---
title: "Environmental labels and certification schemes under EU Green Claims rules"
canonical_url: "https://www.sorena.io/artifacts/eu/green-claims-directive/faq/labels-and-certification-schemes"
source_url: "https://www.sorena.io/artifacts/eu/green-claims-directive/faq/labels-and-certification-schemes"
author: "Sorena AI"
description: "FAQ on environmental labels, certification schemes, EU Ecolabel, third-party verification, and Directive (EU) 2024/825 overlap for green claims."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "EU Green Claims"
  - "environmental labels"
  - "certification schemes"
  - "EU Ecolabel"
  - "sustainability labels"
  - "Directive (EU) 2024/825"
  - "UCPD"
  - "Green Claims"
---
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---

# Environmental labels and certification schemes under EU Green Claims rules

FAQ on environmental labels, certification schemes, EU Ecolabel, third-party verification, and Directive (EU) 2024/825 overlap for green claims.

*FAQ* *Green Claims* *EU*

## Environmental Labels and certification schemes under EU green-claims rules

Environmental labels should be treated as claims with their own scheme governance, evidence, monitoring, and verification file.

Use this FAQ to separate EU Ecolabel and other public labels from private schemes, self-certification, and unsupported sustainability badges.

Environmental labels are not a shortcut around green-claims substantiation. Under the Green Claims proposal, an environmental label is an explicit environmental claim, while Directive (EU) 2024/825 already targets sustainability labels that are not based on a certification scheme or established by public authorities.

## Can teams use an environmental label as evidence for a green claim?

Yes, but only if the label itself is credible for the claim being made. The 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.

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.

- Map the label to the exact product, process, trader, and environmental characteristic that the public claim mentions.
- Confirm that the label is based on a certification scheme or was established by a public authority.
- Check that scheme ownership, decision-making bodies, objectives, requirements, and monitoring procedures are public and understandable.
- Keep the award decision, scope of certification, criteria version, monitoring records, and any withdrawal or suspension conditions with the claim file.

Sources for this answer:

- [Green Claims Directive proposal, COM(2023) 166 final](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Defines environmental labels as explicit environmental claims and sets proposed requirements for environmental labelling schemes in Articles 7 and 8.
- [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Shows the Council text requiring environmental labels to be based on environmental labelling schemes and scheme owners to submit schemes for verification, with limited public-scheme derogations.

## What transparency checks belong in a certification-scheme review?

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.

- Ownership and decision-making: identify the scheme owner, decision body, conflicts process, and funding model where available.
- Criteria and methodology: store the criteria version, product group or trader scope, scientific basis, stakeholder consultation record, and update history.
- Access terms: check whether SMEs and other applicants can join on proportionate, transparent, and non-discriminatory terms.
- Monitoring and enforcement: retain audit, surveillance, complaint, dispute, withdrawal, and suspension procedures.
- Verification: document the third-party body or public-body process used to assess compliance, including competence and independence.

Sources for this answer:

- [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Adds UCPD rules for sustainability labels, including public availability of certification-scheme terms and third-party monitoring of compliance.
- [Green Claims Directive proposal, COM(2023) 166 final](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Requires environmental labelling schemes to publish ownership, decision-making, objectives, monitoring procedures, SME-proportionate joining conditions, expert and stakeholder input, complaints, and non-compliance procedures.

## Does third-party verification apply to labels?

Third-party verification is central where the label is not simply a public-authority label. Directive (EU) 2024/825 defines a certification scheme as a third-party verification scheme and requires objective monitoring by a third party whose competence and independence are based on international, Union, or national standards and procedures.

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.

- For the scheme owner: keep the verifier appointment, independence basis, verification scope, certificate of conformity, and any re-verification trigger.
- For the trader using the label: keep proof that the product, process, or trader was actually awarded the label and that use stays within the certified scope.
- For marketing teams: do not convert a narrow label award into a broader claim about the whole product, company, or future performance.
- For retailers and distributors: keep supplier documentation showing whether the displayed label is public-authority based or certification-scheme based.

