In short: Vague words such as “eco-friendly”, “green” or “sustainable” are what regulators target, and a claim made in a video is still a claim. EU Directive 2024/825 tells Member States to apply new rules from 27 September 2026, including a ban on generic environmental claims without demonstrated performance; the FTC’s Green Guides say marketers should not make unqualified general environmental benefit claims; and the UK’s CMA published a fashion-specific guide in 2024. For UGC, creators should describe what they see and have done, and brands should supply only claims they can prove.
Why fashion UGC runs into this
Fashion creators talk about fabric, packaging and values: “this is so sustainable”, “eco-friendly”, “made responsibly”. In a UGC video those words are easy to say and hard to support. When a brand runs the video as an ad, the claim is part of the brand’s advertising. That is why it belongs in the brief and in the review, the same way cosmetic claims do (see cosmetic claims in UGC).
This is general information, not legal advice. Rules depend on the country where the ad runs.
European Union: Directive 2024/825
The Directive on empowering consumers for the green transition (EU) 2024/825 amends, among others, the EU rules on unfair commercial practices. Its Article 4 says Member States had to adopt and publish the necessary measures by 27 March 2026 and “shall apply those measures from 27 September 2026”. National laws decide the details, so check the law of the country where you advertise. The text bans, among other things:
- Generic environmental claims without demonstrated performance. Annex I point 4a prohibits a generic environmental claim for which the trader cannot demonstrate recognized excellent environmental performance relevant to the claim.
- Offset-based impact claims. Point 4c prohibits claiming, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions.
- Unbacked sustainability labels. Point 2a prohibits displaying a sustainability label that is not based on a certification scheme or not established by public authorities.
The Directive’s definition of a generic environmental claim covers claims “made in written or oral form, including through audiovisual media”, so a claim spoken in a video is within its scope. Bird & Bird’s summary notes that terms like “green” or “eco-friendly” are generic unless the context explains them, and that claims about future environmental performance are also restricted. Whether a particular claim is allowed is a question for the national authorities and your adviser.
United States: the Green Guides
The FTC’s Green Guides (16 CFR 260.4) say that “unqualified general environmental benefit claims are difficult to interpret and likely convey a wide range of meanings” and that marketers should not make them. Marketers can qualify a claim with “clear and prominent qualifying language that limits the claim to a specific benefit or benefits.” The Guides’ own example is “Eco-friendly”, which they say likely conveys that a product has far-reaching environmental benefits. A specific statement such as “made with recycled materials” can change the result, but only if the conditions in the Guides are met.
United Kingdom: the CMA’s fashion guide
SGS reports that the CMA published a compliance guide for fashion on 18 September 2024, covering environmental claims about clothing, footwear, fashion accessories and related services such as packaging, delivery and returns. As SGS summarizes it, the guide stresses that environmental claims must be evidence-based and capable of being substantiated, that hiding or omitting important information is not acceptable, and that a claim should say whether it covers only part of a product’s lifecycle. Check the CMA’s own text before you rely on it.
Say this, not that
The wording below is our suggestion. A specific statement is only fine if it is true and the brand can back it up.
| Instead of | Say (if true and supplied by the brand) |
|---|---|
| “This is so eco-friendly” | “The tag says it is made with recycled polyester” |
| “Sustainable fashion” | “I have worn it for two months and washed it ten times” |
| “Carbon neutral” | Leave it out unless the brand supplies a claim it can prove |
| “Ethical brand” | Describe what you can see, such as the care label |
| A logo or badge you found online | Only a label the brand actually holds |
Checklist for brands
- List the environmental claims creators may repeat, with the exact wording and the evidence you hold for each one.
- Ask creators to avoid “eco”, “green”, “sustainable” and “conscious” unless your list uses that word in that context.
- Name a certification or label only if the product holds it.
- Check captions, on-screen text and spoken words during review. See how to review UGC videos.
- Do not ask for offset-based or future-promise claims unless your adviser has cleared them.
Checklist for creators
- Describe what you see and have done: fabric on the label, how it holds up, how it fits. Fit is covered in fashion try-on and fit videos.
- Use only the environmental claims the brief gives you, in the words it gives you.
- Do not add your own “sustainable” or “eco” because it sounds good.
- If you are not sure a claim is supported, ask the brand for the evidence or leave it out.
On Usicri
Under the Terms of Service, brands are solely responsible for the content and legality of their campaign requests, including the accuracy of the product information they give and any claims they ask creators to make, and creators are solely responsible for the content of the videos they submit (section 3). Misleading content is not allowed (section 8.1). Put the claims list in your campaign description. Usicri does not check videos for compliance with advertising law, so the checklists above are for you. See open campaigns and the UGC brief template for fashion.