EU Green Claims Directive Proposal Requirements

The proposal targets voluntary explicit environmental claims and environmental labelling schemes used in business-to-consumer communication on the Union market. It is designed to sit alongside existing consumer law and product-specific EU rules, not replace every sectoral regime.

In practice, the requirement is not just to avoid false claims. A trader generating an explicit environmental claim would need to be able to show which environmental characteristics the claim covers, how those characteristics were assessed, what evidence supports them, and whether the claim has passed the proposed verification route before consumers see it.

The substantiation file should be claim-specific. The proposal and Council text point to widely recognised scientific evidence, sound methodologies, relevant international standards, life-cycle consideration where appropriate, and identification of significant environmental aspects and impacts.

The assessment should not omit relevant impacts or present a benefit that merely shifts harm to another life-cycle stage. For recycled content, pollution, biodiversity, climate, water, durability, or similar claims, the evidence should match the precise claim rather than a broad sustainability theme.

The proposed rules connect substantiation to communication. A claim should not be reduced to an approved marketing phrase with evidence hidden elsewhere; the consumer-facing material should make the covered environmental characteristics and substantiation summary available in a clear form.

The proposal also uses ex-ante verification as a central enforcement support. Under the Commission proposal and Council general approach, an accredited third-party verifier would check the substantiation and communication before the claim is generated or the label scheme is made available, with a certificate of conformity where the requirements are met.

Environmental labels are not treated as decoration. The proposal applies substantiation, communication, and verification concepts to labels and adds governance requirements for environmental labelling schemes, including transparent ownership, objectives, criteria, monitoring, complaint handling, and non-compliance procedures.

Comparative environmental claims need a tighter file because the risk is not only whether one product has evidence, but whether the compared products, traders, indicators, assumptions, life-cycle stages, and baseline year are genuinely comparable.

Directive (EU) 2024/825 is already adopted and amends the Unfair Commercial Practices Directive and Consumer Rights Directive. It is the consumer-transition law that bans or regulates several greenwashing practices directly through consumer law, while the Green Claims proposal would add more specific substantiation, communication, verification, and labelling rules for explicit claims.

The overlap matters for copy review. A claim can be a problem under Directive (EU) 2024/825 even before applying the Green Claims proposal's future verification structure, especially if it is generic, over-broad, based on offsets for product climate impact, or uses an unsupported sustainability label.

A defensible requirements file should be organized by claim, not by campaign. Each entry should connect the proposed legal requirement to the exact public wording, the evidence base, the communication channel, and the verification or review status.

Because the Green Claims Directive is not final, the file should also preserve institutional-version history: Commission proposal, Parliament position if used, Council general approach, and any later final text once available.