Sources for this answer:

- [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Defines certification schemes as third-party verification schemes and prohibits displaying sustainability labels that are neither certification-scheme based nor established by public authorities.
- [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Requires environmental labelling scheme owners to submit schemes and labels for verification, with traders able to display an awarded compliant label without a separate trader verification procedure.

## How should teams treat the EU Ecolabel?

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.

- Confirm the product or service is covered by the relevant EU Ecolabel product group and criteria.
- Keep the EU Ecolabel licence or catalogue evidence with the exact product or service identifier.
- Use claim wording that matches the certified scope and does not imply unverified benefits outside the EU Ecolabel criteria.
- Refresh the evidence when criteria, licence status, product composition, supplier data, or claim wording changes.

Sources for this answer:

- [EU Ecolabel](https://environment.ec.europa.eu/topics/circular-economy/eu-ecolabel_en?ref=sorena.io) - Commission page identifying the EU Ecolabel as the official EU voluntary environmental-excellence label and linking to product groups, criteria, application routes, and the product catalogue.
- [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Recognises compliance with Regulation (EC) No 66/2010 on the EU Ecolabel as one route to recognised excellent environmental performance when relevant to the claim.

## Can new public or private environmental labelling schemes still be created?

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.

- Prefer existing Union-level schemes and officially recognised type I ecolabels before creating a new label.
- For a proposed private scheme, prepare evidence of added value, environmental ambition, coverage, criteria, methodology, market impact, ownership, and decision-making.
- For a proposed public scheme, check whether the latest legislative text requires Commission approval and publication on an allowed-label list.
- Flag any planned new label launch as legally pending until the final Green Claims Directive text and national implementation route are confirmed.

Sources for this answer:

- [Green Claims Directive proposal, COM(2023) 166 final](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Explains the original proposal's approach to limiting label proliferation and approving new private schemes only where they provide added value.
- [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Grounds the non-final Council position on approval of new public and private environmental labelling schemes and the Commission list of allowed labels.

## How does Directive (EU) 2024/825 overlap with the Green Claims proposal?

Directive (EU) 2024/825 already amends the UCPD framework for consumer-facing environmental marketing. It prohibits displaying a sustainability label that is not based on a certification scheme or established by public authorities, and it also targets generic environmental claims unless the trader can demonstrate recognised excellent environmental performance relevant to the claim.

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.

- Run the Directive (EU) 2024/825 screen first for sustainability-label basis, generic claims, whole-product overclaims, and future-performance claims.
- Run the Green Claims screen for explicit environmental claim substantiation, communication, environmental-label scheme governance, and verification.
- Do not rely on a certificate, label award, or verifier note to justify misleading claim wording outside the certified scope.
- Keep separate evidence for the label's certification basis and for each consumer-facing claim that uses the label.

Sources for this answer:

- [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Provides the adopted UCPD amendments on sustainability labels, generic environmental claims, and future environmental performance claims.
- [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - States that the Green Claims proposal complements Directive (EU) 2024/825 and that UCPD authorities and courts may still assess unfairness where applicable.

## Primary sources

- [Green Claims Directive proposal, COM(2023) 166 final](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Primary proposal text for explicit environmental claims, environmental labels, scheme governance, new-scheme approval, and verification.
  - Quote: "environmental labelling schemes"
- [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council position used for current non-final text on environmental labels, scheme-owner verification, new public and private schemes, and UCPD overlap.
  - Quote: "environmental claims and environmental labels"
- [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Adopted UCPD amendment used for sustainability-label certification, public-authority labels, generic environmental claims, and recognised excellent environmental performance.
  - Quote: "sustainability label"
- [EU Ecolabel](https://environment.ec.europa.eu/topics/circular-economy/eu-ecolabel_en?ref=sorena.io) - Commission source for EU Ecolabel status, product groups and criteria, application route, and catalogue evidence.
  - Quote: "official European Union voluntary label"

