Green ClaimsComparative claimsEU

EU Green Claims Directive and Green Transition Rules Comparative Claims

Check whether a comparative environmental claim uses a comparable product, function, method, dataset, value-chain boundary, and impact basis.

The page focuses on consumer-facing environmental comparisons, including the overlap between the Green Claims proposal, the Council text, Directive (EU) 2024/825, and UCPD guidance.

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Author

Sorena AI

Published

May 9, 2026

Updated

May 9, 2026

Sections

Structured answer sets in this page tree.

Primary sources

Cited legal and guidance references.

Publication metadata

Sorena AI

Published May 9, 2026

Updated May 9, 2026

Overview

Under the EU Green Claims Directive proposal, comparative environmental claims sit alongside the new consumer-law rules in Directive (EU) 2024/825, which amended the Unfair Commercial Practices Directive. Use this page to check whether a comparison between products, suppliers, or traders is based on equivalent evidence, clear disclosure, and the same comparison method before publication.

Section 1

When is an environmental comparison in scope?

Use this page when marketing text, packaging, online ranking, sales material, a label, or a comparison service states or implies that one product, product category, brand, supplier, or trader is environmentally better, less damaging, improved, or more sustainable than another.

Under the Commission proposal, comparative environmental claims are explicit claims that state or imply lower environmental impacts or better environmental performance than other products or traders. The Council text adds a tighter comparator screen: the compared product or trader should belong to the same product group or sector and serve a similar purpose, use, or functional property.

Capture direct claims such as lower-carbon, less water-intensive, more recyclable, greener than, or improved versus a named baseline.
Capture implied comparisons created by badges, tables, filters, scores, product rankings, or side-by-side sustainability messaging.
Do not use the simplified self-documentation route for comparative claims unless the final applicable law later creates a specific route for that claim type.
Do not treat verifier review as a consumer-law safe harbour; UCPD authorities and courts can still assess whether the practice is unfair or misleading.

Sources for this answer

Council general approach on the Green Claims Directive

Grounds the same product group, sector, purpose, use, or functional-property screen for comparative claims.

Commission Green Claims proposal COM(2023) 166

Defines comparative environmental claims and sets extra substantiation requirements in Article 4 of the proposal.

Directive (EU) 2024/825 on empowering consumers for the green transition

Shows that environmental comparisons can also trigger material-information duties under amended UCPD Article 7.

Recommended next step

Review comparative environmental claims before publication

Use this page to align comparator selection, methods, datasets, value-chain coverage, impact significance, public wording, and verification evidence before teams publish environmental comparisons.

Research workflow

Open Research Copilot

Check comparative environmental-claim questions against cited EU source material.

Explore next step

Talk to Sorena

Discuss Green Claims implementation

Review comparator basis, substantiation files, and consumer-facing wording with Sorena.

Explore next step

Section 2

What must be equivalent before publishing the comparison?

Build the comparison around equivalence, not around whichever data happens to be available. A claim such as lower emissions, less water use, more recyclable, or better environmental performance should compare like with like and should use the same method for both sides.

The Green Claims proposal requires equivalent information, equivalent data generation or sourcing, equivalent value-chain coverage, equivalent environmental impacts or aspects, and equivalent assumptions. The Council text keeps those tests and makes method consistency explicit.

Comparator basis: identify the compared products, traders, product group, sector, purpose, use, and functional property.
Function basis: document the service delivered by the products, such as use cycles, volume, lifetime, serving size, delivery distance, or performance level.
Method basis: use the same assessment method, formula, allocation choices, emission factors, impact categories, and calculation boundary for both sides.
Data basis: show that data is generated or sourced in an equivalent way, including time period, geography, technology, supplier tier, primary data, secondary data, and quality checks.
Value-chain basis: cover equivalent life-cycle or value-chain stages and include the most significant stages for each product or trader compared.
Impact basis: cover equivalent environmental characteristics and do not omit significant impacts, aspects, or trade-offs that would change the comparison.

Sources for this answer

Commission Green Claims proposal COM(2023) 166

Article 4 supports equivalent information, data sourcing, value-chain coverage, impact coverage, and assumptions for comparative claims.

Council general approach on the Green Claims Directive

Council Article 4 text adds that the method used for assessing environmental characteristics must be the same.

Compliance Criteria on Environmental Claims

UCPD-oriented guidance supports comparing products serving the same function with the same methods and assumptions.

Section 3

What evidence belongs in the comparative-claim file?

The evidence file should let a reviewer reconstruct the comparison without relying on marketing intent. Keep the actual claim wording, the comparator set, the calculation method, the data lineage, and the consumer-facing summary together.

