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🌍 EU Green Claims Directive Part 1 – A New Era of Truth in Sustainability Marketing

🌿 Is Your Brand Truly Green?🌿

The EU is cracking down on greenwashing with their draft proposal for a new EU Green Claims Directive — a bold move to ensure that environmental claims are scientifically substantiated, independently verified, and crystal clear. Whether you’re a business leader or a conscious consumer, this directive is set to reshape how sustainability is communicated across Europe.

🔍 “Let’s dive into what it means, who it affects, and how to prepare in our latest blog post.”

Article written by:

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In an age where consumers are increasingly eco-conscious, businesses have responded with a surge of green marketing. From “eco-friendly” packaging to “sustainably-sourced ingredients“, environmental claims are everywhere and not just within the cosmetic industry. Claiming to be “green” and “sustainable” has become a competitive factor, with green products registering greater growth than standard products. However, how many of these claims are actually true?

Herein lies the problem of “Greenwashing”…

⚠️ The Problem: Greenwashing

Greenwashing is a deceptive marketing practice where a company or organisation exaggerates or falsely claims to be environmentally friendly* in order to attract environmentally conscious consumers.

Note that an environmental claim is any voluntary message—text, image, symbol, label, or brand name—used in commercial communication that suggests a product or company:

Has a positive or neutral environmental impact
Is less harmful to the environment than other products
Has improved the products environmental performance over time

The increasing prevalence of “greenwashing” has been shown by studies undertaken:

A 2020 EU study found:
- 53% of environmental claims were vague, misleading, or unfounded
- 40% lacked verifiable evidence
A 2018 investigation conducted by the Consumer Protection Cooperation authorities showed 57.5% of sustainability claims lacked sufficient proof.

✅ The EU Response

Based on the issues with “greenwashing” and the increasing amount of environmental claims, the European Union (EU) has taken a bold step to tackle this with the EU Green Claims Directive (see below)—a legislative proposal designed to bring transparency, accountability, and scientific rigour to environmental marketing on the sustainability, durability and carbon footprint of consumer products in general on the EU market.

If you’re a business operating in the EU or a consumer who cares about sustainability, this directive is set to change the game.

🌍 EU Green Claims Directive: Draft Legislation Proposal

🎯 What are the Objectives?

Protect consumers from “greenwashing”
Support the green transition by enabling informed choices
Ensure legal clarity and a level playing field for businesses
Boost competitiveness of genuinely sustainable companies
Promote trust in sustainable products and services

🧾 Key Measures Introduced

Minimum requirements for substantiating and communicating environmental claims
Mandatory third-party verification before claims are marketed
Stricter rules for environmental labels to ensure transparency and credibility
Legal recognition of “certificates of conformity” across the EU

🏷️ Scope and Exemptions

Applies to all sectors not already regulated at the EU level
Micro-enterprises (fewer than 10 employees and turnover under €2M) are exempt from substantiation and communication requirements

💰 Cost and Impact

Higher compliance costs expected, especially for small businesses
Claims covering a product’s entire life cycle (e.g., Green House Gas emissions) require more investment than narrow claims (e.g., recycled packaging)

🏁 Complementary Legislation

Works alongside the Unfair Commercial Practices Directive (UCPD)
Supports existing EU tools like the EU Ecolabel (voluntary label for environmental excellence)

🧾 The EU Cosmetic Industry’s Response to the Draft EU Green Claims Directive

Cosmetics Europe, the cosmetic industry’s trade association, supports the directive’s goals including the ‘life-cycle perspective’ approach proposed by the European Commission (in that a detailed life-cycle analysis would not be required to substantiate all claims) but emphasises the need for:

Harmonised rules across the EU to avoid fragmented implementation
A clear definition of “widely recognised scientific evidence” including documentation needed for substantiation of environmental claims
Exact steps of the verification process
Alignment with internationally recognised standards such as ISO (international standards organisation)
Digital means to share information on claims substantiation whilst protecting confidential business information
Greater transition times with clear deadlines

📖 EU Green Claims Directive vs Current EU Cosmetic Claims Legislation

As many of you know, in the EU, there is already existing legislation for cosmetic claims in that they must be backed up by scientific evidence as per EU Cosmetics Legislation 1223/2009 in the Product Information File (PIF). Equally, there are the 6 common criteria as detailed in Commission Regulation (EU) No 655/2013 of legal compliance, truthfulness, evidential support, honesty, fairness, and informed decision-making.

As there is already some claims governance in place within the EU for cosmetic products, how does this new EU Green Claims Directive further affect cosmetic products?

It is clear that the EU Green Claims Directive is designed to act as a safety net for all those other sectors where claims are not already regulated at the EU level. However, it still has implications for cosmetics when:

Environmental claims go beyond product performance (e.g., “climate neutral brand” or “sustainable packaging”)
Claims are made in corporate marketing, and not just on product labels
Companies use eco-labels or carbon offsetting in their messaging

In these cases, the EU Green Claims Directive will complement existing cosmetics legislation by adding some extra criteria not yet present in EU claims governance:

Requiring third-party verification of environmental claims
Setting minimum standards for eco-labels
Ensuring transparency and comparability across all sectors
Requires transparency for carbon offsetting claims*

*NB – A carbon offsetting claim is a statement made by a company that it has compensated for its greenhouse gas (GHG) emissions by investing in environmental projects that reduce or remove an equivalent amount of carbon dioxide (CO₂) or other GHGs from the atmosphere.

👄 How does this Draft Legislation Impact Cosmetic Companies and Products?

🏢 Who Will Be Affected?

The directive applies to all businesses operating in the EU that make explicit environmental claims about their products or services. This includes:

Manufacturers
Retailers
Online platforms
Service providers

Small and medium-sized enterprises (SMEs) may receive some exemptions or simplified procedures, but they are not entirely excluded.

🗓️ Current Timelines

The EU Green Claims Directive was approved by the European Parliament in January 2024
Final adoption of the directive is expected in late 2025
Member States will have 24 months to transpose it into national law
Cosmetic businesses should prepare for enforcement starting as early as 2026
Businesses will likely have an additional 12 months to comply, meaning the directive could start applying as early as 2027.

✅ What Should Businesses Do Now?

Even though the Directive isn’t law yet, cosmetic businesses can start preparing by:

Auditing existing green claims for clarity, accuracy, and evidence. Check all current environmental claims on products, packaging and marketing materials.
Gather Scientific Evidence by collecting scientific data and studies to substantiate each environmental claim.
Investing in life cycle assessments and environmental data collection.
Training marketing and compliance teams on the new requirements of the EU Green Claims Directive and implement internal processes to ensure ongoing compliance.
Identify accredited third-party verifiers early on to understand the process and schedule verifications
Review and Approve Eco-labels used on products and ensure all eco-labels used are certified or approved by relevant authorities.
Monitor and Update Claims Regularly by regularly reviewing and updating environmental claims to ensure continued compliance. Stay informed about any changes or updates to the directive.

🧠 Why It Matters

The EU Green Claims Directive is more than just a compliance exercise—it’s a cultural shift. It reflects a growing demand for truth in sustainability, where companies are held accountable not just for what they do, but for what they say.

For consumers, it means more confidence in the products they buy. For businesses, it’s a chance to build trust, differentiate themselves, and lead the way in a greener economy.

📌 Final Thoughts

As the EU tightens the rules on environmental marketing, the message is clear: green claims must be more than just green paint. The EU Green Claims Directive is a bold step toward a more honest, transparent, and sustainable marketplace.

Whether you’re a business leader, a policy watcher, or a conscious consumer, this directive is one to watch—and prepare for.