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Environmental claims from 27 September 2026: what Slovak law prohibits

Methodology: Marek Galetka, founder of Pravano. English translation of our Slovak article, which a person approved before publication; every number, date and legal reference of the translation is checked automatically against the original.

Cross-checked as of 26 September 2026 · based on primary sources

Updated 26 September 2026. Based on Act No. 108/2024 Coll. on Consumer Protection, as amended by Act No. 310/2025 Coll.. An informative readiness check, not a legal service or an official audit. Original: slovenská verzia.

Directive (EU) 2024/825, known as EmpCo, is meant to empower consumers for the green transition. Unlike the Czech Republic, Slovakia has already transposed it: Act No. 310/2025 Coll. amends Act No. 108/2024 Coll. on Consumer Protection, and its environmental part took effect on 27 September 2026, exactly on the day from which the directive is to apply. This article explains what changes from that day for anyone who sells goods or provides services in Slovakia and talks about the environment while doing so.

What Act No. 310/2025 Coll. brings

The act was passed on 21 October 2025 and promulgated on 19 November 2025. It adds to the Consumer Protection Act definitions of the terms environmental claim, sustainability label, certification scheme and recognised excellent environmental performance (Section 2(n) to (q)). Environmental or social characteristics and circularity aspects expressly become main characteristics of a product about which a trader must not mislead (Section 10(1)(b)). A claim about future environmental performance without verifiable commitments in a detailed implementation plan with independent verification is also a misleading action (Section 10(2)(d)). And new points are added to Annex 1, the list of practices that are always unfair.

The transposition deadline of the directive (27 March 2026) was formally met. Under Article V, the relevant points have been in effect since 27 September 2026. The act has no transitional period for environmental claims or sustainability labels, so in our reading the new rules apply to commercial practices from that day regardless of the date of manufacture or placing of the product on the market.

Five practices that are always unfair from 27 September 2026

Annex 1 to Act No. 108/2024 Coll. (the part “Misleading commercial practices”), in the version in effect from 27 September 2026, contains the following new points. For these, it is not examined whether a particular consumer was misled; they are prohibited as such.

Point 3: displaying a sustainability label that is not based on a certification scheme or not established by public authorities. Self-created “green labels” without certification are therefore no longer permitted.

Point 6: making a generic environmental claim (such as “climate-friendly”, “environmentally friendly”, “green” or “ecological”) in written, oral or audiovisual form that is not displayed on a sustainability label and whose specification is not clearly and prominently provided in the same medium, where the trader is not able to demonstrate recognised excellent environmental performance.

Point 7: 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.

Point 8: claiming that a product has a neutral, reduced or positive impact on the climate based on the offsetting of emissions.

Point 15: presenting requirements imposed by law on all products within the relevant category as a distinctive feature of the trader's offer.

These points correspond to Article 1 of the EmpCo directive (new points 2a, 4a, 4b, 4c and 10a of Annex I to Directive 2005/29/EC).

Who supervises and what you risk

Supervision of unfair commercial practices (Section 4(2)(a) of Act No. 108/2024 Coll.) is carried out for ordinary goods and services by the Slovak Trade Inspection (SOI) (Section 26(1)(b) and (8)). For food it is the State Veterinary and Food Administration, for cosmetics and food the public health authorities, for medicinal products the State Institute for Drug Control (Section 26(4) to (6)).

For an unfair commercial practice, including a misleading environmental claim, the supervisory authority may impose a fine from €200 to 2% of turnover for the previous accounting period, up to €200,000 (Section 43(1)(a)). In coordinated action against a widespread infringement with a Union dimension, the range is from €500 to 4% of turnover without a cap (Section 43(2)(a)), which transposes Article 13(3) of Directive 2005/29/EC into Slovak law. For a repeated breach within 12 months, from €300 to 3% of turnover, up to €400,000 (Section 43(3)(a)). If the trader ends the infringement and remedies it, the range is halved (Section 44(1)).

What this means for your communication

Go through your packaging, online shop, catalogues, advertisements and social media and look for three things: generic adjectives without a specification right next to the claim, claims about the “whole company” or the “whole product” based on a single characteristic, and climate promises built on offsets. Every claim that remains needs evidence you can present during an inspection. If you plan to claim a future benefit (“by 2030 we will…”), you need a detailed plan with verifiable commitments and independent verification.

This article is a general explanation, not individual legal advice. A specific overview for your company (Pravano Kompas) comes with the free check – in writing, within 2 working days.