Effective September 27, 2026, environmental claims and sustainability labels must comply with the new regulations even when they apply to products already in the distribution chain. There is no transition period. To bring communications regarding existing inventory into compliance, practical solutions may be used, such as covering or correcting claims with adhesive labels (“stickers”) or adding corrective information at the point of sale, near the affected products and clearly identifying them.
In applying the new rules, the competent national authorities may take into account the severity of the violations, the specific circumstances, and the reasonable and proportionate efforts made by companies to comply. The European guidelines on so-called “old stock situations” favor a proportionate approach, but they do not exempt companies from taking action and do not justify practices that were already noncompliant under the previous regulations.
In this context, the MIMIT circular dated August 27, 2026, specifies that, for durable goods already manufactured or placed on the market before September 27, 2026—provided that this fact can be documented— packaging may be brought into compliance at the end of a reasonable shelf life period for the relevant product category, tentatively set at six months. However, it remains necessary to adopt, as of September 27, 2026, reasonable and proportionate measures to ensure compliance with the new provisions. This guidance therefore does not constitute a blanket six-month extension.
Last modified on 09/10/2026