If the claim compares current performance with an earlier product version or a product no longer sold, add a baseline year and evidence that the improvement is significant and recent where the applicable Green Claims text requires that showing. Also explain whether the improvement creates or worsens other relevant environmental impacts.

Claim record with exact public wording, channel, market, product SKUs or trader entities, and publication owner.
Comparator record listing each compared product, trader, supplier, or baseline and why it serves the same or similar function.
Method note with calculation rules, standards or tools used, system boundary, allocation rules, assumptions, exclusions, and limitations.
Data register with source type, collection date, geography, technology, supplier coverage, primary or secondary status, and data-quality review.
Significance review listing the most significant life-cycle stages, environmental impacts or aspects, and any material trade-offs outside the headline claim.
Change log for improved-over-time claims, including baseline year, current measurement period, affected impacts, and evidence that the improvement is not merely a legal minimum or common market practice.

Sources for this answer

Commission Green Claims proposal COM(2023) 166

Supports baseline-year disclosure and explanation of effects on other relevant environmental impacts for improvement comparisons.

Council general approach on the Green Claims Directive

Supports documenting significant environmental characteristics and recent significant improvement for certain baseline comparisons.

Compliance Criteria on Environmental Claims

Supports robust, verifiable, recognised evidence and regular review of claims as comparable products and circumstances change.

Section 4

What information should accompany the consumer-facing comparison?

The public comparison should not force consumers to guess what was compared. When a trader provides a service comparing products on environmental, social, or circularity characteristics, Directive (EU) 2024/825 treats information about the comparison method, compared products, suppliers, and update measures as material information.

For explicit environmental claims under the Green Claims proposal, substantiation information is also expected to be available with the claim through a physical format, web link, QR code, or equivalent. Where verification applies, the proposal includes the certificate of conformity and verifier contact information among the information to be made available.

State the exact environmental characteristic being compared rather than using broad greener, cleaner, or sustainable phrasing.
Name or define the compared products, suppliers, baseline, or benchmark in a way consumers can understand.
Explain the comparison method and scope, including major assumptions, value-chain stages, and exclusions that could affect the result.
Explain how the information is kept current, especially when prices, supplier data, product specifications, or environmental datasets change.
Make certificate or verifier information available only where grounded by the applicable verification route; do not imply public approval, endorsement, or authorisation that has not been granted.

Sources for this answer

Directive (EU) 2024/825 on empowering consumers for the green transition

Amended UCPD Article 7 makes comparison method, products, suppliers, and update measures material for certain comparison services.

Commission Green Claims proposal COM(2023) 166

Article 5 supports making substantiation information available with the claim, including studies, assumptions, limitations, and verification information where applicable.

Council general approach on the Green Claims Directive

Council communication text supports a clear consumer summary and, where applicable, certificate and verifier contact information.

Section 5

Where do comparative claims usually fail?

Most failures are not caused by a missing slogan; they are caused by a comparison that cannot be reproduced on an equivalent basis. A product-level claim can become misleading when one side uses cradle-to-gate data and the other uses full life-cycle data, when the products do not serve the same function, or when the headline omits a significant impact category.

Consumer-law overlap matters. Directive (EU) 2024/825 adds specific greenwashing rules to the UCPD, while the Green Claims proposal adds more detailed substantiation, communication, and verification rules for explicit environmental claims. Meeting one file requirement does not remove the need for a clear, non-misleading commercial practice.

Do not compare a premium product with a different function, lifetime, dosage, service level, or use pattern unless the claim clearly normalises the comparison.
Do not mix supplier-reported data for one product with modelled or industry-average data for another unless the evidence explains why the data is equivalent.
Do not claim improvement over an old product, discontinued competitor, or historical baseline without baseline-year evidence and a check for other affected impacts.
Do not present legally required or common product-category features as if they are distinctive environmental benefits.
Do not use sustainability labels, scores, or certification marks to imply independent approval unless the scheme, certificate, and scope support that message.

Sources for this answer

Directive (EU) 2024/825 on empowering consumers for the green transition

Supports UCPD prohibitions and material-information duties for greenwashing, generic claims, labels, future-performance claims, and comparisons.

Council general approach on the Green Claims Directive

States that UCPD assessment by authorities or courts is not prejudiced by verifier or technical-documentation assessment.

Compliance Criteria on Environmental Claims

Supports avoiding misleading comparative advertising and keeping the comparison objective, relevant, verifiable, and representative.

Primary sources

References and citations

Commission Green Claims proposal COM(2023) 166

eur-lex.europa.eu

Referenced sections

Article 5 supports making substantiation information available with the claim, including studies, assumptions, limitations, and verification information where applicable.