From 27 September 2026, public sustainability claims will face clearer and more targeted legal scrutiny. This is particularly relevant for companies operating in Bulgaria
The Omnibus determines who must report and on what terms. It does not govern the legal risk attached to sustainability claims made to consumers and in consumer-facing marketing. That risk sits in the consumer-protection framework, which is tightening separately and is already producing enforcement action across Europe.
From 27 September 2026, public sustainability claims will face clearerand more targeted legal scrutiny. This is particularly relevant for companies operating in Bulgaria.
Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive (EmpCo), amends the Unfair Commercial Practices Directive and the Consumer Rights Directive and Bulgaria adopted the amendments in September 2026.
The Bulgarian Consumer Protection Act amendments entered into force from 27 September 2026, so the applicable green-claims rules are now grounded in Bulgarian national law.
The amendments introduce new definitions and extend the list of practices that are unfair and prohibited in all circumstances. From a business perspective, the risk hierarchy is the following:
Terms such as “eco-friendly”, “green”, “sustainable”, or “climate-friendly” cannot stand alone as marketing statements. A general environmental claim is prohibited unless the substance of the claim is presented clearly and prominently on the same medium. Generic green language without substantiation will be unlawful.
Claims that a good or service is “carbon neutral”, “net zero”, or has a “positive environmental impact” in greenhouse-gas terms are prohibited where they are based on offsetting greenhouse gas emissions. This strict product and service claim prohibition is separate from the rule for future environmental performance claims, which must be supported by clear, objective, publicly available, and verifiable commitments set out in a detailed implementation plan.
Any sustainability label or trust mark used in commercial communications must be based on a third-party certification system with publicly accessible criteria, open access, and independent compliance monitoring, or must be established by a public authority. Private sustainability marks that do not meet these requirements will be prohibited.
Forward-looking sustainability claims, including emissions targets, net-zero commitments, and future sustainability goals, must be backed by a concrete, documented implementation plan with measurable and time-bound milestones, independently verified and publicly available. Aspirational statements without a supporting plan will not comply.
Presenting a characteristic that is legally required for all comparable products as a distinctive environmentaл аdvantage of a specific product is prohibited.
For violations relating to unfair environmental claims and sustainability labels, the Bulgarian law provide for sanctions of up to 4% of annual turnover in Bulgaria for the preceding financial year, or a fixed sanction of €5,000 to €50,000 where turnover data is unavailable.
The following steps apply to any company that makes public sustainability statements, regardless of whether it falls within the mandatory CSRD reporting scope:
