Simply Explained : Green Claims Directive for Fashion

Sustainability messaging has become a core element of brand identity in the apparel and footwear sectors. Labels such as “eco-friendly,” “climate neutral,” and “low impact” now appear across everything – from hangtags and lookbooks to e-commerce listings. Yet the credibility of these claims is increasingly under scrutiny. According to the European Commission, 53% of environmental claims made in the EU are vague, misleading, or unsubstantiated, revealing a critical gap between marketing narratives and verifiable environmental performance.

The existing Unfair Commercial Practices Directive (UCPD) prohibits misleading environmental claims but does not define how such claims must be substantiated. To close this gap, the European Commission has proposed the Green Claims Directive, which introduces a science-based, harmonized framework requiring footwear and textile companies to rigorously substantiate, independently verify, and transparently communicate environmental claims in business-to-consumer contexts across the European Union.

Read on to find out how this will impact your brand, or find the full text of the Green Claims Directive here.

Greenwashing in the Fashion Industry

As environmental concerns influence more consumer choices, the need for accurate and reliable sustainability information has become critical. Consumers must be able to trust that the environmental claims they encounter are based on measurable performance.

Recent regulatory actions highlight the growing requirement for fashion brands to substantiate environmental claims with scientifically credible data. In 2024, the UK Competition and Markets Authority concluded an investigation into ASOS, Boohoo, and George at Asda, finding that their use of sustainability terms lacked sufficient clarity and could mislead consumers. Similarly, H&M reached a $3 million settlement following allegations that its “Conscious” collection included claims not adequately supported by product-level impact data. 

These cases underscore the need for claims to be based on verifiable life cycle assessments, consistent benchmarks, and accessible documentation – principles at the core of the Green Claims Directive.

What Does the EU Green Claims Directive Mean for Fashion Brands?

The Green Claims Directive, officially titled “Directive on substantiation and communication of explicit environmental claims,” is a legislative proposal by the European Commission delivered in 2023. Its purpose is to ensure that any “explicit environmental claim” made by a “trader” (i.e., apparel brand or retailer) about a “product” or “trader’s activities” in a business-to-consumer context can be substantiated through robust, science-based evidence and communicated transparently to consumers. 

For fashion brands, an explicit environmental claim refers to any message, be that on a product label, hangtag, website, or marketing material, that suggests your product or business is good for the environment, less harmful than others, or has become more sustainable over time.

This includes common phrases like:

• Made from recycled materials”
  
  
• “Biodegradable packaging”
  
  
• “Water-saving dyeing process”
  
  
• “Lower carbon footprint than conventional sneakers”
  

Even visual symbols (like green leaves or eco icons) that imply environmental benefits can count as explicit claims under the Directive.

Important: These rules only apply if the claim isn’t already regulated elsewhere. For example, if you’re using the official EU Ecolabel or energy-efficiency label, those claims follow separate, existing legislation and are not subject to the Green Claims Directive.

How Does the EU Green Claims Directive Differ from the UCPD?

The Unfair Commercial Practices Directive (UCPD), established in 2005, provides a general framework prohibiting misleading advertising and unfair business practices across a wide range of goods and services. In 2022, the Commission proposed the “Greenwashing Directive” to amend the UCPD (and the Consumer Rights Directive), explicitly extending its scope to prohibit deceptive sustainability and social responsibility claims. However, even with that amendment, the UCPD does not provide detailed, product-specific methodologies for assessing environmental impacts. The result? A lack of necessary granularity needed to police complex life-cycle-based claims.

By contrast, the Green Claims Directive provides non-industry-specific yet life-cycle-based rules for substantiating any explicit environmental claim in business-to-consumer contexts. In other words, while the UCPD broadly penalizes vague or misleading claims, the Green Claims Directive sets out specific, science-based criteria so that any assertion about a product’s environmental performance must rest on verifiable evidence. 

Read our UCPD deep dive for fashion here

How Does the Green Claims Directive Tackle Greenwashing in the Fashion Industry?

Under Article 3 of the Green Claims Directive, every apparel and footwear brand making an explicit environmental claim must conduct an assessment that meets the following criteria: 

Life Cycle Perspective

• The claim must be based on a full life-cycle assessment (LCA) or equivalent science-based methodology, covering raw-material extraction, production, use, and end-of-life stages.

Benchmarking Against a Reference

• The product or activity must demonstrably perform “significantly better” than a clearly defined reference scenario (e.g., “20 % lower GHG emissions per pair of sneakers compared to the EU market average for athletic footwear”).
• The chosen benchmark must be documented and reflect “common practice” within the relevant product group.

