EU Green Claims Directive Product vs company claims
A focused FAQ for separating environmental claims about a product or service from claims about the trader, company, organisation, or its activities.
Use it to match the public wording to the product, service, or trader activity that the evidence actually covers, while keeping adopted consumer-law rules separate from the unadopted Green Claims proposal.
Classify the claim by what it describes: the whole product or service, part of it, a specific environmental characteristic, the 's entire business, or one business activity. The evidence and public explanation should use that same boundary. The already prohibits misleading practices. From 27 September 2026, Directive (EU) 2024/825 adds a specific prohibition on presenting an entire product or business as environmentally better when the basis concerns only one product aspect or business activity. The separate Green Claims Directive remains an unadopted proposal.
Side-by-side comparison
Product vs company environmental claims
Compare claim boundaries under the adopted amendments and the substantiation approach in the unadopted Green Claims proposal.
Keep the evidence for a claim about a product, service, product group, component, life-cycle stage, or product environmental characteristic within that product or service boundary.
Second framework
Company or trader claim
Keep the evidence for a claim about the , organisation, business activity, site, value chain, or future company performance within that trader-activity boundary.
Product or service claim: specify whether the wording covers the whole product, part of a product, a service, a product group, or selected environmental characteristics such as recycled content, durability, emissions, packaging, or use-phase performance.
Company or claim: specify whether the wording covers all trader activities or only a business unit, site, activity, value-chain segment, target, label scheme, or environmental characteristic of the trader.
Product or service claim: the generating the , often the producer but sometimes another trader that first introduces a B2C claim, should possess substantiation for the product wording.
Company or claim: the trader generating the organisation-level or activity-level claim should possess the substantiation for the claimed trader activity; environmental label scheme owners substantiate label criteria.
The Council negotiating text distinguishes a retailer that exactly repeats a claim already communicated to consumers from a that first introduces, changes, or repurposes a claim in B2C communication. Use that proposal-stage distinction when assigning the claim file; existing duties remain separate.
Product or service claim: review before packaging, web, advertising, product-page, label, marketplace, or point-of-sale wording states or implies an environmental benefit for that product or service.
Company or claim: review before corporate, brand, sustainability, site, service-provider, value-chain, or future-performance wording states or implies an environmental benefit for the trader or its activities.
The Green Claims proposal addresses voluntary written or oral environmental claims in B2C communication. Images and colours that imply an environmental benefit fall outside that proposed definition of an explicit claim but remain subject to the .
Product or service claim: the Council text would require recognised scientific evidence, accurate information, relevant methods or international standards, and a life-cycle view of significant product impacts and aspects.
Company or claim: the Council text would apply the same approach to the trader activity and the significant environmental aspects or impacts covered by the claim.
Do not use a narrow product study to prove a broad company claim, or a corporate programme to prove every product claim, unless the evidence covers the same object and significant impacts.
Product or service claim: keep product-specific primary information where available, representative secondary information where primary data is unavailable, assumptions, methods, calculations, value-chain scope, and limitations.
Company or claim: keep trader-activity data, site or value-chain scope, emissions or resource data where relevant, target assumptions, carbon credit details for climate claims, methods, calculations, and limitations.
Evidence should be readable against the consumer wording: source, claim object, environmental characteristics, data type, method, significant impacts, trade-offs, reviewer, and version.
Product or service claim: the Council text would require clear, comprehensible communication and use-phase instructions when consumer use is among the most relevant life-cycle stages for achieving the stated performance.
Company or claim: the Council text would require communication of the trader or activity boundary, the environmental characteristics covered, and any carbon-credit or future-performance basis without implying broader coverage.
The summary given with the claim should match the substantiation boundary and should not hide trade-offs, exclusions, or limits behind generic green wording.
Product or service claim: the Council text would limit comparisons to products with a similar purpose, use, or functional properties, using equivalent data, the same assessment method, and equivalent value-chain coverage.
Company or claim: the Council text would compare traders in the same sector using equivalent data, methods, environmental-characteristic coverage, assumptions, and baselines.
A product comparison cannot become a company superiority claim, and a company comparison cannot imply product superiority, unless the comparison evidence separately supports that message.
Product or service claim: product data can support company reporting only for the matching product, activity, or value-chain segment, and only with the same limitations and assumptions.
Company or claim: company data can support product wording only when it is specific enough to the product or service and covers the relevant product impacts and life-cycle stages.
Product or service claim: apply current law and the Directive (EU) 2024/825 amendments from 27 September 2026. Treat Green Claims product provisions only as proposal-stage planning material.
Do not assign final Green Claims deadlines. Check the official procedure record and any later adopted text before turning proposal provisions into a legal launch gate.
Product or service claim: specify whether the wording covers the whole product, part of a product, a service, a product group, or selected environmental characteristics such as recycled content, durability, emissions, packaging, or use-phase performance.
