POLICY & REGULATION · 11 min read
Sri Lanka’s Eco-Label Question Has an Answer Nobody Has Given — and the EU Rule That Makes It Matter Applies on 27 September
On 27 September 2026, four environmental claims become prohibited in all circumstances across the European Union. One of them bans the display of a sustainability label that is neither based on a certification scheme nor established by public authorities. Sri Lankan exporters have been told to watch for a national eco-labeling framework that has no completion date. Meanwhile, a certified, internationally recognised Sri Lankan scheme has been operating since 2021, and neither the European Union’s Colombo readout nor any local coverage we could find mentions it in this context.
By the ESGNexus Editorial Team · August 2026 · Estimated reading time: 11 minutes
KEY TAKEAWAYS
|
A particular kind of regulatory news arrives twice: once as an anxiety and, much later, as a specification. Sri Lankan exporters have been anxious about European greenwashing rules for well over a year. On 27 September 2026 they get the specification, and it is shorter, more concrete, and in one respect considerably more favourable than the anxiety suggested.
Directive (EU) 2024/825 — the Empowering Consumers for the Green Transition Directive, universally shortened to EmpCo — amends the European Union’s Unfair Commercial Practices Directive. Its Article 4(1) is unambiguous about timing:
| By 27 March 2026, Member States shall adopt and publish the measures necessary to comply with this Directive. They shall immediately inform the Commission thereof. They shall apply those measures from 27 September 2026. — Directive (EU) 2024/825, Article 4(1) |
The transposition deadline has passed. The application date has not. What follows is what actually becomes prohibited on that day.
The Four Prohibitions, in the Words That Matter
EmpCo adds these to Annex I of Directive 2005/29/EC. Annex I is the European Union’s list of commercial practices considered unfair in all circumstances. That phrase is the operative one: there is no proportionality test, no case-by-case balancing, and no defense that consumers were not actually misled. If the practice is on the list and you engage in it, it is unfair.
| Point | Prohibited in all circumstances |
| 2a | “Displaying a sustainability label that is not based on a certification scheme or not established by public authorities.” |
| 4a | “Making a generic environmental claim for which the trader is not able to demonstrate recognised excellent environmental performance relevant to the claim.” |
| 4b | “Making an environmental claim about the entire product or the trader’s entire business when it concerns only a certain aspect of the product or a specific activity of the trader’s business.” |
| 4c | “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.” |
Source: Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024, Article 1, amending Annex I of Directive 2005/29/EC. Read directly from the Official Journal text. Point 4b — the whole-product claim resting on a single attribute — does not appear in any Sri Lankan coverage of this directive that we were able to locate, and it is the one most likely to catch an otherwise careful exporter.
Read 4b again, because it is the quiet one. A tea packed in recyclable cartons is not thereby a sustainable tea. A factory running on rooftop solar does not make the garments leaving it environmentally superior products. The prohibition is not on the underlying fact — the carton may well be recyclable, the solar may well be real — but on letting a true statement about one attribute do promotional work for the whole. That is the most common form of a Sri Lankan sustainability claim, and after 27 September, it is the one that fails.
On 4a, the European Commission’s own guidance sets the bar for what a generic claim must demonstrate: recognised excellent environmental performance means the EU Ecolabel, a national or regional EN ISO 14024 Type I scheme, or top environmental performance recognised under other EU law. A generic claim ceases to be generic, the Commission says, when the specifications are provided in clear and prominent terms on the same medium.
Point 2a Has Two Limbs, and Either One Is Enough.
Three of these four prohibitions are entirely within an exporter’s own control. Stop making the generic claim. Stop letting one attribute stand for the whole. Stop calling a product climate-neutral on the strength of purchased offsets. Each is a decision a marketing department can take on its own authority, this quarter, at no cost beyond the loss of a comfortable phrase.
Point 2a is not like that. It does not tell you to stop claiming something; it tells you what has to stand behind a label before you may display it. And the drafting is compressed enough that it is routinely misread as a single, harder test than it is. The Directive’s own recital settles it:
| The displaying of sustainability labels remains possible without a certification scheme when such labels are established by a public authority… — Directive (EU) 2024/825, Recital 7 |
So there are two independent routes to a displayable label. A certification scheme is one. Establishment by a public authority is the other. A privately owned label backed by a genuine certification scheme qualifies without any state involvement whatsoever. A state-established label qualifies without a certification scheme. An exporter needs one of the two, not both — and the widespread assumption that Sri Lankan exporters must wait for a government scheme rests on reading the point as though only the second limb existed.
