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6 min

EU Green Claims Directive: What You Need to Know

Posted by: Aishwaryaa Shashi Date: 24 Jul 2025

The EU Green Claims Directive aims to prevent greenwashing and protect consumers and the environment. With this landmark legislation on the horizon, businesses must prepare for stringent new requirements. So, are you confident that your environmental claims are verifiable and transparent?

What is a Green Claim?

A green claim, or environmental claim, is any statement suggesting a product or service has environmentally beneficial attributes related to emissions, recyclability, or other environmental impacts.

According to the European Commission:

  • 53% of green claims give vague, misleading or unfounded information
  • 40% of claims have no supporting evidence
  • Half of all green labels offer weak or non-existent verification
  • There are 230 sustainability labels and 100 green energy labels in the EU, with vastly different levels of transparency
  • 25% of misleading claims arise from the fashion industry

Examples of green claims:

“Company's environmental footprint reduced by 10% since 2021”

“Packaging made from 50% recycled plastic”

“CO2 emissions linked to this product halved compared to 2019”

What is the EU Green Claims Directive?

The EU Green Claims Directive will establish minimum obligatory requirements for companies making environmental claims to EU consumers, ensuring claims are supported, communicated transparently, and independently verified. Companies will need to provide robust, science-based evidence to back up their environmental claims, and these claims will be subject to verification by independent bodies.

Main objective of the directive

The directive addresses voluntary environmental claims not already governed by other EU regulations (e.g. Digital Product Passport, European Sustainability Reporting Standards (ESRS)). It aims to:

  • Standardise how environmental information is communicated
  • Protect consumers
  • Create fair competition by rewarding genuinely sustainable businesses

Implementation timeline of the EU Green Claims Directive

2023

In March 2023, the European Commission proposed common criteria against greenwashing and misleading environmental claims, known as the Green Claims Directive.

2024

In March 2024, the EU Parliament published their amendments to the Directive.

2025

The Directive was expected to be formally adopted into EU law by the end of 2025. Adoption is currently paused as negotiations were suspended in June 2025 due to micro-business concerns and political pressure.

2026-2027

Once the Directive is formally adopted, EU Member States will have around 18 to 24 months (depending on negotiations) to incorporate it into their national laws.

Companies will have another year to conform to the new rules. Therefore, full business compliance may be required in early 2028.

However, these timelines are subject to change depending on the pace of negotiations and national implementation processes. Therefore, while the Directive is not yet in force, businesses are strongly encouraged to begin preparations now to ensure timely compliance and to benefit from early alignment with standards.

Key highlights from the EU Green Claim Directives

The Directive introduces several stringent requirements that will fundamentally change how businesses communicate environmental benefits:

Specific definitions

Claims like “carbon neutral" or "green" must be specific, well-defined, and verifiable.

Comprehensive substantiation for future environmental performance claims

Environmental claims related to environmental performance such as “carbon neutral by 2030” or “fully renewable by 2050 must be supported by transparent reporting with information accessible to consumers.

Significant improvements

Comparative environmental claims such as “Our shoes produce 30% fewer CO2 emissions than X brand “, cannot compare improvements to products from the same trader or inactive competitors unless the improvement is significant and achieved within the last five years.

Third-party verification

Under the directive proposal, claims must be verified by accredited third-party bodies before market launch, with reviews at least every 5 years.

Ban on misleading practices

Ban on self-certified labels

Generic terms like “eco-friendly” or “sustainable” are prohibited without proper evidence related to the environmental performance of the product. Claims must be backed by approved methodologies that meet specific criteria, often requiring comprehensive Life Cycle Assessment (LCA).

Ban on self-certified labels

Sustainability/eco labels and self-certified labels, lacking conformity certification and regular monitoring, are prohibited.

Ban on claims about entire products

Claims about an entire product are prohibited if the significance is only relevant to one aspect and must be backed by an approved methodology that meets specific criteria.

Ban on environmental claims for products containing hazardous substances

Products with hazardous substances cannot make environmental claims suggesting they are eco-friendly or less harmful.

Ban on unverified carbon claims

For "carbon neutral" claims, companies must demonstrate that they have offset their emissions through credible and verified carbon offset projects or other mitigation measures. For claims like “carbon neutral,” the entire value chain must be considered, not just partial aspects.

Regular reviews and updates

Member States must ensure that traders review and update the substantiation and communication of their claims at least every 5 years to maintain compliance with the Directive.

