UCPD and Directive (EU) 2024/825 overlap How the Green Claims proposal adds detail

Directive (EU) 2024/825 adds environmental-claim concepts and specific greenwashing practices to the UCPD framework. It defines an environmental claim broadly as a non-mandatory commercial message or representation that states or implies a positive, zero, lower, or improving environmental impact for a product, product category, brand, or trader.

For day-to-day claim review, the most important change is that several practices move from broad case-by-case risk into named UCPD controls. A generic environmental claim is prohibited when the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. A sustainability label is prohibited if it is not based on a certification scheme or established by a public authority. A future environmental performance claim is treated as misleading unless it is supported by clear, objective, publicly available, verifiable commitments in a detailed and realistic implementation plan, with measurable and time-bound targets and independent third-party verification.

The Green Claims proposal is the more specific layer for voluntary explicit environmental claims and environmental labelling schemes. The Commission proposal describes it as complementing the UCPD changes by adding rules on substantiation, communication, and verification. The Council general approach likewise frames the Green Claims text as complementing Directive (EU) 2024/825 and applying detailed rules to explicit environmental claims and environmental labels.

The practical distinction is: the UCPD, as amended by Directive (EU) 2024/825, identifies unfair or misleading practices, including blacklist-style prohibitions. The Green Claims proposal would require a trader that generates a covered explicit environmental claim to support it with an assessment, communicate specified information, and have the substantiation and communication checked before the claim or label is put on the market, subject to the proposal's scope and exceptions.

Check both layers when a voluntary business-to-consumer message is explicit and environmental. Examples include packaging recycled-content claims, bee-friendly or nature-positive claims, carbon compensated ride claims, claims to reduce CO2 by a future date, product-level climate neutrality claims, and labels or trust marks that imply environmental superiority.

Start with the UCPD as amended by Directive (EU) 2024/825: is the claim generic, future-looking, whole-product or whole-business when the evidence is narrower, offset-based, or tied to a sustainability label? Then check the Green Claims proposal lens: if the claim is in scope and not already governed by more specific Union rules, what substantiation, communication, labelling-scheme, and verification evidence would be needed before publication?

Do not wait for the Green Claims file to be final before cleaning up claims that Directive (EU) 2024/825 already targets. Generic environmental language, weak labels, offset-based product climate neutrality claims, and unsupported future-performance claims already have a clearer UCPD risk profile under the adopted directive.

For Green Claims-specific controls, avoid presenting proposal details as settled final law. Use them as a design baseline for evidence quality: claim files should identify the exact claim, the environmental characteristic or impact, the product or trader boundary, the data and method used, relevant trade-offs, the communication text, and whether a verifier or certification-scheme check would be needed under the proposal/general-approach text.