The first limb also has an attached definition. Article 2, point (r) tells you exactly what a certification scheme is, and it is a test an exporter can run this week on every mark on its packaging.
| Condition | What Article 2(r) requires of a certification scheme |
| 1 | The scheme is open to all traders willing and able to comply, on terms that are transparent, fair and non-discriminatory. |
| 2 | Its requirements are developed by the scheme owner in consultation with relevant experts and stakeholders. |
| 3 | It sets out procedures for dealing with non-compliance, including provision for withdrawal or suspension of the label. |
| 4 | Compliance is monitored by a third party, against international, Union or national standards, independently of the trader and the scheme owner. |
Source: Directive (EU) 2024/825, Article 2, point (r), read from the Official Journal text on 27 August 2026. Summarised, not quoted verbatim, and reordered for use as a checklist; the operative wording is in the Directive. A logo devised in-house, a buyer’s private mark with no independent audit, or an industry grouping’s badge with no withdrawal procedure will fail one or more of these conditions — and no amount of internal rigor substitutes, because conditions 1 and 4 are structural rather than evidentiary.
Sri Lanka Already Has a Certification-Based Eco-Label
This is the part of the story that has gone unreported, and it materially changes the practical position. Eco Label Sri Lanka is operated by the National Cleaner Production Centre, an organisation founded by UNIDO and UNEP. The programme began in 2018 at the initiative of the United Nations Environment Programme, and in 2021 it became a full member of the Global Ecolabelling Network—the international body for Type I environmental labelling programmes—on whose membership page the scheme appears. Its site states compliance with ISO 14024:2018, the standard for Type I environmental labelling.
It is not a framework awaiting criteria. It publishes certification criteria documents by product category, and it certifies against them. The categories listed on the scheme’s own site run to eight: dairy products, tea products, construction chemicals, textiles and apparel, activated carbon products, rubber-based products, hotels and restaurants. Two of those—tea and textiles and apparel—are the largest sustainability-claim surfaces in Sri Lanka’s EU-bound trade.
The certification route is published, audited and time-bound: application with a questionnaire, review by the NCPC on receipt of the application fee, a verification audit, referral to a certification committee, grant of the certificate, then a first surveillance audit after one year, a second after two, and re-certification at three. That is third-party monitoring with a withdrawal mechanism within a defined cycle—the shape Article 2(r) describes.
We are not going to tell you this scheme is EU-recognised, because no source establishes that, and this article does not print conclusions its sources do not carry. Point 2a is not a register. There is no EU list of approved foreign eco-labels to appear on. What point 2a does is describe two categories, and the exporter’s question is a factual one about the scheme it uses: does the scheme meet the four conditions in Article 2(r)? For Eco Label Sri Lanka, the publicly available evidence — open criteria, stakeholder-developed requirements, third-party verification audits, a surveillance and re-certification cycle — points in that direction on every condition. It is a question to put in writing to the scheme and to your buyer, and it is a far better question than waiting.
The Document Published in Colombo Two Weeks Ago
On 13 August 2026, the Delegation of the European Union to Sri Lanka published a readout of a stakeholder consultation held in Colombo, under the headline “European Union brings together 50+ Public and Private Sector Leaders to Strengthen Sri Lanka’s National Eco-Label”. The EU-funded Green Recovery Facility, implemented by Expertise France in partnership with the Ministry of Environment, hosted the event and drew more than 50 public- and private-sector leaders.
