Green Claims labels and certification schemes under EU consumer rules

Start by deciding whether the badge, seal, score, logo, certification mark, or marketplace icon is a sustainability label, an environmental label, or a separate explicit environmental claim. Directive (EU) 2024/825 defines environmental claims broadly enough to include labels, brand names, company names, product names, pictorial claims, graphic claims, and symbolic representations in commercial communication.

If the label suggests that a product, process, business, or trader has environmental or social characteristics, treat it as a regulated consumer-facing signal. The review should cover the label artwork, nearby text, product scope, proof behind the scheme, and the consumer explanation shown on the same package or digital surface.

A certification-scheme review should prove that the scheme is more than a marketing program. Directive (EU) 2024/825 describes a certification scheme as third-party verification against certain requirements, with publicly available terms. The terms need transparent, fair, and non-discriminatory access; expert and stakeholder input into requirements; non-compliance procedures; and objective third-party monitoring.

The Green Claims proposal is more specific for environmental labelling schemes. It expects transparent ownership and decision-making bodies, free and understandable information on objectives and monitoring procedures, SME-proportionate access conditions, scientific robustness, stakeholder consultation, complaint and dispute handling, and withdrawal or suspension for persistent and flagrant non-compliance.

The Green Claims proposal does not erase existing EU label regimes. It applies to voluntary explicit environmental claims and environmental labelling schemes that are not already regulated by more specific Union rules on substantiation, communication, or verification. The Commission Q&A identifies the EU Ecolabel, energy efficiency label, and organic farming label as examples where specific EU rules prevail.

The EU Ecolabel should be described as the official EU voluntary label for environmental excellence, not as a generic green badge. The Commission explains that it uses strict product-group criteria on a scientific basis, a transparent multi-stakeholder process, and independent third-party certification. If a page, pack, or listing uses the EU Ecolabel, the consumer explanation should point to the certified product group and criteria rather than adding broader unsupported claims.

The Green Claims proposal is designed to stop label proliferation as well as unsupported claim wording. New public schemes at Member State level are constrained; new schemes established under Union law are the preferred path. New private environmental labelling schemes are expected to be approved only where they add environmental ambition, relevant impact coverage, product-group or sector coverage, or SME-support value compared with existing schemes.

Aggregate scores need special review because they can hide important negative impacts behind a single grade, star rating, or composite badge. The Council text flags methodology differences and weighting choices as reasons that labels can mislead consumers. Teams should not create or display an overall environmental score unless the methodology, covered impacts, weighting, exclusions, and consumer explanation are grounded and clear.

A compliant scheme file does not fix unclear consumer wording. The visible claim should tell consumers what the label means, which product or trader it applies to, which environmental characteristic is certified, and where to find the criteria or substantiation. The 2016 Commission compliance criteria warn that wording, imagery, layout, colors, symbols, and labels can mislead if they overstate the environmental benefit or omit material information.

Directive (EU) 2024/825 also tightens generic environmental claims. A broad word such as green, eco-friendly, biodegradable, sustainable, or responsible is higher risk when the label only certifies one narrow attribute. The safer consumer explanation ties the label to the certified characteristic and avoids whole-product or whole-business implications unless recognised excellent environmental performance supports the entire claim.