## Topic Guides

- [Carbon offsets and carbon-neutral claims: EU Green Claims Directive requirements](/artifacts/eu/green-claims-directive/offsets-and-carbon-neutral-claims.md): How to handle carbon-neutral, climate-neutral, compensated, and offset-backed claims under Directive (EU) 2024/825 and the Green Claims proposal.
- [Claims Evidence under the EU Green Claims Directive](/artifacts/eu/green-claims-directive/faq/claims-evidence.md): FAQ on the evidence expected before EU Green Claims are communicated, including scientific substantiation, life-cycle coverage, comparisons, and publication records.
- [Comparative Environmental Claims Under EU Green Claims Rules](/artifacts/eu/green-claims-directive/comparative-claims.md): How to substantiate EU comparative environmental claims using equivalent products, methods, data, value-chain coverage, significant impacts, and consumer-law comparison disclosures.
- [EU Green Claims Applicability Test](/artifacts/eu/green-claims-directive/applicability-test.md): Check whether the EU Green Claims Directive proposal could apply to an explicit environmental claim, environmental label, product claim, trader claim, or B2C communication.
- [EU Green Claims Checklist](/artifacts/eu/green-claims-directive/checklist.md): A concrete checklist for EU environmental claims covering claim inventory, substantiation, life-cycle impacts, comparisons, offsets, labels, verification, and UCPD overlap.
- [EU Green Claims claim categories and evidence map](/artifacts/eu/green-claims-directive/claim-categories.md): Classify EU environmental claims by category: explicit, comparative, product, trader, carbon, labels, generic wording, and evidence needs.
- [EU Green Claims claim categories FAQ](/artifacts/eu/green-claims-directive/faq/claim-categories.md): FAQ guidance on explicit, generic, comparative, product, company, label, and carbon claim categories under the EU Green Claims proposal.
- [EU Green Claims compliance controls for proposal-stage planning](/artifacts/eu/green-claims-directive/compliance.md): Proposal-stage Green Claims compliance controls for claim inventory, substantiation, communication, labels, comparative claims, offset claims, verification planning, and evidence records.
- [EU Green Claims Directive FAQ: scope, evidence, labels, offsets, and status](/artifacts/eu/green-claims-directive/faq.md): Direct answers on the EU Green Claims Directive proposal, explicit environmental claims, substantiation, labels, offsets, PEF/OEF evidence, UCPD overlap, and penalties.
- [EU Green Claims Directive Procedure Calendar](/artifacts/eu/green-claims-directive/deadlines-and-compliance-calendar.md): Track grounded EU Green Claims Directive proposal milestones: Commission proposal, Parliament first reading, Council general approach, and current procedure status.
- [EU Green Claims Directive proposal requirements](/artifacts/eu/green-claims-directive/requirements.md): source-linked summary of proposed EU Green Claims requirements for explicit environmental claims, substantiation, communication, verification, labels, comparisons, and Directive (EU) 2024/825 overlap.
- [EU Green Claims Directive Proposal Status and Legislative Tracker](/artifacts/eu/green-claims-directive/proposal-status-and-legislative-tracker.md): Track COM(2023) 166 and procedure 2023/0085(COD) through public EUR-Lex, OEIL, Parliament, and Council files without treating the proposal as adopted law.
- [EU Green Claims Directive proposal status FAQ](/artifacts/eu/green-claims-directive/faq/proposal-status.md): Current source-linked status of the EU Green Claims Directive proposal: Commission proposal, Parliament first reading, Council general approach, and procedure records.
- [EU Green Claims Directive Substantiation Template](/artifacts/eu/green-claims-directive/green-claims-substantiation-template.md): A field-by-field template for substantiating EU explicit environmental claims with claim scope, evidence, method, PEF/OEF, comparison, carbon-credit, verification, and publication records.
