Green claims: checklist for avoiding greenwashing
The Green Claims Directive requires transparent and verifiable environmental claims. Use our free greenwashing checklist.
- The EU Green Claims Directive targets misleading environmental marketing and requires verifiable, scientifically backed claims.
- 53% of green claims are potentially misleading and 40% lack any verifiable evidence, according to EU research.
- Companies must have their environmental claims assessed by an independent third party at least every five years.
- Micro-enterprises (fewer than 10 employees and under €2 million turnover) are currently exempt; the directive does not apply to B2B communications.
- Non-compliance can result in fines of at least 4% of annual turnover, plus injunctive relief and damage claims.
The Green Claims Directive was launched by the EU Commission to prevent misleading environmental claims, also known as greenwashing, and to promote clear, transparent communication of environmental benefits. This directive is part of the EU Green Deal, which includes other sustainability initiatives such as the Corporate Sustainability Reporting Directive (CSRD), the EU taxonomy and other initiatives.
Sustainability has become a decisive criterion for consumers. Companies are now faced with the challenge of making their environmental claims scientifically sound and verifiable. This article gives you a comprehensive overview of the Green Claims Directive, what it means for your business and how you can make compliant environmental claims.
The Green Claims Directive, part of the Omnibus proposal, currently remains uncertain. In the meantime, the implementation of the EmpCo Directive is moving forward rapidly. You will find all essential information on its content, deadline and practical examples in that article.
Green Claims Directive
What are green claims?
Green claims are environmental statements made by companies indicating the environmental friendliness of their products, services or business practices. These claims are now ubiquitous, from "climate-neutral products" to "environmentally friendly packaging". But how reliable are they really?
According to a study conducted by the EU, 53% of environmental claims are potentially misleading and 40% of claims are not based on any verifiable evidence. The Green Claims Directive addresses this by requiring companies to substantiate their claims with solid data and by prohibiting certain statements outright.
Why this directive is necessary
It is often difficult for consumers to distinguish credible environmental claims from unfounded ones. The Green Claims Directive aims to stop greenwashing, where companies make unsubstantiated or false environmental claims to appear environmentally friendly. The directive gives consumers access to reliable information so they can make informed decisions.
It also improves comparability of environmental claims and requires companies to communicate clearly and transparently. This protects both consumers and companies that are making honest claims.
Which environmental statements are permitted?
Companies must substantiate their environmental claims with scientific evidence and have them verified by independent third parties. Here are examples of what is and is not permitted.
Permitted claims
- "This product is made from 100% recycled plastic" - allowed, as long as the company can prove the material is genuinely recycled and has been tested by an independent body.
- "CO2-neutral supply chain" - allowed, if the company transparently demonstrates the use of certified CO2 offsetting projects that meet the strict requirements of the directive.
Prohibited claims
- "Environmentally friendly" - too general; forbidden without specific, provable information on the environmental benefit.
- "Climate-neutral thanks to CO2 compensation" - not permitted if the compensation scheme is not transparent and detailed.
The Green Claims Checklist
We have created a checklist that companies can use to check whether their environmental claims meet the requirements of the directive.
What the directive means for companies
The directive means greater responsibility and transparency in how you communicate environmental statements.
Five steps to compliant green claims
- Build up in-house expertise on the Green Claims Directive
- Collect and review all existing advertising claims for environmental statements
- Check each environmental statement against the regulatory requirements
- Adapt any non-compliant claims
- Develop internal rules and processes for future claims
Companies must ensure that claims are based on scientific evidence and that all significant environmental impacts of the product or service are taken into account. Every environmental claim must also be reviewed regularly, at least every five years, by an independent body.
Best practice example
With its organic oat drink, the drugstore chain dm is considered a best practice example in implementing the directive.
Already reporting under the CSRD? Our ESRS data points template helps you structure and document the sustainability data that can serve as evidence for your environmental claims.
The link to the CSRD
While the Green Claims Directive focuses on specific environmental claims, the CSRD requires holistic sustainability reporting. Under the CSRD, companies must disclose their entire environmental, social and governance (ESG) performance. The European Sustainability Reporting Standards (ESRS) centre on double materiality, which considers both the impact of a company on the environment and society (inside-out) and the impact of environmental factors on the company (outside-in).
The CSRD collects and makes transparent large volumes of sustainability data, much of which can serve as evidence for the environmental statements you make.
Conclusion: a must for responsible companies
The Green Claims Directive is an important step towards preventing greenwashing and restoring consumer confidence in environmental claims. Companies must ensure that their environmental claims are supported by scientific evidence and can withstand independent scrutiny.
For companies that take sustainability seriously, this directive is also an opportunity to differentiate from competitors and build trust with customers before it becomes mandatory for all.
Acting now means fewer risks and a stronger market position when compliance becomes compulsory.
Frequently asked questions about green claims and greenwashing
Does the Green Claims Directive apply to all companies?
No. Micro-enterprises with fewer than 10 employees and less than €2 million in annual turnover are currently exempt. The directive also does not apply to B2B communications, only to consumer-facing claims.
How much does verification of a green claim cost?
The cost of independent verification is expected to range from around €500 to €8,000. The exact amount depends on the type of environmental claim and the number of products involved.
What penalties apply if companies do not comply?
Non-compliance can result in fines of at least 4% of annual turnover. Affected parties may also seek injunctive relief and damages. The reputational damage from a public greenwashing finding can be substantial beyond any financial penalty.
How does the Green Claims Directive relate to CSRD reporting?
The two are complementary. The CSRD requires companies to report holistic ESG data under the ESRS standards. That same data, especially environmental performance figures, can directly substantiate the green claims you make. Starting your CSRD reporting early gives you a stronger evidence base for compliant environmental marketing.
