EU Ecolabel: criteria, award procedure and costs - and what changes on 27 September 2026
The EU Ecolabel under Regulation (EC) No 66/2010 is voluntary, but from 27 September 2026 it becomes legally privileged: the Empowering Consumers Directive bans sustainability labels not based on a certification scheme and defines "recognised excellent environmental performance" explicitly as compliance with the Ecolabel Regulation. Criteria, procedure, fees in figures, and how it relates to ESPR and the digital product passport.
EU Ecolabel: criteria, award procedure and costs - and what changes on 27 September 2026
Key takeaways
The EU Ecolabel - the Flower - is the European Union’s official environmental label, governed by Regulation (EC) No 66/2010. Article 1 says what it is in one word: a voluntary scheme. That was long its weakness, and that is precisely what is changing in effect right now.
On 27 September 2026, national transpositions of the Empowering Consumers Directive (EU) 2024/825 become applicable. From that day it is an unfair commercial practice in all circumstances to display a sustainability label that is not based on a certification scheme or not established by public authorities. And the new concept of “recognised excellent environmental performance”, which a company must be able to demonstrate for any generic environmental claim, is tied in the legal text to exactly two things: compliance with Regulation (EC) No 66/2010, or an officially recognised national or regional EN ISO 14024 type I ecolabelling scheme.
The Ecolabel does not become mandatory. It becomes one of the few named routes by which a sweeping green claim remains lawful in advertising at all.
What the Ecolabel does not do: it does not discharge any obligation under the Ecodesign Regulation, and it does not produce a digital product passport. If you need the basics of the passport first, start with Digital product passport in 15 minutes.
What the EU Ecolabel is in law
Regulation (EC) No 66/2010 replaced Regulation (EC) No 1980/2000 (Article 18). Its scope is remarkably wide: under Article 2(1) it applies to any goods or services supplied for distribution, consumption or use on the Union market, whether in return for payment or free of charge. That is why the Regulation speaks throughout of “products” and means services too.
Article 2(2) carves out exactly three things: medicinal products for human use, veterinary medicinal products, and any type of medical device. Nothing else. So the practical bottleneck is not the scope of the Regulation but whether criteria exist for your product group at all - more on that below.
Four definitions in Article 3 decide how this works day to day:
- Product group - a set of products serving similar purposes, similar in use or in functional properties, and similar in terms of consumer perception. It is the unit criteria apply to, not the individual product.
- Operator - any producer, manufacturer, importer, service provider, wholesaler or retailer. A retailer can be the applicant.
- Environmental performance - the result of a manufacturer’s management of those product characteristics that cause environmental impact.
- Verification - the procedure certifying that a product complies with specified EU Ecolabel criteria.
Article 17 obliges Member States to lay down penalties that are effective, proportionate and dissuasive. The label is voluntary; misusing it is not.
27 September 2026: why a voluntary label suddenly acquires legal weight
Directive (EU) 2024/825 - commonly the EmpCo Directive, “Empowering Consumers for the Green Transition” - amends Directive 2005/29/EC on unfair commercial practices. Its Article 4 sets two dates: Member States had to adopt and publish the implementing measures by 27 March 2026, and they apply them from 27 September 2026.
Annex I to Directive 2005/29/EC is the list of practices that are unfair in all circumstances. No case-by-case assessment, no balancing. The EmpCo Directive inserts, among others:
| New point | Prohibited practice |
|---|---|
| 2a | Displaying a sustainability label that is not based on a certification scheme or not established by public authorities |
| 4a | Making a generic environmental claim for which the trader cannot demonstrate recognised excellent environmental performance |
| 4b | Making an environmental claim about the entire product or business when it concerns only a certain aspect |
| 4c | Claiming neutral, reduced or positive climate impact based on offsetting |
| 10a | Presenting requirements imposed by law on all products in the category as a distinctive feature of your offer |
Three definitions the Directive inserts into Directive 2005/29/EC carry the weight:
“Sustainability label” means any voluntary trust mark, quality mark or equivalent, public or private, that aims to set apart and promote a product, process or business by reference to environmental or social characteristics. Mandatory labels required under Union or national law are expressly excluded - so CE marking and the energy label do not fall within it.
