Green Claims on Jewelry Packaging: What You Can Actually Say From September 2026 - FSC CRAFT

Every packaging spec sheet has three columns: the material, the print, and the claim. Until recently the third column was free. It cost nothing to write "eco-friendly" on a box, and nobody asked what it rested on.

That is about to change for anyone selling into the EU. The consumer-protection rules on environmental claims tighten on 27 September 2026, and the wording on your carton falls inside them.

This is a guide to what you can say, what you will need on file to say it, and how to brief a factory so the answer arrives in writing rather than as an adjective.

The date to put in your calendar

The relevant instrument is Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive. It was adopted in February 2024, Member States had to transpose it by 27 March 2026, and the new prohibitions and evidence requirements apply from 27 September 2026.

Two features of its scope catch most small brands out:

• It covers business-to-consumer commercial practices — packaging, labelling, advertising, product listing copy. A marketplace listing counts.
• It does not depend on turnover or headcount. There is no small-business carve-out of the kind you see in investor-facing sustainability reporting.

The European Commission also published answers to frequently asked questions on the directive. Those answers are not legally binding, but regulators and courts tend to read them, so they are worth treating as the working interpretation.

Four rules that change what you can print

1. Generic environmental claims must be substantiated. Words like "eco-friendly", "green" and "sustainable" are only permitted where they are tied to recognised, verifiable environmental performance. The unqualified version is the prohibited one.
2. Self-created sustainability labels are out. A badge you designed yourself, without an independent certification scheme behind it, may not be displayed as a sustainability label.
3. Offset-based climate claims are restricted. "Carbon neutral" resting on offsets purchased outside your own value chain is treated as misleading, because it points at someone else's reduction instead of the emissions you actually caused.
4. Comparative claims need evidence. Saying you are better than another product is a stronger statement than saying you are good, so it needs the comparison on file.

None of this is a reason to stop making claims. It is a reason to attach a number, a standard, or a documented practice to the ones you keep.

The US side is different, and moving the same way

Across the Atlantic the instrument is different. The FTC's Green Guides (16 CFR Part 260) were last revised in 2012, and the FTC's review of them — opened with a request for comment in December 2022 — has not produced a final revision. So in the US the guidance still reads as guidance rather than rule.

What is not speculation is the enforcement record. In 2022 the FTC announced settlements totalling US$5.5 million with Kohl's and Walmart over bedding marketed as free of harmful chemicals and made from bamboo, when the conversion process used toxic chemicals. Separately, $21 million in penalties were ordered against manufacturers whose LED bulbs used Energy Star marks the products had not earned. Both cases turned on the same thing: the claim was on the label, the advertiser could not produce the evidence, and the evidence was the whole defence.

The reason that matters for planning is what happens if a rule is finalised. Under Section 5 of the FTC Act the Commission generally lacks civil penalty authority; a formal rule would change that, and per-violation amounts are counted per dissemination, which means a run of shipped cartons is not one violation.

Practical read: the US position is looser today, the EU position is already fixed, and both reward the same habit. Write down why the claim is true.

Which claims you can actually hold

Claims differ in how much they cost to defend. In descending order of defensibility:

• A named standard or certification. It comes with its own scope, its own auditor and its own limits. Say what the scheme covers and do not stretch it to what it does not.
• A stated material fact. "The cartonboard is 70% recycled fibre" is a fact about an input. "The carton is recyclable in household waste" is a fact about an output. Both are answerable with a document from the mill or the converter.
• A documented process. "We recover and treat plating waste water" can be true and specific. "We produce responsibly" cannot.
• A comparison, with the method stated. Comparing your carton against a named baseline, on a declared basis, is the strongest form of comparison — and the one most likely to be asked to show its work.
• A generic adjective. Cheapest to write, most expensive to keep.

The rewrite that survives

What a factory is likely to say	What you can print instead
"Eco-friendly packaging"	"The carton is unlaminated Kraft board with soy-based ink."
"Sustainable materials"	"The shell is PU leather; the interior is synthetic velvet."
"Carbon neutral shipping"	"We ship by sea rather than air, which is the largest reduction we control."
"100% recycled"	Whatever the board content actually is — or nothing, if it is not documented.
"Green"	Delete it. It is not carrying a fact and it is the exact term the new EU rules target.

The middle column is often less flattering than the first. That is not a failure; an unflattering claim that survives an audit is worth more than a flattering one that does not.

Five questions to send your factory in writing

Ask these by email and keep the reply. The answer is the evidence you will be asked for later.

1. What specific environmental claim are you making about this component, in writing? Names only.
2. What is the basis for it? Mill certificate, chain-of-custody statement, supplier declaration, measured data.
3. Which part of the product does the claim not cover? If the answer is "everything", the claim is about the company, not the box.
4. Can I have that in a document I can file, not just in an email? A declaration that exists only in a thread is hard to produce to a regulator.
5. What is the end-of-life answer for this part? Unlaminated paper recycles in most municipal streams; a foil-laminated carton with an adhesive layer usually does not, whatever the fibre content.

The method here is the same as working through an eco-claim before you buy, and the same questions arrive from large retailers, who pass their forms straight to their suppliers rather than to you — see retailer sustainability questionnaires.

What we will and will not put on our own packaging

We will answer questions 1 to 5 above in writing for your order, and we will tell you when the honest answer is that we cannot document something.

What we do not do is publish an environmental percentage we have no measurement behind, and we do not make offset-based climate claims, because the reduction would belong to someone else's value chain rather than ours. On transport we will say what we actually do — sea freight as the default rather than air — which is the reduction we can evidence and is written up in sea versus air freight.

On materials themselves, see jewelry box materials. On the compliance documents that cover your product rather than your marketing, see CE, RoHS and FCC reporting.

FAQ

Does this apply to small brands, not just large ones?

In the EU, yes. The directive covers commercial practices aimed at consumers regardless of company size; there is no turnover threshold in the way there is for investor-facing reporting rules.

Can I still say "eco-friendly" anywhere?

Only where it is tied to recognised excellent environmental performance — for example an ecolabel or documented top performance against applicable EU rules. On packaging, the safer route is to state the material fact and drop the adjective.

Is it legal to use my own sustainability badge?

Not as a sustainability label, unless it sits on an independent certification scheme or is authorised by a public authority. If you already have one in artwork, check its basis before the reprint.

What about "carbon neutral"?

A claim that rests only on buying offsets outside your own value chain is treated as misleading under the new EU rules, and the FTC has said it will scrutinise offset claims. If you want to say something, say the reduction you made.

Where does this leave recycled content claims?

They are fine if they are accurate and documented, and problematic if the percentage came from a marketing sentence rather than from the mill. Ask for the figure in writing and match it to the artwork.

Do you hold environmental certifications we could reference?

We provide the compliance documentation your market asks for; environmental certification is a separate matter. Ask us directly and we will tell you what we can evidence rather than imply something we cannot.

Is this a reason to stop using the word sustainable in my brand name?

Usually not — the question is whether an average consumer reading that name in that context expects an environmental benefit. If they might, treat the name as a generic environmental claim and be ready to substantiate it.

Next step

Send your RFQ with the five questions above. We will answer them in writing for your order, including where the answer is no. Contact FSC CRAFT.

Related: How to verify an eco-friendly claim before you buy · How to answer a retailer's sustainability questionnaire · Jewelry box materials · Compliance and testing

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