Sri Lanka launched its National Eco-Labelling Framework in 2022, the Delegation says, “as a foundation for developing a nationally recognised eco-labelling system”. The readout names the Green Building Council of Sri Lanka and the Sri Lanka Sustainable Energy Authority among existing sector-specific initiatives. It identifies fragmentation across schemes as the problem to be solved. It does not name the National Cleaner Production Center or Eco Label Sri Lanka. Whether the certified scheme is intended to sit inside the national framework, alongside it, or be superseded by it is not stated in any source we were able to read, and it is the single most useful thing the Ministry of Environment could clarify this month.
| A nationally recognised eco-labelling system will strengthen consumer confidence, support sustainable industries and help Sri Lankan businesses respond to evolving environmental expectations in domestic and international markets. — Ms. R.H.M.P. Abeykoon, Additional Secretary, Ministry of Environment, 13 August 2026 |
Dr Johann Hesse, Head of Cooperation at the Delegation of the European Union to Sri Lanka and the Maldives, put the trade dimension plainly at the same event: “As sustainability becomes an increasingly important factor in global trade, credible and transparent environmental standards are essential.”
Neither document mentions the other. The Delegation’s readout does not cite EmpCo. EmpCo, being a directive of general application, does not name any country’s eco-label. But the relationship between them is not subtle: six weeks before the European Union begins prohibiting sustainability labels that lack certification or a public-authority foundation, the European Union is in Colombo funding work on a national label.
The Missing Date, and What This Article Will Not Claim
The Delegation’s readout says the next phase will focus on strengthening technical capacity, refining harmonized criteria and supporting the implementation of a trusted national eco-label, with stakeholders continuing to shape its final form “in the months ahead”. It gives no completion date. EmpCo gives a very precise one.
So the honest statement of the position is this. Point 2a takes effect on a fixed day. The state-led National Eco-Labelling Framework will not be finished by then, according to any published timetable, and an exporter waiting for it will be waiting past the deadline. But an exporter does not need it, because the first limb of point 2a does not require the state — and a certified Sri Lankan scheme with international standing has been operating for five years.
And here is what we will not claim, because no source supports it: that any Sri Lankan label is recognised under point 2a, or that displaying one confers compliance. No EU instrument names Sri Lanka’s schemes, and no source we found says the Commission has assessed them. The logic is available; the conclusion is not established. An exporter should treat it as a question to put to its buyer in writing — and should note that arriving with a certificate, an audit trail and the Article 2(r) conditions addressed one by one is a materially different conversation from arriving with a promise that a national scheme is coming.
A Correction to the Record: the Green Claims Directive Was Not Withdrawn
Much compliance commentary, including material circulating among exporters, says the European Union abandoned its green-claims rules. It did not, and the distinction matters for anyone deciding how much to invest in substantiation.
The Green Claims Directive is a separate, still-pending proposal. The Commission announced an intention to withdraw it on 20 June 2025. Five days later, Executive Vice-President Teresa Ribera clarified that it had not officially been withdrawn. The 2026 Commission Work Program, adopted on 21 October 2025, lists the proposal as pending. The European Parliament’s own Legislative Train Schedule, updated as recently as 20 April 2026, records the file’s status in one word: Blocked. Two trilogues were held, in January and April 2025, and negotiations were subsequently cancelled rather than concluded.
Blocked is not withdrawn. A blocked file can move. More importantly, none of this touches EmpCo, which was adopted in February 2024, transposed by March 2026, and applies in September — a fact confirmed in the legal commentary on the withdrawal itself, which noted that the Green Claims proposal’s fate would not affect the existing anti-greenwashing framework.
| Date | What happened, or happens |
| 2018 | Eco Label Sri Lanka was initiated by the United Nations Environment Program. |
| 2021 | Eco Label Sri Lanka becomes a full member of the Global Ecolabelling Network. |
| 2022 | Sri Lanka launches its National Eco-Labelling Framework — a separate, state-led initiative. |
| 28 February 2024 | Directive (EU) 2024/825 (EmpCo) adopted, amending the Unfair Commercial Practices Directive. |
| 28 January 2025 | First trilogue on the separate Green Claims Directive proposal. |
| 24 April 2025 | Second Green Claims trilogue. Negotiations subsequently cancelled. |
| 20 June 2025The | Commission announces its intention to withdraw the Green Claims proposal. On 25 June, EVP Ribera clarifies it has not officially been withdrawn. |
| 21 October 2025 | 2026 Commission Work Programme adopted. The Green Claims proposal is listed as pending. |
| 27 March 2026 | EmpCo transposition deadline. Member States adopt and publish national measures. |
| 20 April 2026 | European Parliament Legislative Train records the Green Claims file as ‘Blocked’. |
| 13 August 2026 | EU Delegation in Colombo publishes its readout on strengthening Sri Lanka’s National Eco-Label. No completion date given. |
| 27 September 2026 | EmpCo measures apply. The four Annex I prohibitions take effect across the EU. |
Who Is Actually Bound
The same reading ESGNexus has applied to the packaging regulation and to the deforestation rules applies here, and it is worth restating because it is routinely overstated in both directions. EmpCo binds traders in the European Union. A Sri Lankan exporter is not the regulated entity and will not be prosecuted under it.
