Stricter greenwashing rules: Hungary removes key transitional rule

1. The concept of an "environmental claim" is broad and form-neutral

The new definition covers not only express statements, but also any message, representation, symbol or visual element that claims or suggests that a product, product category, brand or business:

• has a positive impact on the environment;
• has no impact on the environment;
• is less harmful to the environment than alternatives; or
• has improved its environmental impact over time.

In other words, visual and symbolic communication can also constitute an environmental claim – not just words.

2. Several practices will be automatically prohibited

These include, among others:

• displaying a sustainability label that is not based on a certification scheme or established by public authorities;
• making a generic environmental claim without being able to demonstrate recognised excellent environmental performance relevant to that claim; and
• presenting an environmental claim for an entire product or the entirety of a business activity where the claim actually relates only to a particular aspect of the product or a specific operation of the business.

In the case of these practices, the authority will not need to prove an actual capacity to mislead consumers in order to find them unlawful.

3. Strict conditions will apply to future-oriented environmental claims

Claims concerning future environmental performance will only be permissible where they are supported by clear, objective, publicly available and verifiable commitments, measurable and time-bound targets, and a detailed and realistic implementation plan. The implementation must also be regularly verified by an independent third-party expert, with the findings made available to consumers.

An important last-minute development

It had originally been envisaged that, for communications appearing on product packaging, the new rules would apply in Hungary only to products manufactured on or after 27 September 2026. However, a last-minute legislative amendment adopted on 18 September 2026 removed this transitional provision.

As a result, from 27 September 2026, packaging communication on products manufactured before that date will also have to comply with the new rules. Businesses should therefore consider reviewing their environmental claims, sustainability labels and other environmental messaging appearing on existing product packaging before the new rules take effect.