“Certification scheme” means a third-party verification scheme whose terms are publicly available and meet four criteria: it is open on transparent, fair and non-discriminatory terms to all traders willing and able to comply; its requirements are developed by the scheme owner in consultation with relevant experts and stakeholders; it sets out procedures for non-compliance and provides for withdrawal or suspension of the label; and monitoring of compliance is subject to an objective procedure carried out by a third party whose competence and independence from both scheme owner and trader rest on international, Union or national standards.
“Recognised excellent environmental performance” means environmental performance compliant with Regulation (EC) No 66/2010, or with national or regional EN ISO 14024 type I ecolabelling schemes officially recognised in the Member States, or top environmental performance in accordance with other applicable Union law.
The practical consequence is uncomfortably clear. A self-designed green seal on your packaging with no certification scheme behind it is not merely challengeable case by case from 27 September 2026 - it is unfair per se. And a line like “eco-friendly” or “sustainable” without a specification given in clear and prominent terms on the same medium is a generic environmental claim, for which proof of recognised excellent environmental performance is required - a bar the legislator itself calibrated using the Ecolabel and type I schemes.
How EmpCo and the Green Claims debate fit together is set out in Empowering Consumers Directive: greenwashing and DPP and Green Claims Directive and DPP.
Four tiers of environmental proof
After 27 September 2026, environmental claims sort into four practical tiers. It is worth placing your own communication honestly on this ladder:
| Tier | What it is | Legal standing from 27.09.2026 |
|---|---|---|
| Own claim | Self-formulated statement, own seal with no third-party verification | As a label, unfair per se (Annex I point 2a); as a generic claim, defensible only with proof under point 4a |
| Private certification scheme | Third-party verified scheme meeting the four definitional criteria | Lawful as a label; does not by itself establish recognised excellent environmental performance |
| EU Ecolabel / type I label | Regulation (EC) No 66/2010 or an officially recognised EN ISO 14024 scheme | The proof of recognised excellent environmental performance named in the legal text |
| Mandatory labelling | CE marking, energy label, in future the DPP | Not a sustainability label under the Directive - and under point 10a not a selling point |
The last row is underrated. New point 10a prohibits presenting legal obligations as a distinctive feature of your offer. “We have a digital product passport” stops being a marketing line the moment the passport is mandatory for the product group; it becomes a compliance fact. Standing out on environmental performance requires proof above the statutory line.
How the criteria are built - and why they are hard to meet
Article 6(3) requires criteria to be determined on a scientific basis considering the whole life cycle. Seven aspects must be taken into account: the most significant environmental impacts (climate change, nature and biodiversity, energy and resource consumption, waste generation, emissions to all media, physical pollution and the use and release of hazardous substances); the substitution of hazardous substances by safer ones wherever technically feasible; the potential to reduce impacts through durability and reusability; the net environmental balance of benefits and burdens including health and safety; where appropriate social and ethical aspects, referencing instruments such as relevant ILO standards; the criteria of other officially recognised type I labels, to build synergies; and, as far as possible, the principle of reducing animal testing.
Under Article 6(4) the criteria must also ensure that labelled products function adequately for their intended use. The Ecolabel is not a pure environmental mark: it couples environmental performance to fitness for purpose.
The Commission states the ambition level in its own guidance on the Regulation: criteria are based on the best products available on the EEA market over the life cycle and correspond indicatively to the best 10-20 % of products available on the EEA market at the moment the criteria are adopted. By design, this is not a mass-market label.
The substance hurdle where most applications fail
Article 6(6) is the hard edge of the Regulation. The Ecolabel may not be awarded to goods containing substances or mixtures classified as toxic, hazardous to the environment, carcinogenic, mutagenic or toxic for reproduction (CMR) under the CLP Regulation (EC) No 1272/2008, nor to goods containing substances referred to in Article 57 of the REACH Regulation (EC) No 1907/2006.
