Proposal for a Green Claims Directive

Proposal for a Directive of the European Parliament and of the Council on substantiation and communication of explicit environmental claims (Green Claims Directive)

Update

Since June 2025, negotiations to adopt the Green Claims Directive have stopped. There is no indication yet that they will resume in the future. However, a general prohibition on unsubstantiated or misleading environmental and social claims on products applies from 27 September 2026. Directive (2024/825) bans vague environmental claims (e.g. “green” or “environmentally friendly”) that cannot be demonstrated; see EU rules on environmental claims for products.

What was the proposed Green Claims Directive?

Due to concerns that consumers are misled by inaccurate environmental or “green” claims, in 2023 the European Commission proposed new rules on how businesses may voluntarily communicate the environmental aspects of their products or company before the products are put on the EU market. This included rules on how to justify and communicate green claims. It was proposed that EU Member States should establish assessment bodies to check and approve all green claims and green labelling schemes before they are made public.

What is changing?

Since June 2025, negotiations to adopt the Green Claims Directive have stopped. There is no indication yet that they will resume in the future. This followed an announcement by the European Commission that it intended to withdraw the Directive (although political negotiations were well advanced at that stage; European Commission 2025a). However, the proposal has not been formally withdrawn, and is listed in the Commission’s 2026 Workplan as “pending” (European Commission 2025b).

Withdrawal of the proposal does not mean there are no rules regarding environmental claims. From 27 September 2026, new EU requirements apply that prohibit different types of unsubstantiated or misleading claims, such as sustainability labels that are not substantiated through private or public certification schemes; unsubstantiated generic claims (e.g. “green” or “environmentally friendly”); or unjustified comparisons with the environmental characteristics of similar products (see EU rules on environmental claims for products).

For details of what was proposed in the 2023 Directive, see Background.

Why?

To support its environmental goals, the Commission seeks to better inform EU consumers about the impacts of products on the environment, to help them make their purchasing decisions. In recent years there has been concern about “greenwashing” – making unjustifiable claims with regard to the environmental performance of products or businesses. The Commission fears that the existence of multiple private and EU Member State environmental labelling schemes could damage EU businesses’ capacity to sell products throughout the EU.

Timeline

The proposed Directive has not been formally withdrawn by the European Commission, but negotiations on the proposal stopped in in June 2025 and there is no indication that they will start again.

Recommended Actions

Businesses supplying the EU market should ensure that they have adequate information (e.g. environmental assessments) to support any green/environmental claims that they make in relation to their products.

Background

What was the 2023 Directive proposing to do?

To ensure that businesses communicate fairly to consumers about the environmental impacts of their products or business, the European Commission proposed new rules on:

• how EU Member States must check and approve claims and labelling schemes
• the information that businesses must make available to consumers to justify their green claims
• how environmental labelling schemes are managed.

The Directive proposed to verify and authorise voluntary green claims on products before they were put on the EU market. It did not create an obligation to include environment-related information on products.

The proposed definition of environmental or green claim was: “any message […] which states or implies that a product or trader has a positive or no impact on the environment or is less damaging to the environment than other products or traders, respectively, or has improved their impact over time” (definition in the Proposal for a Directive).

Justifying and communicating green claims

it was proposed that businesses making “explicit environmental claims” (written claims that appear on an environmental label) about their products or business would substantiate claims as follows.

Before supplying their products on the EU market, businesses would have to carry out an assessment (Art. 3) demonstrating that the claimed environmental impacts:

• go beyond what is required by law and are significant, taking into account the whole life-cycle of the product, including both positive and negative environmental impacts
• are precise regarding claims that their greenhouse gas emissions have been “offset” by carbon credits.

Where possible, businesses would have to provide primary company-specific data to demonstrate the environmental performance claimed. Where this is not possible, they would provide accurate secondary information based on other sources such as literature studies.

Where a business claims that its products are environmentally better than other products (“comparative environmental claim”), it would also have to demonstrate that the data compares equivalent environmental impacts and stages of the value chain fairly (Art. 4).

No standard methodology for substantiating claims

The European Commission has developed guidance for measuring the life-cycle environmental performance – the product environmental footprint – of specific products (Recommendation 2021/2279). However, in 2023 the Commission considered that for certain products, including fish and food, the methodology did not take into account all potential environmental impacts. Businesses were therefore not tied to a methodology and were expected to choose how to substantiate their claims.

Communication of environmental claims

The Directive proposed that a business would have to make available information relating to the environmental claim (Art. 5), either in physical form or online, including:

• details of environmental performance
• underlying studies and calculations
• a certificate of conformity demonstrating that the claim has been approved (see “Approval” below)
• a consumer-friendly summary of the assessment that supports the claim.

When the way in which a product is used (e.g. how it needs to be disposed of) is relevant to the product’s claimed environmental performance, consumers would have to be informed about this use.

Environmental labels and labelling schemes

Environmental labels – voluntary quality marks (public or private) that cover “only or predominantly environmental aspects of the product, process or trader” (Art. 2(8)) – are often represented as an overall environmental score or rating. The Directive proposed that such scores/ratings would be permitted only if awarded under an approved environmental labelling scheme (Art. 7).

Management of environmental labelling schemes

Under the proposed Directive, environmental labelling schemes – third-party verification schemes certifying that a product complies with certain requirements – would only be approved (Art. 8) if they:

• provide transparent and freely accessible information about the scheme: its ownership, decision-making bodies, objectives, and requirements and procedures to monitor compliance
• establish conditions for joining the scheme that do not exclude small and medium enterprises
• are scientifically robust and tested with stakeholders
• have complaint and dispute resolution mechanisms
• have procedures in place to deal with non-compliance, including the possibility to withdraw or suspend labels.

New environmental labelling schemes

One concern that the Directive aimed to address is the growing number of different private, industry-led labelling schemes. To limit this, it was proposed that from the date when the new rules would apply:

• in EU Member States, no new national/regional public labelling schemes would be permitted
• in non-EU countries, new private and public national labelling schemes would be approved for use on products exported to the EU only when they add value compared to existing schemes, for example if they have more environmental ambition or greater coverage of environmental impacts, or focus on certain products.

Approval of environmental claims/labels

The Directive proposed that all environmental claims and environmental labels would have to be verified and approved before being made public. EU Member States would be responsible for setting up the assessment bodies (or verifiers) and procedures to check that environmental claims and labels comply with the rules on justification and communication, and that environmental labelling schemes meet requirements. Where criteria were met, the verifier would issue a certificate of conformity confirming that the claim, label, and/or labelling scheme complies with the EU rules. A certificate of conformity issued in one Member State would be valid for the whole EU market.

Unfair commercial practices and consumer rights

The Unfair Commercial Practices Directive (2005/29/EC) and the Consumer Rights Directive (2011/83/EU) aim to protect the interests of consumers at EU level.

Resources

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