Finland
Status of the current legislative process
The working group preparing the national implementation of the EmpCo issued their report in the form of a draft Government Proposal on 21 October 2025. The report has been out for comments until 2 December 2025, after which the process will continue.
As the report is just an initial proposal of the implementation, some amendments may still occur when the final Governmental Proposal is given. However, according to the relevant contact person possible changes are expected to be minor.
According to current estimates the Government Proposal will be issued during week 9/2026.
Link to the draft (if available)
The working group’s report may be downloaded here (in Finnish): https://julkaisut.valtioneuvosto.fi/items/814b1145-9ecb-4887-8d78-f4e347364931.
Does the implementation go beyond EmpCo requirements?
N/A
Are there any comments from relevant authorities on the interpretation or enforcement of the national implementation?
Yes
The Finnish Government has expressed some reservations about expanding pre-contractual information requirements as well as the obligation to indicate the exact duration of legal guarantee of conformity. In Finland there is no specific duration for the legal guarantee of conformity, such as two years, as its length depends on the nature of the goods and the defect found in them.
Will the national implementation be applied in a Business-To-Business (B2B) context?
No
Is there a green claims guide/guidance in your country?
The Finnish Competition and Consumer Authority has issued the Consumer Ombudsman’s guideline on the use of environmentally oriented claims in marketing. A new chapter on the Consumer Ombudsman’s case law on environmental marketing (Chapter 6) has also been added in 2025. The guideline is available here (in English): https://www.kkv.fi/en/consumer-affairs/facts-and-advice-for-businesses/the-consumer-ombudsmans-guidelines/the-use-of-environmentally-oriented-claims-in-marketing/.
In addition, the Finnish Competition and Consumer Authority has issued guidelines to companies on environmental marketing. The guideline is available here (in Finnish only): https://www.kkv.fi/kuluttaja-asiat/tietoa-ja-ohjeita-yrityksille/ohjeet-yrityksille-ymparistomarkkinointiin/.
What are the sanctions and penalties?
The new EU requirements will be implemented within the provisions prohibiting unfair, misleading and aggressive practices. Non-compliance will therefore be sanctioned under the same legal framework. For traders, this includes a penalty of a maximum of 4 % of the trader’s turnover for the year preceding the cessation of the infringement or violation. In addition, traders may be obliged to compensate the consumer for the damage caused.
Does the national implementation answer the following questions:
(1) whether sustainability labels can take the form of text;
(2) whether generic environmental claims can be used or are they banned unless you have recognised excellent environmental performance;
(3) whether GHG impact claims based on GHG offsets are banned only if offsets are the sole basis, or even if offsets and GHG reductions are combined.
(1) The draft proposal does not explicitly address whether sustainability labels can take the form of text.
(2) Presenting a generic environmental claim without being able to demonstrate recognised excellent environmental performance relevant to the claim is prohibited.
(3) The draft proposal prohibits claims stating that a product has a neutral, reduced or positive impact on the environment if the claim is based on greenhouse gas offsetting. Thus, e.g. the use of “climate neutral” would only be allowed if the claim is based on the actual lifecycle impact of the product in question and not based on the offsetting of greenhouse gas emissions outside the product’s value chain.