Article 6(7) allows derogations - but only where substitution is not technically feasible, as such or through alternative materials or designs, or where the product has significantly higher overall environmental performance than comparable goods. Then comes the sentence that decides most cases in practice: no derogation shall be given for substances that meet the Article 57 REACH criteria and are identified under the Article 59(1) procedure (that is, on the Candidate List) and are present in mixtures, in an article or in any homogeneous part of a complex article in concentrations above 0,1 % (w/w).
The 0,1 % threshold and the reference to the homogeneous part are exactly the quantities that trigger the REACH notification and communication duties and the SCIP submission. If your substance data is in order for REACH, you can answer the Ecolabel question in hours; if it is not, you answer it in months. The connection is unpacked in REACH Regulation and the digital product passport.
Procedure and who does what
Under Article 7, the Commission, Member States, competent bodies and other stakeholders may, following consultation of the EUEB (European Union Ecolabelling Board), initiate and lead the development or revision of criteria. The leading party produces six documents: a preliminary report, a proposal for draft criteria, a technical report supporting the proposal, a final report, a manual for potential users and competent bodies, and a manual for authorities awarding public contracts. Where criteria already exist under another type I scheme for a group the Ecolabel does not cover, a shortened procedure under Annex I Part B may apply; Part C covers non-substantial revisions.
Article 8(2) gives the Commission nine months after consulting the EUEB to adopt criteria per product group, published in the Official Journal. Article 8(3) requires four determinations: assessment requirements, three key environmental characteristics for the optional text box on the label, the period of validity of the criteria, and the degree of product variability allowed. Article 8(4) warns against disproportionate burdens on SMEs.
Examples of criteria decisions in force, which show the spread:
| Product group | Decision |
|---|---|
| Graphic paper, and tissue paper and tissue products | Decision (EU) 2019/70 |
| Electronic displays | Decision (EU) 2020/1804 |
| Lubricants | Decision (EU) 2018/1702 |
| Indoor cleaning services | Decision (EU) 2018/680 |
| Laundry detergents | Decision (EU) 2017/1218 |
| Hand dishwashing detergents | Decision (EU) 2017/1214 |
| Dishwasher detergents | Decision (EU) 2017/1216 |
The list is not exhaustive - it shows that covered groups run from detergents and paper through furniture and textiles to services such as tourist accommodation, while technical capital goods are largely absent.
The award procedure step by step
Article 9 sets out the process, and it is more tightly timed than most expect.
1. Apply to the right body. Where the product originates in a single Member State, the application goes to a competent body of that State. Where it originates in the same form in several, any one of them may be chosen. Where it originates outside the Union, apply to a competent body in a Member State where the product is to be or has been placed on the market.
2. Completeness check: two months. The competent body checks within two months of receipt whether the documentation is complete and notifies the operator. If the operator fails to complete the documentation within six months of that notification, the application may be rejected.
3. Verification and registration number. Where the documentation is complete and compliance with the criteria and assessment requirements is verified, the body assigns a registration number to the product. Operators meet the costs of testing and conformity assessment, and may be charged travel and accommodation costs where on-site verification is needed outside the Member State of the competent body.
4. Production sites. Where criteria require production facilities to meet certain requirements, they must be met in all facilities where the labelled product is manufactured (Article 9(6)). Competent bodies preferentially recognise tests accredited to ISO 17025 and verifications by bodies accredited under EN 45011 or an equivalent international standard (Article 9(7)).
5. Contract, then label. The competent body concludes a contract with each operator using the standard template in Annex IV. The label may be placed on the product only after the contract is concluded (Article 9(9)) - and the registration number must go on the product too.
6. Register. The awarding body notifies the Commission, which maintains a regularly updated common register, publicly available on the EU Ecolabel website (Article 9(10)).