The pressure arrives commercially instead, and it arrives earlier than the legal date. An EU buyer facing an Annex I prohibition on a claim it makes about a product cannot carry that risk alone; it will push substantiation requirements down its supply chain through contract clauses, evidence requests, and specification changes. That process starts when the buyer’s compliance team reads the directive, not when the directive applies. For a September date, that means now.
What to Do Now
1. Inventory every environmental claim and label on your EU-bound packaging and marketing. Sort them into the four categories above. Most exporters will find the exposure lies in 4a and 4b—generic language and whole-product claims resting on a single attribute—rather than in the offsetting prohibition that gets the headlines.
2. Run every label you display against the four conditions in Article 2(r). Is the scheme open to all comers on non-discriminatory terms? Were its requirements developed with experts and stakeholders? Does it have a non-compliance and withdrawal procedure? Does an independent third party monitor compliance against a recognised standard? The second limb does not save a mark that fails any of these unless a public authority established it.
3. Take point 4b seriously even though nobody has told you about it. Recyclable packaging does not make a sustainable product. Renewable energy at a single site does not make a business green. A true statement about one attribute may not characterise the whole. This is the prohibition least covered locally and the one closest to standard Sri Lankan practice.
4. If you export tea, apparel, rubber goods or activated carbon, look at Eco Label Sri Lanka before you look anywhere else. The scheme already publishes criteria for your category and already certifies against them, on a three-year audited cycle. Whatever the National Eco-Labelling Framework eventually becomes, it exists today, and a certificate is an artifact you can present to a buyer in October.
5. Ask the Ministry of Environment how the national framework relates to the existing certified scheme. The EU-funded work names neither the NCPC nor Eco Label Sri Lanka. Exporters investing in certification now are entitled to know whether that investment carries forward into the national framework or is superseded by it. Ms R.H.M.P. Abeykoon, Additional Secretary, is the named contact in the EU release.
6. Get ahead of your buyer’s substantiation request rather than answering one. A supplier who arrives with claims already sorted, labels already traced to their schemes, and whole-product language already retired is in a materially different negotiating position from one who is asked cold in October.
Questions Sri Lankan Exporters Are Asking
1. Will the National Eco-Label be fully recognised and usable for EU compliance by 27 September 2026?
Two questions are bundled here, and they have different answers. On usability: almost certainly not, and no source says otherwise. The EU Delegation’s 13 August readout describes the next phase as strengthening technical capacity and refining harmonised criteria, with stakeholders shaping the framework’s final form “in the months ahead”. No completion date or criteria set has been published. Thirty-one days is not a realistic window.
On recognition: the question rests on a false premise. Point 2a does not create an EU register of approved foreign labels, and there is nothing to recognise. It states a category test. A label is displayable if it is based on a certification scheme as defined in Article 2(r), or if a public authority establishes it. A national scheme established by the Ministry of Environment would fall within the second limb in plain terms of the text — but no EU instrument names it, and no source we found indicates the Commission has assessed it, so we decline the conclusion.
The practical answer is that the question is the wrong one to be waiting on. An exporter that needs a compliant label in September should look at the first limb, where a certified Sri Lankan scheme already operates, rather than the second, where the state-led framework has no date.
2. What should exporters do if their products currently use private or uncertified sustainability labels?
There are exactly three lawful destinations, and the choice is commercial.
- Retire the mark. The cheapest option, available immediately, and the right one for a decorative in-house logo that carries no evidentiary weight with buyers anyway. Removing a label is not an admission of anything; it is housekeeping ahead of a deadline.
- Move to a scheme that satisfies Article 2(r). For most Sri Lankan exporters that means Eco Label Sri Lanka, the EU Ecolabel, or another EN ISO 14024 Type I programme. Note that a privately owned label is not disqualified simply for being private — a buyer’s own mark or an industry association’s badge qualifies if it is backed by a genuine certification scheme with independent third-party monitoring. The test is the scheme, not logo ownership.
- Replace the label with a specific, substantiated claim. A label is not the only way to communicate performance. But a replacement claim must clear 4a (not generic) and 4b (attribute-specific, not standing in for the whole product or business). “Made in a facility certified to ISO 14001 since 2019” survives both. “Eco-friendly” survives neither.
What does not work is keeping the mark and building an evidence file behind it. Conditions 1 and 4 of Article 2(r) — open access and independent third-party monitoring — are structural. No amount of internal documentation converts a self-awarded logo into a certification scheme.
3. How should exporters communicate with EU buyers about compliance and the status of the National Eco-Label?
Start from the correct allocation of risk. You are not the regulated party; your buyer is. Do not tell a buyer you are “EmpCo compliant” — it is not a status a Sri Lankan supplier can hold, and a compliance officer who knows the instrument will read the phrase as evidence you have not read it. What the buyer needs from you is the material that lets it defend its claims.
Send three things, unprompted, before the buyer asks:
- A claims inventory — every environmental claim and label that appears on the product, its packaging, your catalogue and your website, with the evidence behind each and a note of which you are retiring before 27 September.
- A label provenance sheet — for each mark you display, the scheme that stands behind it, the certificate number, the issuing and expiry dates, the audit cycle, and the scheme’s position against the four Article 2(r) conditions.
- One question back: what claims does the buyer intend to make about this product in the EU market? Their exposure drives your obligations. A buyer planning to market your tea as “sustainable” needs far more from you than one selling it on origin and grade.
On the national framework specifically, say what is true and no more: Sri Lanka has a state-led eco-labelling framework in development with EU funding, no published completion date, and a separate certified scheme already operating that your certificate comes from. Overstating the national framework’s readiness to a European compliance team is the single most damaging thing an exporter could do in this conversation, because it will be checked, and the readout says “in the months ahead”.
4. What is the process and timeline for obtaining certification under Sri Lanka’s eco-label scheme?
For Eco Label Sri Lanka, the process is published by the National Cleaner Production Centre and runs in eight stages: application with the accompanying questionnaire; application review by the NCPC on receipt of the application fee; a verification audit; referral of the records to the certification committee for approval; grant of the certificate; a first surveillance audit one year after the licence is granted; a second surveillance audit at two years; and re-certification at three years.
The scheme does not publish an expected elapsed time from application to certificate, and we will not estimate one. Nor are fee amounts published on the pages we could read. Both are questions for the NCPC directly, and both should be asked this week rather than in September — the binding constraint is almost certainly the verification audit, which requires an on-site assessment and therefore the scheme’s scheduling capacity, not yours.
For the National Eco-Labelling Framework, there is no published certification process, because the criteria are still being harmonised. There is nothing to apply for yet.
5. Where can exporters find timely updates on the eco-label’s progress and on the EU rules?
Six sources, in descending order of authority. Go to the first three before you read commentary on any of this, including ours.
- EUR-Lex for the enacted text of Directive (EU) 2024/825. This is the only place the four prohibitions, the 27 September date, and the Article 2(r) definition exist authoritatively. Everything else, including this article, is a reading of it.
- The European Commission’s Questions & Answers on Directive (EU) 2024/825 — but check the version. It is a living document: first issued in November 2025 and updated on 18 May 2026, with the update materially changing how brand, product, and company names are assessed. A print-out from last year is a liability.
- The European Parliament’s Legislative Train Schedule for the status of any pending EU file, including the Green Claims Directive. It includes a status field and a page-updated date, and it settles one-page questions that law-firm commentary leaves ambiguous for months.
- The EU Delegation to Sri Lanka (eeas.europa.eu) for the national eco-label work, which the Delegation is funding and which it has so far reported through its own releases rather than through Sri Lankan government channels.
