The Competition and Consumer Protection Commission has a range of enforcement powers in respect of breaches of consumer protection law, including the power to issue compliance notices, seek prohibition orders and, in serious cases, pursue criminal sanctions. 

Next Steps for Retailers and Businesses

The Regulations come into legal effect on 27 September 2026 and significantly raise the standard for retailers and businesses to provide clearer, more accurate pre-contractual information, particularly regarding environmental claims and product durability.

Retailers and businesses should be familiar with the regulations. To prepare, the following steps should be considered:

• Review all consumer-facing marketing materials, product labels, instore signage and online product listings to ensure environmental claims are accurate, substantiated and compliant
• Update any pre-contract information processes to reflect the new consumer information requirements
• Engage with manufacturers and producers to secure independent verification for any sustainability labels or long-term durability guarantees
• Review internal compliance and approval procedures for marketing and advertising content.

For further information on the Regulation and its potential impact on your business, please contact Matthew Austin, Partner or Laura O’Farrell, Senior Associate in our Commercial and Business team.