What the EU Green Claims Directive actually involves

The EU Green Claims Directive (proposed in March 2023, expected to apply from late 2026) requires that explicit environmental claims made by companies about their products and services are substantiated by scientific evidence, verified by an accredited third party before use, and communicated in a standardised format. It covers claims on product packaging, in advertising, and on websites, including terms like eco-friendly, carbon neutral, natural, sustainable, and biodegradable. Claims based on offsetting, carbon neutrality assertions without substantial reductions, or generic sustainability terminology without specific substantiation are particularly targeted.

Why it's harder in practice than it looks

The range of claims covered is broader than most marketing teams realise

The directive covers not just explicit numerical claims (30 percent lower carbon) but also symbolic representations (green leaf icons, nature imagery used to imply sustainability) and comparative claims (greener than, lower impact than). Many companies are making claims across all these categories without the scientific substantiation the directive requires.

Third-party pre-verification is a new and resource-intensive requirement

Unlike current UK and EU advertising guidance, which allows ex-post challenge of misleading claims, the Green Claims Directive requires verification before a claim is made. This means companies need to build verification processes into their product development and marketing approval workflows, a structural change rather than a one-time audit.

Carbon neutrality claims face specific and high evidential bars

Claims of carbon neutrality for products or companies are specifically targeted by the directive's provisions against claims based primarily on offsetting. A credible claim of this type requires verified emissions data across the product's full life cycle, minimum substantial reduction before offsetting is used, and use of only high-quality, permanent removal credits for any residual offsetting.

Supply chain claims require supplier evidence chains

Claims about sustainable sourcing, ethical supply chains, or certified inputs require documented evidence from suppliers. Companies that have been making these claims based on internal policy rather than verified supplier data face significant rework before they can substantiate them under the directive.

What good looks like

A Green Claims Directive-ready company has conducted a full audit of all explicit and implicit environmental claims across its product range and communications channels, assessed each claim against the directive's substantiation requirements, removed or paused claims that cannot be substantiated, and built a verification workflow into its product development and marketing approval process. Claims that remain are specific, evidence-based, and consistent with the product's verified environmental performance.

When to bring in external support

Green claims compliance requires a combination of environmental performance expertise (to assess claim substantiation), legal knowledge (to interpret regulatory requirements and assess liability), and marketing process understanding (to redesign approval workflows). Leafr's network includes green claims compliance specialists who have audited product portfolios and supported claim substantiation programmes for consumer goods, fashion, food and retail clients ahead of the directive's enforcement date.

Frequently asked questions

What is the EU Green Claims Directive?

The EU Green Claims Directive is proposed EU legislation requiring that explicit environmental claims about products and services be scientifically substantiated, independently verified before use, and communicated in a standardised format. It is part of the EU's broader Green Deal package designed to eliminate greenwashing and enable consumers to make genuinely informed purchasing decisions. Enforcement is expected from late 2026 for EU markets.

What types of claims are covered by the directive?

The directive covers explicit environmental claims, any statement, symbol, or label suggesting that a product has a positive, neutral, or reduced environmental impact. This includes carbon neutral, biodegradable, eco-friendly, sustainably sourced, made from recycled materials, and comparative claims such as lower carbon footprint than our previous product. It does not cover claims regulated by existing sector-specific EU law, such as organic food labelling.

Does the directive apply to UK companies?

The directive directly applies to companies making green claims in EU markets. UK companies selling products or services into the EU will need to comply for those markets. The UK's own Green Claims Code, operated by the Competition and Markets Authority, has similar substantiation requirements and has already resulted in enforcement action. UK companies trading in both markets should design claims to meet the higher of the two standards.

What is required to substantiate a carbon neutral claim?

To make a credible carbon neutral claim for a product under the directive, a company needs: a full Life Cycle Assessment covering all relevant emissions from cradle to grave, substantial verified emissions reduction before any offsetting is used, use of only high-quality permanent removal credits for residual emissions, independent verification by an accredited body, and clear communication about what is and is not included in the claim. Claims of carbon neutrality based primarily on purchased offsets without substantial prior reduction are specifically targeted by the directive.

What are the penalties for non-compliance with the Green Claims Directive?

The directive requires member states to impose effective, proportionate and dissuasive penalties. The European Commission has indicated that penalties should include fines of up to four percent of annual turnover in the member states where the infringement occurred, confiscation of revenues from the relevant transaction, and temporary exclusion from public procurement. Enforcement responsibility sits with national competent authorities in each EU member state.