- [EU Green Claims Directive vs FTC Green Guides](/artifacts/eu/green-claims-directive/green-claims-directive-vs-ftc-green-guides.md): A source-limited comparison focused on the EU Green Claims proposal: scope, substantiation, verification, labels, offsets, and reusable evidence.
- [EU Green Claims penalties and enforcement FAQ](/artifacts/eu/green-claims-directive/faq/penalties.md): FAQ on EU Green Claims penalty risk, Council and proposal enforcement principles, UCPD overlap, and evidence that reduces greenwashing risk.
- [EU Green Claims Templates for Claim Evidence and Verification](/artifacts/eu/green-claims-directive/templates.md): Reusable templates for EU green-claim substantiation, verifier handoff, evidence inventory, sustainability labels, comparative claims, and Directive (EU) 2024/825 status checks.
- [EU Green Claims Verification and Audit Readiness](/artifacts/eu/green-claims-directive/verification-and-audit-readiness.md): Prepare explicit environmental claims for substantiation review, verifier handoff, source traceability, communication checks, and proposal-stage caveats.
- [EU Green Claims: Product vs Company Claims](/artifacts/eu/green-claims-directive/product-vs-company-claims.md): Compare product, service, and company environmental claims under the EU Green Claims proposal: scope, evidence, significant impacts, communication, and reuse limits.
- [FAQ: carbon offsets and carbon-neutral claims under EU Green Claims rules](/artifacts/eu/green-claims-directive/faq/offsets-and-carbon-neutral-claims.md): FAQ guidance on carbon neutral, climate neutral, offset, carbon credit, and future climate claims under the Green Claims proposal and Directive (EU) 2024/825.
- [FAQ: comparative environmental claims under EU Green Claims Directive](/artifacts/eu/green-claims-directive/faq/comparative-claims.md): FAQ guidance on EU comparative environmental claims: equivalent data, method boundaries, product comparisons, substantiation, presentation, and UCPD overlap.
- [FAQ: PEF and OEF evidence requirements for EU Green Claims](/artifacts/eu/green-claims-directive/faq/pef-and-oef-evidence.md): FAQ on when Product and Organisation Environmental Footprint methods help substantiate EU environmental claims, including scope, data quality, and method limits.
- [Green Claims Directive proposal status check workflow](/artifacts/eu/green-claims-directive/proposal-status-check-workflow.md): A source-linked workflow for checking the Green Claims Directive proposal status across OEIL, EUR-Lex, Council documents, and Parliament records.
- [Green Claims Directive vs Empowering Consumers Directive](/artifacts/eu/green-claims-directive/green-claims-directive-vs-empowering-consumers-directive.md): Compare the Green Claims proposal with Directive (EU) 2024/825: ex-ante substantiation and verification versus adopted UCPD amendments on generic claims, future performance, labels, and timing.
- [Green Claims Directive vs ISO 14021](/artifacts/eu/green-claims-directive/green-claims-directive-vs-iso-14021.md): Compare the proposed EU Green Claims Directive with ISO 14021 for voluntary environmental claims, substantiation, self-declared labels, evidence, and verification.
- [Green Claims Directive vs UK Green Claims Code](/artifacts/eu/green-claims-directive/green-claims-directive-vs-uk-green-claims-code.md): Compare the EU Green Claims Directive proposal with the UK Green Claims Code, covering substantiation, communication, labels, offsets, verification, enforcement, and evidence.
- [Green Claims evidence workflow for substantiation](/artifacts/eu/green-claims-directive/claim-substantiation-evidence-workflow.md): Build a Green Claims proposal evidence file for voluntary EU environmental claims: status check, scope, scientific evidence, life-cycle impacts, comparisons, carbon credits, verification, consumer communication, and review.
- [Green Claims labels and certification schemes](/artifacts/eu/green-claims-directive/labels-and-certification-schemes.md): How EU Green Claims rules and Directive (EU) 2024/825 treat environmental labels, certification schemes, EU Ecolabel use, new schemes, evidence records, and consumer-facing clarity.