Two limits in the same article are routinely missed: the award is without prejudice to environmental or other regulatory requirements of Union or national law applicable across the product’s life stages (Article 9(12)), and the right to use the label does not extend to using the EU Ecolabel as a component of a trademark (Article 9(13)).
Under Article 10, any false or misleading advertising and any label or logo that leads to confusion with the EU Ecolabel is prohibited; the competent body verifies compliance on a regular basis, upon complaint, and by random spot-checks.
Form and number
Annex II - replaced in 2017 by Regulation (EU) 2017/1941 - sets the form: the label, the optional label with text box (three environmental characteristics drawn from the product group criteria), and the registration number in the format xxxx/yyy/zzzzz, where xxxx is the country of registration, yyy the product group and zzzzz the number given by the competent body. It is printed in two colours (Pantone 347 green for the leaves and stem of the flower, the “Є” symbol, the web address and the EU acronym, Pantone 279 for everything else), or black on white, or white on black.
What it costs - in figures
Annex III sets floors and ceilings. Regulation (EU) 2017/1941 replaced only Annex II, so the fee regime stands unchanged:
| Fee | Standard | SMEs and operators in developing countries | Micro-enterprises |
|---|---|---|---|
| Application fee (based on real administrative costs) | no lower than EUR 200, no higher than EUR 1 200 | no higher than EUR 600 | maximum EUR 350 |
| Annual fee (may be required) | up to EUR 1 500 | no higher than EUR 750 | EUR 350 |
The application fee is reduced by 20 % for applicants registered under EMAS and/or certified to ISO 14001. The reduction carries a condition: the applicant must explicitly commit, in its environmental policy, to ensure full compliance of its ecolabelled products with the criteria throughout the validity of the contract, and that commitment must be incorporated into its detailed environmental objectives. ISO 14001 certified applicants demonstrate implementation annually; EMAS registered applicants forward a copy of their annually verified environmental statement.
The annual fee period begins on the date of the award. Not included in these figures, and usually the larger item in practice: laboratory testing, evidence gathering along the supply chain, and - where criteria address production facilities - on-site verification. Article 9(4) makes use of the label conditional on the fees having been paid in due time.
Validity and renewal
According to the Commission, product group criteria are usually valid for three to five years, depending on the Commission decision for each group. They are reviewed before expiry and either revised or prolonged. The administrative difference matters: if criteria are revised, licence holders need to renew their contract; if validity is prolonged, the contract renews automatically. Licence holders may use the label from the date of award until the end of the criteria’s validity.
Ecolabel, ESPR and the digital product passport: where they touch and where they do not
This is where companies either place the Ecolabel correctly or misunderstand it entirely.
The EU itself explained why it moved from labels to obligations. The recitals to the Ecodesign Regulation (EU) 2024/1781 say of instruments such as the EU Ecolabel introduced by Regulation (EC) No 66/2010 that they are broader in scope but have a reduced impact due to the limitations of voluntary approaches. ESPR and the digital product passport are the answer to that finding. The mandatory side is covered in ESPR Regulation: ecodesign requirements.
The Ecolabel is expressly not a misleading label. ESPR prohibits placing on the market products bearing labels likely to mislead or confuse customers by mimicking the labels provided for in that Regulation. The recitals exempt the EU Ecolabel and other nationally or regionally officially recognised EN ISO 14024 type I ecolabels - provided the criteria developed under those schemes are at least as strict as the ecodesign requirements. The exemption is conditional, not blanket.
Ecolabel criteria feed into ecodesign requirements. Under Article 5 ESPR, when preparing ecodesign requirements the Commission must take into consideration relevant technical information used as a basis for or derived from Union law or instruments, including Regulation (EC) No 66/2010, Directive 2010/75/EU, the technical screening criteria adopted under the Taxonomy Regulation (EU) 2020/852 and the EU green public procurement criteria. In practice: today’s Ecolabel criterion is a candidate for tomorrow’s mandatory requirement. Pursuing the label buys you a head start.
