EU Green Claims Proposal and Green Transition Rules Claim Categories

Under the Council general approach, treat a written or oral claim as an explicit environmental claim when it tells consumers that a product, service, brand, product category, trader, or business activity has a positive, zero, reduced, or improved environmental impact. The Commission proposal also includes claims contained in environmental labels, while the Council text routes environmental labels separately. Both texts focus on voluntary business-to-consumer claims that are not already regulated by more specific EU rules.

Examples for triage include product packaging claims, web copy, ads, sales scripts, public product pages, company-name or product-name wording with an environmental meaning, and environmental labels when they communicate an environmental benefit. For this category, the owner should record the claim text, medium, audience, claimed benefit, product or trader boundary, and whether a sector rule already governs the claim.

Flag a claim as comparative when it says or implies that one product, product category, supplier, brand, trader, or business activity is greener, cleaner, lower-impact, more recyclable, more durable, or otherwise environmentally preferable to another. Comparisons need a common method, comparable products or suppliers, material and verifiable features, and a way to keep the comparison current.

The comparison file should name the compared products or suppliers, the function being compared, the environmental characteristics used, assumptions, data sources, calculation method, update trigger, and any limits. A broad comparison should be narrowed if it only supports one attribute, one life-cycle stage, one market, or one version of the product.

Separate product claims from trader or company claims before review. A product claim should identify the exact good, service, component, packaging element, feature, or life-cycle stage covered. A trader claim should identify whether it covers the entire business, a site, a portfolio, a specific activity, procurement practice, logistics network, or other operating boundary.

From 27 September 2026, national measures implementing Directive (EU) 2024/825 specifically target overbroad claims about an entire product or a trader's entire business when the evidence only concerns a certain product aspect or a specific business activity. A recycled-material claim for packaging, a renewable-energy claim for one facility, or a repairability claim for one model should not be written as if it describes the full product, brand, or business. Before that date, the same boundary can still matter under the current UCPD's misleading-action and misleading-omission tests.

Route climate-neutral, CO2-neutral, carbon-positive, climate-net-zero, climate-compensated, reduced-climate-impact, limited-CO2-footprint, and similar wording to a separate review path. From 27 September 2026, national measures implementing Directive (EU) 2024/825 must prohibit claims that a product has a neutral, reduced, or positive greenhouse-gas impact when that claim is based on offsetting outside the product value chain.

A product climate claim should therefore distinguish actual life-cycle impact evidence from information about investments in environmental initiatives or carbon-credit projects. Future climate-performance claims also need clear, objective, publicly available and verifiable commitments, measurable time-bound targets, a realistic implementation plan, allocated resources, and independent third-party verification.

Treat environmental labels and sustainability labels as their own category. From 27 September 2026, national measures implementing Directive (EU) 2024/825 must prohibit displaying a sustainability label that is neither based on a certification scheme nor established by a public authority. The Green Claims proposal separately addresses environmental labelling schemes and labels covering environmental aspects of products or traders.

For every label, keep a register showing the scheme owner, public-authority basis or certification scheme basis, eligibility criteria, monitoring process, withdrawal or suspension rules, scope, product or business covered, and evidence that the trader is allowed to display it. Do not treat self-created icons, badges, trust marks, or private seals as low-risk simply because they look small on a page.

Flag generic environmental claims such as green, eco-friendly, environmentally friendly, nature's friend, ecological, climate friendly, carbon friendly, energy efficient, biodegradable, biobased, sustainable, conscious, or responsible when the claim is not specified clearly and prominently on the same medium. From 27 September 2026, national measures implementing Directive (EU) 2024/825 must prohibit generic environmental claims where the trader cannot demonstrate recognised excellent environmental performance relevant to the claim.

Generic wording should usually be replaced with the specific substantiated benefit: recycled content, lower energy use, repairability, recyclability, durability, reduced packaging, renewable energy used for a defined process, or another supported characteristic. If the claim remains generic, the file needs evidence of recognised excellent environmental performance that is relevant to the entire claim; an adjacent label or rating is insufficient unless its scope supports the wording.

The evidence file should answer five questions: what exact claim is being made, who generated it, what product or trader boundary it covers, what environmental characteristic is claimed, and what cited evidence makes the claim reliable, comparable, verifiable, current, and understandable to consumers.

For explicit claims and labels, the Green Claims proposal points toward substantiation, communication, review, verification, and certification. For UCPD-based controls, the evidence should also be ready for competent authorities because the Commission-hosted Compliance Criteria say factual environmental statements should be supported and the evidence retained for a reasonable period after use in a commercial communication.