Use of Recognized Standards and Primary Data

• All assessments must rely on internationally recognized standards (e.g., ISO 14040/44 for LCAs, CEN methods for textile fiber tracing) and validated emission factors (e.g., Ecoinvent, EF 3.1).
• Wherever available, primary data (e.g., actual energy and water usage from suppliers, on-site emissions measurements) must be used. If primary data are unavailable, secondary data (e.g., peer-reviewed LCA databases) may be used, provided they are representative of the brand’s supply chain.

Definition of Scope and Functional Unit

• The claim must clearly specify its scope, whether it refers to the entire product, a component (e.g., the upper’s recycled polyester content), or a corporate activity (e.g., factory energy use).
• The functional unit (e.g., “per pair of shoes,” “per kilogram of fabric”) must be explicitly stated to ensure comparability.

Non-Equivalence to Legal Minimums

• Any claim must go beyond existing legal requirements. For example, stating “chrome-free leather” must demonstrate improvements relative to REACH limits, not merely compliance with them.

Disclosure of Trade-Offs

• Fashion brands must identify and disclose any negative environmental impacts that may arise from the claimed improvement.

Separate Reporting of Offsets

• If the claim relies on greenhouse-gas offsets, companies must clearly differentiate between:
  • Actual emission reductions within their value chain (e.g., switching to solar-powered dye houses), and
  • Offset credits (e.g., reforestation projects).
• The type, quality, and certification standard of offsets (e.g., ISO 14064-2) must be disclosed.

Third-Party Verification

• An independent, accredited verification body must confirm that the underlying assessment, data sources, and communication align with the directive requirements.
• Verification reports or certificates must be made available to enforcement authorities and, optionally, to consumers.

Transparent Documentation and Accessibility

• All supporting documentation (LCA reports, data-source descriptions, methodological choices) must be retained for inspection and, upon request, made accessible to consumers (e.g., via QR code or a link).

Comparative Green Claims

For comparative explicit environmental claims, which state or imply better or worse environmental impacts or performance than other products or traders, additional substantiation requirements apply. These include ensuring that:

• Identify Both Parties Clearly: Specify the product (or trader) making the claim and the reference product (or trader) being compared.
• Use the Same Functional Unit and Boundaries: Apply identical life-cycle scope (e.g., cradle-to-grave) and a consistent unit (e.g., “per pair of shoes”) for both items.
• Benchmark with Representative Data: Source up-to-date, industry-average, or peer-reviewed data for reference, ensuring an apples-to-apples comparison.
• Demonstrate a Significant Difference: Quantify the performance gap (e.g., “30 % lower water use”) and show it exceeds normal data variability.
• Disclose Methodology and Uncertainty: Briefly state key methodological choices (e.g., allocation rules) and any uncertainty range in the comparison.
• Reveal Relevant Trade-Offs: Note any negative impacts for either item (e.g., lower water use but higher energy consumption).
• Avoid Misleading Framing: Do not omit material environmental aspects that could alter the overall comparison; specify which impact category is compared if not all are included.
• Obtain Independent Verification: Have an accredited third party confirm that both the claimed product’s data and the reference’s data meet the Directive’s requirements.

Third-Party Verification for Green Claims Directive

Under the Green Claims Directive, any environmental claim must be verified by an independent, accredited third party. Here are some of the requirements:

Accreditation under the EU Framework

Verifiers must be accredited under Regulation (EC) No 765/2008 to perform conformity assessments (e.g., LCAs, GHG accounting) and reference recognized standards to ensure they are qualified to audit LCA studies and related data.

Organizational and Financial Independence

Verifiers must be fully independent of the company or products they audit. They may not provide any consulting, design, production, or advisory services related to the environmental attributes under review.

Technical Competence and Resources

The verifier must possess the necessary expertise (e.g., in LCA methodologies), equipment, and infrastructure to carry out the verification activities for which it is accredited.

Here are some examples of eligible verifiers:

• National conformity assessment bodies (e.g., DAkkS in Germany, and COFRAC in France) are accredited to verify GHG footprints under ISO 14065.
• Specialized product-verification entities accredited under ISO 17029 with extended scope for textile and footwear LCAs.
• Carbon footprint auditors, accredited to assess offset integrity.

Green Claims Directive and the Role of PEFCR for Apparel and Footwear

The Product Environmental Footprint Category Rules (PEFCR) for Apparel and Footwear provide a science-based, harmonized method for measuring and comparing the environmental performance of products across the EU. Developed over several years, the PEFCR for the fashion sector is now finalized, with no further modifications expected. 