ISO standards and LCA

The methodology for claiming emphasises using relevant ISO standards and comprehensive LCA evaluating both positive and negative environmental impacts even if you are claiming one aspect and not whole product.

No legal or standard practice claims

The proposal forbids claims like “plastic recyclability” or “no forced labour” that merely indicate compliance with the law or highlight benefits that are already standard practice in the market.

Proposal is not directly enforceable

The proposal is not directly enforceable so each EU Member State must adopt them into their national regulations to take any actions.

Who Will Be Impacted by the Directive?

The Directive applies to all businesses operating in the EU which make environmental claims about their products, services, or company operations. This includes:

  • EU-based businesses of all sizes
  • Non-EU companies targeting EU consumers
  • Manufacturers, wholesalers, and retailers

The UK Context: Green Claims Code and Related Regulations

While the UK is not subject to this EU directive, it has established its own approach through the Green Claims Code introduced by the Competition and Markets Authority (CMA). However, UK businesses operating in the EU or marketing to EU consumers will still be required to comply with both the upcoming Green Claims Directive and the existing Empowering Consumers for the Green Transition Directive (ECGT) (EU) 2024/825 referred to as a “sister directive” to the Green Claims Directive.

Key differences include:

  • The UK Green Claims Code is a voluntary framework while the EU Directive will be mandatory
  • The UK code applies to both Business to Consumer (B2C) and Business to Business(B2B) transactions, whereas the EU directive applies only to B2C
  • The UK code allows more flexibility in substantiating claims and does not mandate third-party verification

The UK Green Claims Code emphasises six key compliance checkpoints:

  1. Truthfulness: Claims must be accurate
  2. Clarity: Claims must be unambiguous
  3. Transparency: No hidden information
  4. Comparability: Fair product or service comparisons
  5. Evidence-based: Strong supporting evidence required
  6. Holistic: Claims should consider full life cycle assessment

The main areas of CMA investigation are:

  • Vague terms claimed by a product such as “natural”/” eco-friendly”, etc
  • Use of exaggerated environmental claims
  • Claiming that the entire product is recyclable when only one part (e.g. the packaging) is recyclable
  • Using green logos or labels on products without any supporting evidence

WHAT ARE THE LEGAL IMPLICATIONS BEHIND GREENWASHING REGULATIONS?

  • Financial penalties of up to 4% of annual turnover in the EU
  • Additional financial penalties may be imposed by individual EU Member States
  • Forced withdrawal of non-compliant environmental claims
  • Reputational damage and loss of consumer trust
  • Investors may seek compensation if they have incurred losses due to greenwashing, particularly in the case of large, listed companies
  • Legal proceedings initiated by regulatory authorities
  • In the UK, the CMA can issue fines of up to 10% of annual turnover, and individuals may face penalties of up to £300,000 under the Digital Markets, Competition and Consumers Act 2024 (DMCCA) for breaches of consumer protection laws
  • In extreme cases, criminal liability may apply

How to Prepare for the EU Green Claims Directive: Avoiding Greenwashing in Your Marketing

To ensure compliance and avoid accusations of greenwashing, we recommend:

  • Audit existing claims: Begin life cycle assessment, critical review and compliant labelling now across marketing materials, packaging, and websites
  • Document substantiation: Ensure robust documentation supports each claim
  • Develop verification processes: Establish protocols for independent third-party verification
  • Train marketing teams: Educate staff on the new requirements and compliant messaging
  • Implement regular reviews: Claims must be reviewed and updated at least every 5 years

TÜV SÜD’s Services for the EU Green Claims Directive: Verifying Your Environmental Claims

We offer a comprehensive range of services to help you fulfil these complex requirements:

Contact our experts to discuss how we can help you ensure your environmental claims meet the highest standards of verification, helping you build consumer trust while maintaining regulatory compliance.

Explore our carbon management services.

Your Next Steps

The EU Green Claims Directive proposal represents a significant shift in how environmental claims must be substantiated and communicated. By taking proactive steps now, you can ensure compliance while strengthening consumer trust in your sustainability efforts.

We recommend conducting a thorough assessment of your current environmental claims under ECGT Directive 2024/825 compliance by March 2026, while monitoring progress on the Green Claims Directive and developing a strategic roadmap for compliance.

Ready to validate your environmental claims? Contact our experts today to find out how we can help you prepare for the EU Green Claims Directive.

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