EU Green Claims Directive and Green Transition Rules Comparative Claims

This page is relevant 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.

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.

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.

The public comparison should not force consumers to guess what was compared. From 27 September 2026, when a trader provides a service comparing products on environmental, social, or circularity characteristics, national measures implementing Directive (EU) 2024/825 treat information about the comparison method, compared products, suppliers, and update measures as material information. Before that date, assess omissions under the current UCPD and national law.

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.

A comparison fails when it cannot be reproduced on an equivalent basis. A product-level claim can mislead 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.