EU rules for the green transition do not create one universal “green certificate” for every product. They make the scope and substantiation of commercial environmental statements more important. For a cross-border seller, brand owner or supplier, the practical starting point is to map each statement on a product page or package to the relevant SKU, material, legal entity, evidence and use condition before deciding which rule applies.
Start with legal status: adopted rules are not the same as a proposal
Directive (EU) 2024/825 was adopted on 28 February 2024. It amends the Unfair Commercial Practices Directive 2005/29/EC and the Consumer Rights Directive 2011/83/EU. Member States must transpose it by 27 March 2026, and the new rules apply from 27 September 2026. This article uses that adopted directive as the main reference for preparation before September 2026.
COM(2023)166 is a separate Commission proposal commonly called the “Green Claims Directive”. It concerns the substantiation and communication of explicit environmental claims, but it is not the same instrument as Directive (EU) 2024/825 and should not be presented as an adopted, generally applicable obligation. If a business uses proposed environmental-footprint, verifier or labelling concepts for internal planning, it should label them as proposal-stage material and check the legislative status again before publication.
1. Identify the commercial statement before collecting documents
Directive (EU) 2024/825 treats an environmental claim broadly: a non-mandatory message or representation in a commercial communication, including text, images, graphics, symbols, brand names, company names or product names, that states or implies a positive or zero environmental impact, less harm than another product or trader, or an improvement over time. A leaf symbol, an “eco” product name and a “low carbon” headline therefore deserve the same scope-first review as a sentence.
A sustainability label is a voluntary trust mark, quality mark or equivalent mark used to distinguish and promote a product, process or trader by reference to environmental or social characteristics. Mandatory labels required by EU or national law are outside that definition. Calling a mark a “certification” is not enough: the reviewer should examine the public scheme rules, scope and monitoring arrangements.
2. Boundaries to check before 27 September 2026
Generic environmental claims need relevant substantiation
Expressions such as “green”, “eco-friendly”, “environmentally friendly”, “climate-friendly” and similar broad wording are high-risk when the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. A clear and prominent specification on the same medium may change how a statement is characterised, but the specific statement still has to comply with other applicable rules. A small disclaimer does not repair an unsupported overall impression.
A packaging attribute must not become a whole-product claim
If the evidence only supports recycled material in the packaging, the product page should not imply that the entire product is made from recycled material. Use a defined object, such as “the packaging contains recycled material”, only when the supporting data covers the stated percentage, material layer, batch or SKU range and calculation basis. Do not invent a percentage because a supplier document uses a broad marketing phrase.
Do not turn offsetting into a product climate result
The directive adds to the prohibited practices a claim, based on greenhouse-gas offsetting, that a product has a neutral, reduced or positive environmental impact in terms of greenhouse-gas emissions. Carbon projects, product footprints, reduction data and offset arrangements are different records. Buying or retiring offsets does not by itself make a product “zero-emission”. Any specific climate statement needs a separate review of the product boundary, baseline, method, period and sector rules.
Do not present a legal requirement as a unique green advantage
Requirements imposed by law on all products in the relevant product category on the Union market should not be presented as a trader’s distinctive environmental advantage. A page may explain a legal requirement, but it should distinguish a mandatory condition from a voluntary business commitment and from a private certification-scheme condition.
A sustainability label needs a credible scheme or public authority basis
Displaying a sustainability label that is neither based on a certification scheme nor established by a public authority is one of the newly targeted prohibited practices. Scheme requirements and conditions of use should be publicly available, with objective third-party monitoring. The competence and independence of that third party need to be supported by relevant standards or procedures. A certificate or mark does not automatically prove that a particular SKU, package or web statement is covered.
3. Build an index around claim, object, evidence and owner
Start with the exact wording and visual meaning used in the market-facing material, not with a list of certificates held by the supplier. A reviewable index should include at least:
- Exact claim: preserve the wording and artwork version from the product page, package, label, advertisement and product name; record language, channel, first-use date and version.
- Claimed object: identify whether the statement concerns the whole product, a component, packaging, a material, a process, transport or an activity of the trader; link it to the relevant SKU, model, batch or product family.
- Environmental attribute and boundary: state whether the subject is recycled content, material origin, energy, emissions, durability, repairability or recyclability, and record what is expressly excluded and which market is covered.
- Evidence and method: link specifications, bills of materials, material declarations, test reports, calculations, supplier files, footprint work or other method documents; record data source, method, period and version.
- Legal entity and owner: record the brand owner, manufacturer, importer, page operator, certificate holder and data provider so that a supplier document is not silently treated as evidence for a different legal entity.
- Label or certificate conditions: record the scheme, public rules, certificate number, scope, issuer, validity, suspension or withdrawal status, permitted artwork and wording, and whether the SKU or packaging is actually covered.
- Change triggers: record who reopens the review when materials, formulas, factories, suppliers, packaging, methods, scheme rules or claim wording change, and which documents must be refreshed.
4. Review packaging, labels and certificates in three layers
Page and packaging layer
Transcribe the environmental wording and describe the meaning of each graphic. Review the headline, selling points, icons, front-of-pack wording, product detail page and FAQ together because their combined design may create a broader impression than any single sentence. Separate “product”, “packaging” and “material” as claim objects.
Product and supply-chain evidence layer
Map the claim to the SKU, material composition, manufacturing site and time period. A supplier certificate or test report may be a source document, but the reviewer still needs to check the holder, scope, material or process, sample or batch, issue date, active status and conditions of use. “The supplier has a certificate” is not the same as “this page claim is covered”.
Scheme and legal-boundary layer
Identify whether the mark is issued by a public authority, licensed under a certification scheme or created by the business itself, and retain the public rules and monitoring information. Mandatory labels, sector rules, food-contact requirements, energy labels, textile labels and packaging-waste requirements need their own checks. The general framework of Directive (EU) 2024/825 does not replace those specific regimes.
5. A bounded implementation example
Assume a brand wants to publish “packaging contains recycled material” on an EU product page and has received a material declaration and a certification-scheme document from its supplier. The page owner first preserves the exact wording and packaging artwork. The product or procurement owner then confirms that the statement concerns packaging only and checks the material layer, percentage, batch and supplier records. The scheme owner checks the mark’s permitted use, scope and status. A compliance owner then asks whether packaging, product-category or consumer-information rules add a separate requirement. If a step cannot be substantiated, narrow or pause the statement; do not convert missing evidence into a claim of compliance.
6. Six questions before publication
- What exact environmental statement or visual impression appears on the page, package or label?
- Does it concern the whole product, packaging, a component, a material, a process or an activity of the trader?
- Does the evidence cover the same SKU, material, legal entity, time period and target market?
- Can the public scheme rules, conditions of use, third-party monitoring and current status be retained?
- Has a legal requirement been presented as a unique advantage, or has offsetting been presented as a product environmental result?
- Who reopens the review when the material, supplier, packaging, method or wording changes, and which records are refreshed?
Sources and limits
The legal dates, definitions and prohibited-practice boundaries in this article are based on the official EUR-Lex text of Directive (EU) 2024/825 and its Legislation Summary. The European Commission’s Sustainable consumption page was used to check the transposition and application dates. The separate COM(2023)166 proposal was checked against the Commission’s Green claims page and the EUR-Lex procedure record.
This is a claim-and-evidence indexing framework. It is not a substitute for the law of a particular Member State, sector-specific requirements, certification-scheme rules or legal advice. Before publication, review the actual product category, commercial role, target country and wording.