Here is an overview of the final version (v3.1) of the PEFCR guideline.

While the Green Claims Directive does not currently mandate the use of PEFCR yet, it explicitly recognizes them as a valid basis for substantiating claims. According to the Directive:

“Category rules for specific products or traders can be used to support the substantiation of claims in line with the requirements of this Directive.”
(Recital 32, COM/2023/166 final)

The Directive also empowers the Commission to adopt delegated acts that may make PEF the reference methodology for specific product categories in the future.

Read our PEF Apparel and Footwear deep dive here

What Does This Mean for Apparel & Footwear Brands?

Using the finalized PEFCR allows brands to measure product impacts such as carbon footprint (CO₂e), water use, and land use, all according to a harmonized and scientifically accepted methodology. This ensures that environmental claims are credible, comparable, and aligned with EU regulatory expectations.

Several upcoming EU initiatives, including the Ecodesign for Sustainable Products Regulation (ESPR) and the Digital Product Passport (DPP), are expected to build on PEF-based methods. Brands that invest now in PEF-aligned infrastructure will be better positioned to make comparative claims, meet future regulatory requirements, and ensure their environmental messaging is both compliant and competitive.

PEF score in Carbonfact - Environmental Data platform

When will the Green Claims Directive be Implemented?

While the Green Claims Directive has not yet entered into force, its legislative progress is well underway; therefore, fashion brands should not wait until enforcement begins to take action. Here is the expected timeline:

• 2023: European Commission publishes the Green Claims Directive proposal
• Late 2025: Expected entry into force
• Mid-2027: Member state transposition deadline: 18 months after the date of entry into force (i.e., mid-2027). During this period, each country must adopt national laws, appoint competent authorities, and set up verification mechanisms.
• Early 2028: Application date: 24 months after entry into force all substantive requirements (e.g., life-cycle assessments, third-party verification processes, public disclosure standards) become applicable. Fashion brands can no longer make any new environmental claims without complying with the Green Claim Directive’s criteria.

What are the Consequences of Non-Compliance for Textile Brands?

Member states must lay down effective, proportionate penalties for infringements that discourage repeat offenses. Factors influencing the level of fines include the nature, gravity, extent, and duration of the infringement, whether it was intentional or negligent, the brand’s annual turnover, the economic gains from the violation, and any previous infringements. 

Minimum Penalty Threshold: For cross-border infringements (e.g., an online retailer selling sneakers across multiple EU states), fines must be at least 4% of the annual turnover in the affected member state(s), aligning with penalties under the Digital Services Act and GDPR for similarly serious breaches. Smaller local infringements may incur proportionate fines.

In addition to monetary sanctions, member states can impose:

• Confiscation of revenues gained from the misleading claims
• Temporary exclusion (up to 12 months) from public procurement and funding programs (e.g., subsidies available under the EU’s Common Agricultural Policy for textile fiber producers)
• Public naming and shaming
• Mandatory corrective advertising (e.g., prominently updating product labels to remove the environmental claim).

Green Claims Directive is a Data Regulation

By 2028, every environmental claim you make to consumers must be scientifically substantiated, independently verified, and fully documented. That means: no compliant claim without structured, high-quality data. For brands still relying on spreadsheets, supplier PDFs, or disconnected reporting tools, the risk of non-compliance is high. 

That’s why apparel and textile companies must start building their data infrastructure now. Early preparation is essential to avoid last-minute scrambles, verification failures, or greenwashing penalties.

Carbonfact is your partner in a post-Green Claims market. As an environmental data platform built specifically for fashion and textile brands, Carbonfact enables rapid, scalable, and compliant product-level impact measurement, laying the foundation for credible communications around environmental impact.

We help you with:

• Scientific, Product-Level Data: Carbonfact runs detailed product LCAs for your whole catalog, delivering cradle-to-grave environmental impact data (GHGs, water, waste, etc.) based on robust methodologies like PEFCR, ISO 14040, and the GHG Protocol. 
• Full Transparency and Auditability: All data, sources, assumptions, and methods behind environmental claims are documented, retained, and accessible for inspection, critical for compliance. Audit trails make it easy to provide supporting evidence if regulators or consumers request it.⁠
• A⁠⁠utomated Data Management: Integration with ERPs, PLMs, and traceability solutions automates the collection and validation of primary data needed for substantiating claims and makes it possible to quickly respond to regulatory or consumer information requests.⁠

Clearly document scope, functional units, and trade-offs: The platform lets you define whether an impact applies to the entire product (e.g., “full shoe”), a single component (e.g., “midsole”), or a corporate activity (e.g., “factory operations”).