- [Green Claims penalties and enforcement: proposal and Council approach](/artifacts/eu/green-claims-directive/penalties-and-enforcement.md): How the EU Green Claims proposal and Council general approach handle competent authorities, corrective measures, penalties, verifiers, and UCPD overlap.
- [Green Claims penalties and fines under the EU proposal](/artifacts/eu/green-claims-directive/penalties-and-fines.md): source-linked summary of proposed Green Claims enforcement, corrective measures, penalty criteria, and the Council approach to maximum-fine language.
- [Green Claims substantiation evidence pack](/artifacts/eu/green-claims-directive/substantiation-and-evidence-pack.md): Build a source-linked evidence pack for EU Green Claims: claim inventory, scientific substantiation, life-cycle impacts, PEF or OEF records, comparisons, labels, offsets, verification, and traceability.
- [Green Claims verifier workflow for explicit environmental claims](/artifacts/eu/green-claims-directive/verifier-workflow.md): A concrete verifier-preparation workflow for voluntary explicit environmental claims: claim boundaries, substantiation evidence, verifier package, certificate handling, and change reviews.
- [Greenwashing risk checklist for EU green claims](/artifacts/eu/green-claims-directive/greenwashing-risk-checklist.md): A concrete EU greenwashing checklist for marketing, product, legal, and sustainability teams reviewing vague claims, evidence gaps, offsets, labels, comparisons, and future targets.
- [How do the UCPD, Directive (EU) 2024/825, and Green Claims proposal overlap?](/artifacts/eu/green-claims-directive/faq/ucpd-and-empowering-consumers-overlap.md): FAQ on how Directive (EU) 2024/825 changes UCPD greenwashing rules and how the Green Claims proposal would add substantiation, communication, labels, and verification detail.
- [Microenterprise and Scope Exclusions in the EU Green Claims Proposal](/artifacts/eu/green-claims-directive/faq/microenterprise-and-scope-exclusions.md): FAQ on proposal-stage Green Claims scope: microenterprise treatment, voluntary B2C explicit environmental claims, B2B limits, and EU-rule exclusions.
- [PEF and OEF evidence for EU green claims](/artifacts/eu/green-claims-directive/pef-and-oef-evidence.md): How Product and Organisation Environmental Footprint studies can support EU green-claim substantiation without treating PEF or OEF as mandatory for every claim.
- [Product vs company claims under the EU Green Claims Directive](/artifacts/eu/green-claims-directive/faq/product-vs-company-claims.md): FAQ guidance on separating product, service, and company environmental claims under the EU Green Claims proposal, with substantiation and communication boundaries.
- [Verifier workflow under the EU Green Claims Directive](/artifacts/eu/green-claims-directive/faq/verifier-workflow.md): FAQ on the proposed EU Green Claims verifier workflow: substantiation, ex-ante verification, verifier requirements, certificates, and proposal-stage caveats.
- [What Counts as a Green Claim Under the EU Green Claims Proposal](/artifacts/eu/green-claims-directive/what-counts-as-a-green-claim.md): source-linked scope guide to explicit environmental claims under the EU Green Claims proposal and related Directive (EU) 2024/825 concepts.

*Recommended next step*

*Placement: after evidence section*

## Review environmental labels before publishing green claims

Check scheme governance, certified scope, third-party verification, EU Ecolabel evidence, and UCPD claim wording before a label appears in consumer-facing material.

- [Open Research Copilot](/solutions/research-copilot.md): Check label and certification-scheme questions against cited EU source material.
- [Discuss Green Claims implementation](/contact.md): Review label governance, certification evidence, and claim wording with Sorena.


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