EU Green Claims Directive Proposal FAQ on environmental claim categories

An explicit environmental claim is an environmental claim made in written form or orally. The Council text distinguishes it from implicit claims such as colours or imagery, which remain handled under the wider unfair-commercial-practices framework.

For an explicit claim, the evidence file should first state exactly what the claim covers: the whole product, part of a product, a product aspect, all trader activities, or a specific activity. The assessment then needs scientific evidence, accurate information, relevant standards, significant life-cycle impacts or aspects, primary information where available, representative secondary information where primary data is not available, and a check that the claim is not merely a legal minimum.

Directive (EU) 2024/825 defines a generic environmental claim as written or oral environmental wording whose specification is not provided in clear and prominent terms on the same medium. From 27 September 2026, national implementing measures prohibit such a claim unless the trader can demonstrate recognised excellent environmental performance relevant to it. Existing UCPD rules can still catch vague or misleading wording before then.

Do not approve a generic claim because a product has one positive attribute. The evidence should show the claimed environmental excellence is relevant to the claim, significant for the product or trader, not just common practice, and not offset by unmentioned trade-offs.

A comparative environmental claim says or implies that one product or trader has lower environmental impact or better environmental performance than another. It needs the normal explicit-claim evidence plus equivalence across the comparison.

The comparison file should prove that the compared products or traders use equivalent data, equivalent sourcing or generation methods, equivalent value-chain coverage, equivalent impact or aspect coverage, and equivalent assumptions. If the comparison is against an older product, a discontinued product, or a trader that no longer sells to consumers, the record should state the baseline year and show the improvement is significant and recent.

Product claims need evidence for the specific good or service and the life-cycle stages that matter to that claim. If the use phase is one of the most relevant life-cycle stages, the claim should tell consumers how to use the product to achieve the stated environmental performance.

Trader or company claims need evidence for the activities covered by the wording. A company-level claim cannot borrow a narrow product improvement unless the claim clearly limits itself to that product, activity, site, business line, or environmental aspect. Product Environmental Footprint and Organisation Environmental Footprint methods are relevant because they are life-cycle methods for products and organisations, respectively.

An environmental label is not just a short claim in a logo. The proposal treats labels as claims awarded under environmental labelling schemes, with scheme-level evidence and governance requirements in addition to claim substantiation.

The scheme owner should be able to show transparent ownership, decision-making bodies, objectives, monitoring procedures, proportionate joining conditions, expert and stakeholder input for criteria, complaint and dispute handling, and non-compliance procedures. The label should also be verified against the relevant substantiation, communication, and scheme requirements unless an applicable exemption or simplified route applies.

Climate claims need the normal explicit-claim file and a separate climate evidence file. From 27 September 2026, national measures implementing Directive (EU) 2024/825 prohibit claims that a product has a neutral, reduced, or positive greenhouse-gas impact based on offsets outside the product value chain. Existing UCPD rules can still apply to misleading offset claims before that date.

For trader climate claims using carbon credits, the evidence should separate the trader's greenhouse-gas emissions and reductions from any credits. It should identify the quantity of credits in tCO2e, the period, whether credits are reductions or removals, the scheme, registry, verification and certification route, and, for offset claims, the percentage of total greenhouse-gas emissions balanced out by credits.

For internal publication approval, create a claim register entry for each category. The entry should identify the exact wording, medium, market, product or trader boundary, category, owner, evidence method, source data, consumer-facing support, verification route, and review trigger.

The evidence file should be strong enough for a reviewer to tell whether the claim is specific, accurate, significant, current, not misleading by omission, and not broader than the data. It should also preserve the public explanation consumers will see, because Green Claims communication rules focus on both substantiation and how the substantiated claim is communicated.