Company or claim: specify whether the wording covers all trader activities or only a business unit, site, activity, value-chain segment, target, label scheme, or environmental characteristic of the trader.
Product or service claim: the generating the , often the producer but sometimes another trader that first introduces a B2C claim, should possess substantiation for the product wording.
Company or claim: the trader generating the organisation-level or activity-level claim should possess the substantiation for the claimed trader activity; environmental label scheme owners substantiate label criteria.
The Council negotiating text distinguishes a retailer that exactly repeats a claim already communicated to consumers from a that first introduces, changes, or repurposes a claim in B2C communication. Use that proposal-stage distinction when assigning the claim file; existing duties remain separate.
Product or service claim: review before packaging, web, advertising, product-page, label, marketplace, or point-of-sale wording states or implies an environmental benefit for that product or service.
Company or claim: review before corporate, brand, sustainability, site, service-provider, value-chain, or future-performance wording states or implies an environmental benefit for the trader or its activities.
The Green Claims proposal addresses voluntary written or oral environmental claims in B2C communication. Images and colours that imply an environmental benefit fall outside that proposed definition of an explicit claim but remain subject to the .
Product or service claim: the Council text would require recognised scientific evidence, accurate information, relevant methods or international standards, and a life-cycle view of significant product impacts and aspects.
Company or claim: the Council text would apply the same approach to the trader activity and the significant environmental aspects or impacts covered by the claim.
Do not use a narrow product study to prove a broad company claim, or a corporate programme to prove every product claim, unless the evidence covers the same object and significant impacts.
Product or service claim: keep product-specific primary information where available, representative secondary information where primary data is unavailable, assumptions, methods, calculations, value-chain scope, and limitations.
Company or claim: keep trader-activity data, site or value-chain scope, emissions or resource data where relevant, target assumptions, carbon credit details for climate claims, methods, calculations, and limitations.
Evidence should be readable against the consumer wording: source, claim object, environmental characteristics, data type, method, significant impacts, trade-offs, reviewer, and version.
Product or service claim: the Council text would require clear, comprehensible communication and use-phase instructions when consumer use is among the most relevant life-cycle stages for achieving the stated performance.
Company or claim: the Council text would require communication of the trader or activity boundary, the environmental characteristics covered, and any carbon-credit or future-performance basis without implying broader coverage.
The summary given with the claim should match the substantiation boundary and should not hide trade-offs, exclusions, or limits behind generic green wording.
Product or service claim: the Council text would limit comparisons to products with a similar purpose, use, or functional properties, using equivalent data, the same assessment method, and equivalent value-chain coverage.
Company or claim: the Council text would compare traders in the same sector using equivalent data, methods, environmental-characteristic coverage, assumptions, and baselines.
A product comparison cannot become a company superiority claim, and a company comparison cannot imply product superiority, unless the comparison evidence separately supports that message.
Product or service claim: product data can support company reporting only for the matching product, activity, or value-chain segment, and only with the same limitations and assumptions.
Company or claim: company data can support product wording only when it is specific enough to the product or service and covers the relevant product impacts and life-cycle stages.
Product or service claim: apply current law and the Directive (EU) 2024/825 amendments from 27 September 2026. Treat Green Claims product provisions only as proposal-stage planning material.
Do not assign final Green Claims deadlines. Check the official procedure record and any later adopted text before turning proposal provisions into a legal launch gate.
How should teams decide between product and company claims?
Start with the claim object: product, service, product part, product characteristic, , trader activity, or future company performance.
Use the product evidence file only for the matching product or service boundary, and use the company evidence file only for the matching -activity boundary.
Split mixed wording into separate claims when the same substantiation does not cover both objects, all significant impacts, trade-offs, and consumer-facing explanations.
How should teams separate product claims from company claims?
Separate the claim by its object. A product or service claim says something about the environmental impact, aspect, characteristic, or performance of a product, a product group, a service, a component, packaging, production method, use phase, or end-of-life stage. A company claim says something about the itself, the organisation, a business activity, a site, operations, a value chain, or future company performance.
For the proposal-stage scope test, an is the written or oral environmental statement presented to consumers about the product or . Record that exact statement before deciding which evidence boundary applies.
Do not let one evidence file silently cover both. Under the Council's June 2024 negotiating position, the proposed substantiation assessment would specify whether the claim relates to the whole product, part of a product, certain aspects of a product, all activities of a , or only part of those activities. If the public wording crosses that boundary, narrow the wording or expand the evidence before publication.
Directive (EU) 2024/825 gives concrete boundary examples. "Made with recycled material" can mislead when only the packaging is recycled but the presentation covers the entire product. A can also mislead by implying that its whole business uses renewable energy when several facilities still use fossil fuels. A narrower, accurate statement about the packaging or a measured business-wide reduction can remain possible.
Product or service boundary: identify the exact product, service, component, product group, life-cycle stage, or environmental characteristic covered by the claim.