The presumption of conformity exists - but only in the legacy stock. Article 9(3) of the Ecodesign Directive 2009/125/EC provides that products awarded the Community Ecolabel are presumed to comply with the ecodesign requirements of the applicable implementing measure, in so far as those requirements are met by the ecolabel. ESPR repealed Directive 2009/125/EC with effect from 18 July 2024, but Article 79(1)(b) keeps Article 9(3), among other provisions, applicable to products regulated by implementing measures adopted under Article 15 of that Directive, until those measures are repealed or declared obsolete. Two points of precision: the cross-reference in Article 9(3) is formally to the repealed Regulation (EC) No 1980/2000, whose successor is Regulation (EC) No 66/2010; and Article 9(4) allowed the Commission to recognise other ecolabels as equivalent.
For ESPR itself, the presumption does not apply. ESPR’s own presumption of conformity (Article 41) rests on harmonised standards and common specifications, not on ecolabels. The Ecolabel is therefore not a route to ESPR conformity and no substitute for the digital product passport. Anyone selling it that way is selling a misconception.
The underlying data is the same. This is the real commercial point. Ecolabel criteria require data on substances and their concentrations, recycled content, durability, repairability and recyclability, energy and resource consumption, and in places emissions and supply chain aspects. Those are the very fields the digital product passport and product-level reporting carry. Build one data layer at the product - unique identifier, maintained substance list, versioned evidence, sourced figures - and it serves the Ecolabel application, the DPP, CE documentation and customer questionnaires from a single source. Build a spreadsheet per occasion and you pay three times. The sequence for that is in How to implement DPP: checklist.
What is not covered - and what you can do about it in 2026
Advisory articles tend to leave this out, yet it decides feasibility.
The Ecolabel exists only for product groups with adopted criteria. For anything else there is no application route. And the Commission’s current guidance on criteria development is explicit: given the priorities set out in the Strategic EU Ecolabel Work Plan 2025-2029, no request for development of criteria for new product groups can be considered in 2026. Proposals are collected and kept for later consideration should resources become available.
Two further tracks are closed or parked:
- Financial products: work on Ecolabel criteria has been discontinued; the output will feed the revision of the Sustainable Finance Disclosure Regulation.
- Food and feed products: after a feasibility study and the EUEB’s opinion, the Commission is currently not intending to develop criteria, while not excluding a revisit in the context of a wider EU food strategy. The basis for that line of enquiry is Article 6(5) of the Regulation.
And Article 11 closes the obvious workaround: where EU Ecolabel criteria for a product group have been published, another nationally or regionally officially recognised type I scheme that did not cover that group at the time of publication may be extended to it only where its criteria are at least as strict as the EU Ecolabel criteria. National labels are not an easier parallel route.
So if you operate in an uncovered product group, from 27 September 2026 you have three realistic options: use an existing officially recognised type I label where it covers your group; choose a private certification scheme that demonstrably meets the four definitional criteria - which makes the label lawful, without carrying generic environmental claims; or drop generic claims and make specific, substantiated ones instead. The third option is the underrated one: point 4a targets the generic claim. A concrete figure specified in clear and prominent terms on the same medium - a substantiated recycled content share, or a product carbon footprint calculated to a recognised method - is not a generic environmental claim. The methodology is in How to calculate a product carbon footprint.
Five steps to prepare
1. Check whether criteria exist for your product group
Without adopted criteria there is no procedure. Check the register of criteria decisions and the validity period of the relevant decision. A decision expiring in eight months is a poor starting point - wait for the revision and work against the new draft criteria in the meantime.
2. Run the substance test first
Treat Article 6(6) and (7) as an exclusion test before anything else. Concretely: if a Candidate List substance is present above 0,1 % by weight in a homogeneous part, the route is closed - no derogation is available for those substances. That is settled in hours if your substance data exists, and it blocks months of work if it does not.
3. Audit your own communication against Annex I
Inventory every seal, icon and environmental claim on packaging, website, data sheets and marketplace listings. For each, ask: is it based on a certification scheme as defined, or established by public authorities? Is the claim specific and specified in clear and prominent terms on the same medium? Is any climate claim based on offsetting? Does it present a legal obligation as a distinctive feature? This belongs before 27 September 2026, not after.
