EMPCO · OLD STOCK · 28 SEPTEMBER 2026
Do the new EU green-claim rules apply to packaging printed before 27 September 2026?
Yes: the Commission’s September guidance says the rules also reach packaging already made, ordered, distributed or on retailers’ shelves before the application date. That does not create an automatic instruction to destroy every old pack.
Old stock is in scope. The remedy still needs a case-specific decision.
Directive (EU) 2024/825 applies from 27 September 2026. The Commission FAQ discusses old stock, while the CPC network describes reasonable and proportionate enforcement considerations. These materials are interpretive or coordination guidance—not a blanket exemption, guaranteed sticker solution or binding safe harbour.
Start with the exact printed version and where its units are.
- Identify the environmental wording, badge or image on each artwork version—not just the latest approved file.
- Link the version to SKUs, countries, batches and shelf life.
- Record known units separately at warehouse, distributor and retailer; leave an unknown quantity unknown.
- Compare the printed claim with the website, marketplace listing, paid ad and point-of-sale material.
- Keep the evidence and a named owner for each proposed change.
A scanner can flag a claim pattern, but it cannot tell whether a particular retailer has 500 or 5,000 units or whether a corrective notice is sufficient in a particular case.
Prioritise practical corrections without inventing an exemption.
The CPC approach may take account of stock size, packaging cycles, earlier orders, shelf life and the feasibility of corrective action. Possible actions include changing online copy, correcting future packaging, changing advertising and providing additional point-of-sale information. For a printed pack, an over-sticker or POS notice needs specific legal and operational review; neither is automatically adequate.
Record the decision, responsible person, affected markets, execution evidence and a fresh claim review. Keep “proposed”, “implemented” and “verified” separate states. This avoids treating an intended action as a completed correction.
See how an old-stock exposure ledger works.
The sample workspace links claim findings to artwork versions and known/unknown channel stock. It does not accept uploads, save your inventory or make a legal remediation decision.
Read the rule and the old-stock guidance.
Directive (EU) 2024/825 — empowering consumers for the green transitionEuropean Union ↗Questions and Answers on Directive (EU) 2024/825 · September 2026, Q18European Commission services ↗Common Understanding on old stock and proportionate enforcementConsumer Protection Cooperation Network ↗Source state checked 28 September 2026. The Commission FAQ states preliminary views of Commission services; only the Court of Justice can give an authoritative interpretation of EU law. This article is educational, not a decision about any specific stock, remedy or national enforcement case.