Environmental Labels and certification schemes under EU green-claims rules

Yes, but only within the label's certified scope. The Commission Green Claims proposal treats environmental labels as explicit environmental claims and defines an environmental labelling scheme as a certification scheme that certifies a product, process, or trader against the requirements for an environmental label. A valid award does not substantiate broader wording about impacts or activities outside the scheme criteria.

Before using a label in packaging, advertising, procurement material, or a product page, teams should check the scheme behind it. The useful evidence is not the badge artwork; it is the scheme file showing ownership, objectives, criteria, monitoring, complaint handling, non-compliance procedures, and verification.

The review should start with public transparency, because both the Green Claims proposal and Directive (EU) 2024/825 focus on whether consumers can trust the label's governance. A scheme should not be accepted if its rules, owner, decision-makers, criteria, monitoring, or non-compliance process cannot be found or understood.

For private schemes, the review should also test whether the scheme is open on fair and non-discriminatory terms, whether the requirements were developed with relevant experts and stakeholders, and whether compliance monitoring is objective and independent.

Third-party verification is central where the label is not established by a public authority. Directive (EU) 2024/825 defines a certification scheme as a third-party verification scheme with publicly available terms and objective compliance monitoring by an independent, competent third party. National measures apply these new rules from 27 September 2026.

The Green Claims proposal adds a separate verification layer for explicit environmental claims and environmental labelling schemes. The Council general approach keeps that structure but makes the scheme owner the party that submits the scheme and corresponding label for verification; traders awarded a compliant label may display that label without repeating the scheme-level verification.

The EU Ecolabel is different from a private sustainability badge. It is the official EU voluntary label for environmental excellence, and Commission materials describe it as promoting goods and services with reduced environmental impact across the life cycle.

Teams can use EU Ecolabel evidence when the public claim stays inside the certified product group and criteria. They should still preserve the product group criteria, licence or catalogue record, and claim wording, because a label for one criterion or product group does not automatically support a broad claim such as sustainable, responsible, or green for the whole business.

The Green Claims proposal is designed to slow proliferation of environmental labels, not to invite new badges for every product line. The Commission proposal would have stopped new national or regional public schemes after transposition while allowing new schemes under Union law; it would also have required new private schemes to be approved only where they add environmental value compared with existing schemes.

The Council general approach changes the detail: new national or regional public schemes and public schemes from third countries would be subject to Commission approval before entering the Union market, while new private schemes would need Member State approval and added value. Existing schemes may continue only if they meet the directive's requirements. Because the proposal is not final, teams should avoid publishing fixed approval deadlines or final-law statements unless they are citing the adopted text when it exists.

Directive (EU) 2024/825 amends the UCPD framework for consumer-facing marketing. From 27 September 2026, national measures must prohibit displaying a sustainability label that is not based on a certification scheme or established by public authorities. They also prohibit generic environmental claims unless the trader demonstrates recognised excellent environmental performance relevant to the claim. Existing UCPD misleading-practice rules continue to apply before that date.

The Green Claims proposal is more specific for explicit environmental claims and environmental labels: it adds substantiation, communication, scheme governance, and verification requirements. Passing a Green Claims verification check would not automatically make a marketing practice fair under the UCPD, and the Council text expressly preserves national authority and court assessment under Directive 2005/29/EC where applicable.

For products or packaging created before 27 September 2026, do not assume a blanket old-stock exemption. The CPC authorities' June 2026 common understanding expects timely, good-faith compliance work and says authorities may phase enforcement where genuine and specific transitional difficulties arise. The treatment remains fact- and authority-specific.