4. Build the data layer once, use it repeatedly
Store the evidence the Ecolabel application requires where the passport data already sits: against the unique product identifier, versioned, with source and date per field. The application then becomes a query rather than a research project - and ESPR and passport obligations draw on the same stock.
5. Plan fees and effort realistically
The regulatory fees are modest (application no higher than EUR 1 200, SMEs EUR 600, micro-enterprises EUR 350; annual fee up to EUR 1 500, with the reduction for EMAS or ISO 14001). Budget laboratory testing, supplier evidence and possible on-site verification separately - those carry the real cost. And schedule against the Article 9 clock: two months for the completeness check, six months to complete the documentation.
Frequently asked questions
Is the EU Ecolabel mandatory from 27 September 2026?
No. It stays voluntary - Article 1 of Regulation (EC) No 66/2010 says so expressly. What changes is the law around it: sustainability labels without a certification scheme become unfair, and the required proof of recognised excellent environmental performance is tied in the legal text to the Ecolabel Regulation and to officially recognised type I schemes. The label does not become mandatory, but it becomes a named route to proof.
Does the Ecolabel replace the digital product passport?
No, in neither direction. The passport is an obligation flowing from ESPR and the relevant delegated acts; the Ecolabel is a voluntary award under its own Regulation. A presumption of conformity for ecodesign requirements exists only in the legacy stock of implementing measures under Directive 2009/125/EC, which ESPR keeps applicable via Article 79(1)(b). ESPR’s own presumption of conformity runs through harmonised standards.
What does the EU Ecolabel actually cost?
The regulatory fees under Annex III: an application fee based on real administrative costs, no lower than EUR 200 and no higher than EUR 1 200 (SMEs and operators in developing countries no higher than EUR 600, micro-enterprises EUR 350), minus 20 % for EMAS registration or ISO 14001 certification; plus a possible annual fee of up to EUR 1 500 (SMEs EUR 750, micro-enterprises EUR 350). Not included: testing, conformity assessment and, where applicable, travel and accommodation for on-site verification outside the competent body’s Member State - the operator bears those under Article 9(5).
My product group is not covered - can I apply to have it added?
In principle any interested stakeholder may submit a proposal for a new product group. In practice, not this year: because of the priorities in the Strategic EU Ecolabel Work Plan 2025-2029, the Commission can consider no request for criteria development for new product groups in 2026. Proposals are collected and reviewed later, if resources allow.
Can I incorporate the Ecolabel into my logo?
No. Article 9(13) states that the right to use the EU Ecolabel does not extend to using it as a component of a trademark. Permitted use is on the awarded products and their associated promotional material (Article 9(11)) - with the registration number.
Read next
- Digital product passport in 15 minutes: what the DPP is and why the EU is introducing it
- ESPR Regulation: ecodesign requirements
- Empowering Consumers Directive: greenwashing and DPP
- Green Claims Directive and DPP
- REACH Regulation and the digital product passport
- How to calculate a product carbon footprint, step by step
- How to implement DPP: checklist
If you want the evidence for an Ecolabel application and the data for the digital product passport to come from one source, myDPP shows how that data layer is built at the product.
Sources
- Regulation (EC) No 66/2010 of the European Parliament and of the Council of 25 November 2009 on the EU Ecolabel: EUR-Lex 32010R0066
- Commission Regulation (EU) 2017/1941 of 24 October 2017 amending Annex II: EUR-Lex 32017R1941
- Directive (EU) 2024/825 (Empowering Consumers) of 28 February 2024: EUR-Lex 32024L0825
- Regulation (EU) 2024/1781 (ESPR) of 13 June 2024: EUR-Lex 32024R1781
- Directive 2009/125/EC (Ecodesign framework), Article 9: EUR-Lex 32009L0125
- European Commission, EU Ecolabel - Product Groups and Criteria: environment.ec.europa.eu