Sustainable consumption law in Spain: how it transposes the anti-greenwashing directive and the right to repair

Spain's forthcoming sustainable consumption law transposes two EU directives at once: Directive (EU) 2024/825 on empowering consumers for the green transition, applicable across the Union from 27 September 2026, and Directive (EU) 2024/1799 on the right to repair, already applicable since 31 July 2026. As of this publication, the Spanish text was still at the draft-bill (anteproyecto) stage, not yet sent to Congress. That doesn't change the fact that both directives already bind companies operating in Spain by direct application of EU law, regardless of whether the national law is finished.

What's being transposed, and what already applies without waiting for the Spanish law

The two reference EU rules are:

• Directive (EU) 2024/825 of 28 February 2024, on empowering consumers for the green transition through better protection against unfair practices and better information. Applicable across the EU from 27 September 2026.
• Directive (EU) 2024/1799 of 13 June 2024, on common rules promoting the repair of goods (right to repair). Member states had to transpose and apply it from 31 July 2026, as confirmed by the European Commission itself; its repair obligations cover the products listed in Annex II that already carry reparability requirements under EU ecodesign legislation (household appliances, consumer electronics and similar goods), not any good whatsoever.

In other words: even though the Spanish parliament hasn't yet passed its own law, both directives already produce effects in Spain through direct application of EU law from their respective dates. What's missing is the Spanish law that formally folds them into the General Law for the Defence of Consumers and Users (TRLGDCU) and the Unfair Competition Act, with national implementing detail and the domestic penalty regime.

The new prohibitions in the Spanish draft bill

The Draft Law on Sustainable Consumption, approved by the Council of Ministers on 1 July 2025, adds the following, among others, to the blacklist of unfair commercial practices:

• Future-behaviour environmental claims (for example, "we'll be carbon neutral by 2030") made without a clear, public, verifiable commitment backed by a detailed implementation plan with time-bound interim targets.
• Sustainability labels without certification: displaying a label without proper authorisation, in breach of certification requirements, or one that doesn't come from a public authority or accredited body.
• Opaque product comparisons: when a company compares its products with a competitor's on environmental grounds, it must disclose the comparison method, the products and suppliers included, and how it keeps the information up to date.
• Planned obsolescence: hiding that a software update will affect how a product works, presenting non-essential updates as mandatory, misleadingly communicating features that limit durability, claiming a durability that isn't real, or inducing premature replacement of consumable parts.

These prohibitions are the legal basis for what's already known as greenwashing regulation: any environmental claim a company can't back up with documentation becomes, directly, an unfair commercial practice.

The right to repair in the Spanish draft bill

Building on Directive 2024/1799, the Spanish draft adds, among other measures: availability of spare parts for a minimum of ten years after production of a good ceases, an obligation to disclose the repairability score and the estimated cost of parts, a system for manufacturers to partially fund out-of-warranty repairs, and the option for a consumer to receive a refurbished good as a temporary substitute while a repair is carried out. The Right to Repair Directive explains the full EU framework, including the one-year extension of the legal guarantee when a consumer chooses to repair instead of replace.

The draft bill also regulates so-called shrinkflation: the obligation to visibly disclose when a product's quantity is reduced while the price stays the same or rises, with a minimum 90-day disclosure window.

At EU level, Directive 2024/1799 also adds two pieces worth having on your radar even if they don't affect day-to-day compliance yet: a standardised European Repair Information Form that a repairer can offer a consumer, whose terms stay valid for 30 days once issued, and a European online repair platform, planned for January 2028, meant to help consumers find repairers and sellers of refurbished goods. Neither requires immediate action, but both signal where the repairability framework is heading over the next few years.

For a marketing or legal team, the practical starting point is an inventory: every environmental claim currently in market materials, packaging, or product pages, matched against whether there's a document behind it that a regulator could actually request. A claim with no such document is the one to fix first, regardless of how the Spanish bill's own timeline plays out.

What it changes in existing Spanish law

Where the bill stands right now

The text's progress so far, with the dates that are publicly on record:

After the public consultation stage, the text must go back to the Council of Ministers as a formal bill (second round) before being sent to Congress for parliamentary debate. As of the most recent information we were able to verify, that submission to Congress had not yet happened. If your company needs certainty on the exact approval timeline, it's worth checking the bill's status in Congress before setting internal deadlines on that basis.

What a company should do while the Spanish law isn't approved yet

No company selling in Spain or to Spanish consumers can wait for Congress to pass the law before starting to comply. Directive 2024/825 has bound since 27 September 2026 and Directive 2024/1799 since 31 July 2026, and Spanish courts and the consumer authority itself can already apply an interpretation consistent with those directives when assessing a commercial practice. In practice, that means reviewing, before that date, any decarbonization strategy communication that promises future results without a verifiable plan, any in-house label without recognised certification, and any product environmental transparency communication that isn't backed by traceable data.

Frequently asked questions

Has Spain's sustainable consumption law already been approved?

No. As of the most recent verified information (March 2026), it was still at draft-bill stage, with the CNMC's report already issued but not yet submitted to Congress.

So there's nothing to comply with yet?

There is: the two EU directives the Spanish law transposes are already applicable in their own right, the consumer empowerment one from 27 September 2026 and the right to repair one from 31 July 2026, regardless of whether Spain has finished its own implementing law.

Which products does the right to repair cover?

The goods listed in Annex II of Directive 2024/1799, which are the ones that already carry reparability requirements under EU ecodesign legislation, such as certain household appliances and electronic equipment.

What if my company uses its own sustainability label?

The draft bill classifies it as an unfair practice if the label lacks a verifiable certification system or doesn't come from a public authority or accredited body.

Can I still announce future climate neutrality targets?

Only if the commitment is clear, public, verifiable by a third party, and comes with an implementation plan with time-bound interim targets. A generic target without that plan becomes an unfair practice.

What is shrinkflation and how does it affect me?

It's reducing a product's quantity while keeping or raising the price without disclosure. The draft bill requires visible disclosure for a minimum of 90 days whenever this happens.

Does the extra legal guarantee year for repairs apply automatically?

It applies when the consumer chooses repair over replacement under the legal guarantee, adding one year on top of the standard period, as set out in the amended Sale of Goods Directive that Directive 2024/1799 relies on.

While the Spanish law works its way through parliament, the prudent move is to back every environmental product claim with verifiable data rather than promises. At Manglai, our product carbon footprint solution is built to support those claims with the data and the document behind them, instead of exposing you to a misleading-advertising penalty.