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Green ClaimsComparative claimsEU

EU Green Claims Proposal 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
Oct 15, 2026
5 sections5 primary sources
Overview

Use this page before publishing a consumer-facing environmental comparison between products, suppliers, or traders. Check that both sides use equivalent evidence, a clear comparator, and the same method. The Green Claims Directive remains a stalled proposal, so its extra comparison and verification rules are planning controls. Apply the current UCPD and national law now; Member States' measures implementing Directive (EU) 2024/825 apply from 27 September 2026.

Section 1

When is an environmental comparison in scope?

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, 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.
  • The Council draft excludes comparative claims from Article 3a(3)'s future implementing-act branch for less complex claims. Its other Specific Technical Documentation branches are defined separately. Record the exact branch and eligibility basis; none is a current Green Claims approval route.
  • 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.
Recommended next step

Review comparative environmental claims before publication

This page helps 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.
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.
Section 4

What information should accompany the consumer-facing comparison?

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.

  • 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 the applicable verification route requires it; do not imply public approval, endorsement, or authorisation that has not been granted.
Section 5

Where do comparative claims usually fail?

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.

  • 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.
Primary sources

References and citations

Council general approach on the Green Claims Directive
data.consilium.europa.eu6 citations
Referenced sections
  • Grounds the Council comparative-claim text: same product group or sector, similar purpose or function, same assessment method, equivalent value-chain and impact coverage, consumer summaries, verifier information, and UCPD non-prejudice.
  • Grounds the same product group, sector, purpose, use, or functional-property screen for comparative claims.
  • Council Article 4 text adds that the method used for assessing environmental characteristics must be the same.
Show 3 more
  • Supports documenting significant environmental characteristics and recent significant improvement for certain baseline comparisons.
  • Council communication text supports a clear consumer summary and, where applicable, certificate and verifier contact information.
  • States that UCPD assessment by authorities or courts is not prejudiced by verifier or technical-documentation assessment.
"same product group or sector"
More quoted passages
"method used for assessing"
"improvement is significant"
"clear and easy to understand"
"should not prejudice the assessment"
Commission Green Claims proposal COM(2023) 166
eur-lex.europa.eu5 citations
Referenced sections
  • Grounds the Commission proposal provisions on comparative-claim substantiation, baseline years, significant impacts, communication, substantiation information, and verification references.
  • Defines comparative environmental claims and sets extra substantiation requirements in Article 4 of the proposal.
  • Article 4 supports equivalent information, data sourcing, value-chain coverage, impact coverage, and assumptions for comparative claims.
Show 2 more
  • Supports baseline-year disclosure and explanation of effects on other relevant environmental impacts for improvement comparisons.
  • Article 5 supports making substantiation information available with the claim, including studies, assumptions, limitations, and verification information where applicable.
"generated or sourced in an equivalent manner"
More quoted passages
"comparative explicit environmental claims"
"baseline year for the comparison"
"made available together with the claim"
Compliance Criteria on Environmental Claims
commission.europa.eu4 citations
Referenced sections
  • Grounds consumer-law guidance that environmental comparisons should be objective, relevant, use the same function, methods and assumptions, and rely on verifiable evidence.
  • UCPD-oriented guidance supports comparing products serving the same function with the same methods and assumptions.
  • Supports verifiable, recognised evidence and regular review of claims as comparable products and circumstances change.
Show 1 more
  • Supports avoiding misleading comparative advertising and keeping the comparison objective, relevant, verifiable, and representative.
"same methods and assumptions"
More quoted passages
"robust, independent, verifiable"
"objective and relevant"
Directive (EU) 2024/825 on empowering consumers for the green transition
eur-lex.europa.eu4 citations
Referenced sections
  • Grounds the UCPD overlap for environmental comparisons, including method, compared products, suppliers, update measures, generic environmental claims, labels, and future-performance claims.
  • Shows that environmental comparisons can also trigger material-information duties under amended UCPD Article 7.
  • Amended UCPD Article 7 makes comparison method, products, suppliers, and update measures material for certain comparison services.
Show 1 more
  • Supports UCPD prohibitions and material-information duties for greenwashing, generic claims, labels, future-performance claims, and comparisons.
"method of comparison"
More quoted passages
"measures in place to keep"
"clear, relevant and reliable information"
Commission Draft Amending Budget No 2 for 2026, COM(2026) 460
data.consilium.europa.eu
Referenced sections
  • Current official status source: Green Claims negotiations were at a standstill and no agreement was expected in 2026.
"The negotiations on the Green Claims Directive proposal are at a standstill, and no agreement is expected in 2026."

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