- The Ministry of Environment for the National Eco-Labelling Framework itself, and the National Cleaner Production Center(ecolabelsrilanka.org) for the operating certified scheme, its criteria documents, and its registered product list. These are two different bodies publishing on two different tracks, and an exporter needs to monitor both until someone clarifies the relationship between them.
- Your buyer’s compliance team. Unglamorous, and the fastest-moving source of all. They will know what their national transposition of EmpCo says and how their regulator is signaling enforcement long before any of it reaches Colombo.
None of the four prohibitions requires a Sri Lankan exporter to change a product. Three require it to stop saying something. The fourth requires it to know who certified the mark on its packet — and, contrary to the prevailing assumption, that certifier need not be the state or European. Set against the packaging regulation’s compostability requirement, which asks for a physically different bag by 2028, this is a light obligation. It is also one where the useful move has been available in Colombo since 2021, and the conversation has been looking elsewhere.
Note on sources and their limits. The Directive text — Article 4(1), Article 2(r), Recital 7 and the four Annex I points — was read directly from the Official Journal on 27 August 2026; the Article 2(r) conditions are summarised and reordered as a checklist, not quoted. The European Commission’s June 2026 Questions & Answers, source of the ‘recognised excellent environmental performance’ definition and the generic-claim test, was read on 24 August and not re-read for this article. Details of Eco Label Sri Lanka are taken from the scheme’s own site, the National Cleaner Production Centre’s site, and the Global Ecolabelling Network’s organisation page for the scheme, all read on 27 August. The scheme’s pages are inconsistent on the status of its Sri Lanka Accreditation Board accreditation under ISO/IEC 17065:2012 — one page describes it as achieved in 2024, another as ongoing — and this article therefore does not rely on it. The Ministry of Environment’s own page on the National Framework on Eco-labeling could not be read: env.gov.lk returned a redirect loop to fetchers on 27 August. Two island.lk articles could not be retrieved for the same reason; when an article says no local outlet carried a given point, it means none we were able to read.
Sources & Further Reading
Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition — eur-lex.europa.eu
European Commission, “Questions & Answers on Directive (EU) 2024/825”, Brussels, June 2026 (first edition November 2025; updated 18 May 2026) — commission.europa.eu
European Parliament, Legislative Train Schedule, “Substantiating and communicating green claims”, page updated 20 April 2026 — europarl.europa.eu
Delegation of the European Union to Sri Lanka, “European Union brings together 50+ Public and Private Sector Leaders to Strengthen Sri Lanka’s National Eco-Label”, 13 August 2026 — eeas.europa.eu
Global Ecolabelling Network, organisation page for Eco Label Sri Lanka — globalecolabelling.net
Eco Label Sri Lanka, programme overview, application process and product categories — ecolabelsrilanka.org
National Cleaner Production Center Sri Lanka, eco-labeling program pages and published certification criteria documents — ncpcsrilanka.org
Lanka News Web, “Sri Lanka’s Green Market Ambitions Collide with Implementation Challenges”, 17 August 2026 — lankanewsweb.net
Linklaters Sustainable Futures, “EU: Sustainability initiatives in the Commission 2026 Work Programme”, 21 October 2025 — sustainablefutures.linklaters.com
Latham & Watkins, “European Commission Announces Intention to Withdraw EU Green Claims Directive Proposal”, 24 June 2025 — lw.com
Mawrata News, “EU Packaging and Green Claims Rules to Impact Sri Lankan Exporters from September 2026”, 14 June 2026 — mawratanews.lk
Sri Lanka Export Development Board, “Sri Lanka’s export performance exceeded US$ 17.2 billion in 2025”, 2026 — srilankabusiness.com
| About ESGNexus ESGNexus is Sri Lanka’s independent platform for ESG, CSR, and sustainability intelligence. We track company-level ESG performance, regulatory developments, and sustainability data across Sri Lanka’s listed companies, large unlisted corporates, and state-owned enterprises. All editorial content is independently produced. Sponsored content is clearly labeled. |
Data disclaimer: Information in this article is sourced from publicly available documents. ESGNexus does not independently verify company disclosures. Errors and omissions excepted.