Company boundary: identify whether the claim covers the whole , one business line, one site, one activity, one value-chain segment, or a future company target.
Mixed wording: split statements such as "our products are sustainable because our company is carbon neutral" into separate product and claims, each with its own substantiation and communication summary.
Legal-status limit: the Green Claims Directive was still an unadopted proposal in the official procedure records checked on 25 July 2026. Do not present its substantiation, verification, or timing provisions as final law.
Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers.
Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life.
Question 2
What substantiation changes when the claim is about a product or service?
For a product or service claim, evidence must fit the product boundary being advertised. The Council general approach would require recognised scientific evidence, accurate information, and relevant methods or international standards, with the claimed environmental characteristics shown to be relevant and significant from a life-cycle perspective.
A narrow favourable attribute does not support wording that implies broader product performance. Under the Council negotiating text, if consumer use is among the most relevant life-cycle stages, the claim would also include instructions on how to achieve the stated environmental performance. These are proposal-stage requirements, not current Green Claims law.
Keep primary information where available for the product characteristics being claimed, such as composition, recycled content, emissions, energy use, repairability, durability, or packaging data.
Use representative secondary information only where primary information is unavailable, and document why it fits the specific value chain of the product or service.
Check trade-offs: improvements in one impact category should not hide significant harm or a transfer of negative impacts to another life-cycle stage.
If a sector-specific EU rule already governs the environmental claim, use that rule first rather than treating the Green Claims proposal as the only source.
Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers.
Question 3
What substantiation changes when the claim is about the company?
For a company or claim, the evidence scope follows the activity presented to consumers. A claim about the whole organisation needs evidence for that broader boundary. A claim about one division, site, fleet, store format, procurement programme, or future target should name that narrower boundary.
The Council negotiating text covers explicit environmental claims about traders as well as products. Under that text, a product footprint or label would not by itself substantiate a broad organisation claim unless the evidence also covered the activity and environmental characteristics communicated. Independently, the adopted Directive (EU) 2024/825 adds a prohibition, applicable from 27 September 2026, on whole-business wording based on one specific business activity.
Map the activity covered by the claim, including sites, operations, suppliers, services, value-chain stages, and time period.
For climate-related claims, keep emissions reductions and any carbon credits or offset/contribution elements separate in the substantiation summary.
Avoid turning legal minimum compliance or common sector practice into a distinctive company environmental benefit.
From 27 September 2026, amended Article 6(2) treats a future environmental performance claim as potentially misleading if it lacks clear, objective, publicly available, verifiable commitments in a detailed and realistic implementation plan with measurable, time-bound targets, allocated resources, and regular independent third-party verification whose findings are available to consumers.
Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
Directive (EU) 2024/825 complements the Green Claims proposal by prohibiting certain misleading environmental marketing practices, including unsupported generic environmental claims.
Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life.
Question 4
What is the practical rule before publishing either type of claim?
Publish only wording that the evidence supports. Identify the product, service, , or activity covered and avoid implying a broader environmental benefit. Under the Council general approach, a covered explicit claim would also need a clear consumer-facing summary of its substantiation, but that Green Claims requirement remains proposal-stage.
Boundary drift occurs when product evidence implies a company-wide benefit, or company-level initiatives imply that every product or service is environmentally better. Treat those as separate claims unless the same evidence covers both objects, all significant impacts, and the same comparison baseline.
Before approval, ask: is this about a product, a service, a product part, the , or a specific trader activity?
Then ask: does the evidence cover the same boundary, life-cycle stages, significant impacts, trade-offs, baseline, and time period as the wording?
For comparisons, compare like with like: product group to product group, sector to trader sector, equivalent data, equivalent method, and equivalent value-chain coverage.
Separate dates by instrument: the Directive (EU) 2024/825 amendments apply from 27 September 2026, while the Green Claims proposal has no final transposition or application deadline.
Approval outcome: approve the exact boundary supported; qualify the statement if only one aspect or activity is evidenced; split mixed product and wording; or stop publication until the missing product, organisation, comparison, or trade-off evidence exists.
Reassess when the product composition, packaging, supplier, site mix, energy source, business structure, acquisition, divestment, reporting period, comparison baseline, market, channel, or claim wording changes.
Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers.
Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life.
Directive (EU) 2024/825 complements the Green Claims proposal by prohibiting certain misleading environmental marketing practices, including unsupported generic environmental claims.
Recommended next step
Keep claim wording within the evidence boundary
Separate product, service, and trader claims before approving public environmental wording or evidence summaries.
Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers.
Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
"whole product, part of a product or certain aspects of a product, or to all activities of a trader"
Directive (EU) 2024/825 complements the Green Claims proposal by prohibiting certain misleading environmental marketing practices, including unsupported generic environmental claims.
Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life.
"environmental impact, aspect, or performance of a product or the trader itself"