Green Claims
The Green Claims Directive and Greenwashing
Substantiating environmental claims — the Green Claims Directive, the Empowering Consumers Directive and the DPP's role as evidence infrastructure.
The EU is advancing two parallel measures requiring environmental claims to be substantiated: the Empowering Consumers Directive (treating greenwashing as an unfair commercial practice) and the Green Claims Directive (verification and communication of claims). The conclusion is clear: unevidenced "eco-friendly" messaging now creates legal risk.
What is targeted
| Practice | Status |
|---|---|
| Generic claims such as "eco-friendly", unevidenced | Prohibited |
| Claims based on only one aspect of a product | Potentially misleading |
| Self-awarded sustainability labels | Restricted |
| Offset-based carbon neutral claims | Restricted |
| Presenting a legal requirement as an advantage | Misleading |
Building the evidence
- Choose a methodology: ISO 14067, PEF or a recognised programme. See PEF.
- Declare the scope: does the claim cover the whole product or one component?
- Raise the assurance level: third-party review or accredited verification. See ISO 14040/14044 vs 14067.
- Make the evidence reachable: a passport is the most practical way to link to it.
The DPP's role
A passport carries the supporting data in structured form: the carbon value and its methodology, the recycled content share and chain-of-custody model, certificate numbers and validity.
That closes the gap between marketing communication and evidence: the QR next to the claim leads to the proof. See proving recycled content and what consumers should see.
Common mistakes
- Describing mass balance as physical content. "This product contains recycled material" can be misleading.
- Hiding the system boundary. Presenting a cradle-to-gate number as a full life cycle.
- Communicating with stale data. A PCF changes when the energy mix changes.
- Boasting about a legal requirement — marketing the absence of an already-restricted substance, for example.
Frequently asked questions
Would it be safer to make no environmental claims at all?
No. Well-constructed, evidenced claims remain a strong differentiator. See brand differentiation with a DPP.
Does having a certificate make my claim safe?
A certificate is strong evidence but must match the scope of the claim. A GRS certificate does not mean the whole product is recycled.
Is publishing a passport itself a claim?
Presenting data in a passport is a declaration, not a claim. Claim rules apply once you turn that data into a marketing message.
