EU Green Claims Greenwashing Risk Checklist

Flag broad phrases such as green, eco-friendly, sustainable, climate friendly, carbon neutral, natural, zero emissions, or similar wording unless the same medium gives a clear and prominent specification of the benefit. The safer replacement is a narrow claim that names the product part, process, lifecycle stage, metric, and evidence basis.

A generic environmental claim should not pass review merely because a product has one positive feature. Directive (EU) 2024/825 links generic claims to recognised excellent environmental performance relevant to the claim, and the Commission criteria warn that broad claims can imply no negative impact or only positive impact.

Do not publish an environmental claim and then look for evidence. The review owner should be able to point to clear, independent, verifiable, and generally recognised evidence before the claim goes live.

For claims about a product, the evidence file should identify the product variant, geography, lifecycle stages considered, primary company-specific data used, secondary data used, calculation method, assumptions, exclusions, and who can explain the evidence to a competent authority or customer.

A claim can be technically true and still misleading if it highlights one improvement while hiding a worse trade-off elsewhere. Review whether the claim covers the lifecycle stages and environmental aspects that matter for the product category, or whether it needs a narrower boundary statement.

This gate is especially important for recycled content, biobased materials, refill models, reduced energy or water claims, transport claims, packaging claims, and any claim that compares two product versions.

Future-performance claims need a different review path from achieved-performance claims. A slogan such as net zero by a given year, climate positive, fully circular, plastic free soon, or zero waste target should not be presented as a current product benefit.

Directive (EU) 2024/825 treats future environmental-performance claims as risky unless they are backed by clear, objective, publicly available, and verifiable commitments in a detailed and realistic implementation plan with measurable and time-bound targets, resources, and independent third-party verification.

From 27 September 2026, stop product claims such as climate neutral, carbon neutral, CO2 neutral certified, climate net zero, climate compensated, or reduced climate impact when they are based on offsetting greenhouse gas emissions outside the product value chain. Before that date, assess the same wording under the current UCPD and national law rather than assuming it is safe.

For entity-level climate claims that involve carbon credits, separate gross emissions reductions from credits or financial contributions. The evidence should identify the credit share, reduction or removal type, verification scheme, registry, accounting approach, and risk controls for double counting, permanence, additionality, and baseline quality.

Labels, trust marks, quality marks, badges, and private schemes should not pass review unless their meaning is clear to consumers and their rules are public, objective, monitored, and enforceable. The same gate applies to claims that imply public authority approval or certification.

Comparative claims need like-for-like evidence. A claim such as lower impact than, greener than, 30 percent less carbon, best in class, or better than conventional should identify the comparator, function, market, method, assumptions, and lifecycle stages used for both sides.

Approval applies to the reviewed wording, evidence version, product boundary, market, language, medium, and date. It does not automatically cover a shorter headline, translation, marketplace field, influencer script, new product variant, or redesigned label. The publication owner should be able to find and remove every live use.

Reopen the risk decision when any fact that supports the claim changes. The Green Claims proposal texts use changed accuracy as a review trigger, while the Commission environmental-claims criteria call for regular review and evidence that remains relevant while the claim is used. A scheduled review does not replace an earlier event-driven review.