For a brand with several thousand ASINs across five markets, that is not a campaign adjustment. It is a job for the entire catalogue. It sounds like more work than it turns out to be: the affected vocabulary is a manageable set, and most of the work is translation rather than deletion. 

What exactly changes on 27 September? 

Behind the date sits Directive (EU) 2024/825, known as EmpCo. It is not a separate law; it amends existing consumer and competition law. In Germany the implementation is an amendment to the UWG, published in February 2026. There is no transition or sell-through period. 

One phrase carries the whole change: per se. Until now, someone had to demonstrate that a particular claim in a particular context misled a consumer. From the cut-off, several environmental claims sit on a blacklist, and anything on that list is unlawful without any case-by-case assessment. What stays uncertain is no longer the legality of the claim, only whether anyone looks. 

That is where it gets uncomfortable. In Germany, enforcement runs largely through private action: competitors, the Wettbewerbszentrale and consumer associations. Because no proof of actual deception is needed any more, the cost of bringing a case drops sharply. A screenshot comes close to sufficient evidence. If you already manage Amazon with a compliance lens, the pattern is familiar from the GPSR obligations: a single field decides, and it never shows up in standard reporting. 

There is a seventh point that has nothing to do with greenwashing and is routinely missed: for goods with digital elements you now have to state the period covered by software and security updates, plus information on repair and spare parts and a harmonised notice on statutory warranty rights. So for beauty, food and household the topic is vocabulary. For consumer electronics it is missing mandatory information. 

Where do these claims sit in a listing? 

Wider than most teams assume. The rules cover not only sentences but images, symbols, seals and even brand and product names, as soon as they convey an environmental benefit. On a product detail page that means the title, bullets, description, A+ content including the text inside its graphics, secondary images, the Brand Store, and the names of variations and product lines. 

The last two are the ones almost nobody has on their radar. A sub-line called “EcoLine” is an environmental claim in the legal sense, and that cannot be fixed by rewriting a bullet point. 

One more thing slips through routinely: seals and green icons that exist as pixels inside an A+ graphic are out of reach for a plain keyword search. That is exactly why most brands never find them, even though the clearest infringements tend to sit there. 

Why the working window is tighter than the date suggests 

There is no sell-through window. From the cut-off, non-compliant claims are unlawful on stock and material produced earlier. Every ASIN that is live is in scope, not just newly created ones. 

Then there is lead time. A+ approval, image production and feed cycles take weeks. Work commissioned in early September will realistically not be live by 27 September. 

Enforcement will be selective rather than systematic. No authority scans catalogues automatically on 28 September. What gets picked are recognisable names and clear-cut cases: a long-tail ASIN with “eco” in a bullet is not the first target, a bestseller with “climate neutral” in the title is. And the expensive part is rarely the cease-and-desist itself but the undertaking signed afterwards, which binds permanently and carries a contractual penalty for every repeat. 

This is why a single check in August is not enough. Amazon began replacing over-length titles with AI-generated versions in late July 2026 under the title change to 75 characters. A catalogue that is being rewritten automatically is the worst possible place to rely on a snapshot. 

How Remdash helps you check 

This is what our claim audit is for: a one-off inventory of the critical wording across the entire catalogue, optionally extended by monthly monitoring that keeps the check live after the cut-off. 

Finding the claims is automated across text and images. Title, bullets, description, A+ modules and attributes are already held as text in Remdash, our AI-powered growth platform for Amazon, because every monitored product page is monitored at least daily. Claims that exist as pixels inside an A+ graphic are read automatically as well. 

The next step is automated too, and few people expect it: deciding whether a word is actually being used as an environmental claim. “Green” on a green kettle is a colour, not a claim, and the tool works that out. Only genuinely ambiguous cases go to a human. In a recent audit that was nine items out of 4,021. The legal call on the flagged set stays with your legal team, but they are looking at a filtered list rather than doing the finding.