EU Green Claims Directive Proposal Compliance

The Commission proposal covers explicit environmental claims made by traders about products or traders in business-to-consumer commercial practices. Treat every textual claim and environmental label as a recordable item, including packaging, product pages, ads, QR-code content, brand names, symbols, and label displays that suggest environmental performance.

Classify each entry by claim boundary: whole product, part of product, specific environmental aspect, trader-wide activity, future performance claim, comparison, label, aggregated score, or claim using greenhouse-gas offsets. Also flag claims already governed by more specific Union rules so the team does not apply the Green Claims proposal where sector rules take precedence.

For each in-scope explicit environmental claim, prepare an assessment before approval. The proposal expects the assessment to specify the claim boundary, rely on widely recognised scientific evidence and accurate information, take relevant international standards into account, and show that the covered impacts, aspects, or performance are significant from a life-cycle perspective.

The dossier should distinguish primary information collected by the trader from representative secondary information. Where the claim uses offsets, keep emissions data separate from offset information and document whether the offsets are reductions or removals, plus the basis for integrity and correct accounting.

The proposed communication control is narrower than a general marketing review. The public claim should only cover impacts, aspects, or performance that have been substantiated, and the consumer-facing support should be available with the claim through a physical disclosure, web link, QR code, or equivalent.

For a final product where the use phase is among the most relevant life-cycle stages, the claim file should include the consumer-use information needed to achieve the expected environmental performance. For future environmental performance claims, keep the commitment time-bound and tied to improvements inside the trader's own operations and value chain.

Comparative environmental claims need a separate comparison file. The proposal expects equivalent information, data generation, value-chain coverage, impact coverage, and assumptions for the compared products or traders. If the comparison relies on an improvement over an older product, the record should explain the baseline and the effect on other relevant environmental impacts, aspects, or performance.

Labels and certification schemes need their own register. Under the proposal, environmental labels must meet substantiation and communication requirements and be subject to verification; environmental labelling schemes need transparent ownership, objectives, monitoring procedures, expert-developed requirements, complaint handling, and non-compliance procedures. Under Directive (EU) 2024/825, displaying a sustainability label not based on a certification scheme or not established by a public authority is added to the UCPD blacklist.

The Green Claims Directive has no adopted compliance deadline. The Commission proposal supports planning for verification before publication and a certificate of conformity after a verifier finds compliance. The Council text also proposes Specific Technical Documentation for eligible Article 3a claims instead of the full Articles 3 and 10 route. Record the institutional text, exact eligibility branch, and consumer-disclosure requirement; none currently grants EU Green Claims approval.

A defensible compliance file should let a decision owner or future verifier trace the claim from public wording to substantiation, communication, approval, and withdrawal. Keep the file usable even if the final adopted text changes: show which source text was used, which assumptions are proposal-stage, and which facts need confirmation before launch.