Simply Explained: Green Claims Directive for Fashion

Status: Proposal published in 2023; legislative process paused.

The Green Claims Directive was proposed to establish EU-wide requirements for substantiating voluntary environmental claims, including both product- and brand-level claims. For fashion brands, it was designed to rely on life cycle–based evidence, using the Product Environmental Footprint (PEF) methodology as the main reference framework.

As of June 2025, the legislative process for the Green Claims Directive has been paused and is in serious doubt. The European Commission signaled its intention to withdraw the proposal, stating that ongoing negotiations conflicted with its simplification agenda, particularly due to the administrative burden for micro-enterprises.

This article explains what the Directive was intended to introduce and why it remains relevant for understanding the EU’s direction on environmental claims in fashion. In the meantime, we recommend that brands follow the Empowering Consumers for the Green Transition Directive, an active EU law currently being transposed into national legislation, which amends the Unfair Commercial Practices Directive (UCPD) and already sets binding rules on environmental marketing in 2026.

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.

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 would 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 would not be subject to the Green Claims Directive.

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

The Unfair Commercial Practices Directive (UCPD), adopted in 2005, is the EU’s core consumer protection framework. It prohibits misleading and unfair commercial practices across all sectors, including environmental marketing claims. In 2024, the UCPD was amended by the Empowering Consumers for the Green Transition Directive (ECGT), which strengthened the rules on sustainability-related claims by explicitly banning certain practices, such as generic environmental claims without evidence, claims based solely on carbon offsetting, and unapproved sustainability labels.

While the UCPD clearly defines which types of environmental claims are not allowed, it does not explain how companies should substantiate allowed claims, nor does it set product-specific methodologies for assessing environmental impacts. Enforcement therefore, focuses on whether a claim is misleading, rather than on harmonized methods for measuring environmental performance.

The Green Claims Directive was designed to complement this framework by introducing life cycle–based substantiation requirements for any explicit environmental claim made to consumers. It would have required companies to rely on recognized methodologies, such as the Product Environmental Footprint (PEF), and to support claims with quantified, verifiable evidence. 

Read our UCPD deep dive for fashion here

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

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

Life Cycle Perspective

• The claim should 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 should 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 should be documented and reflect “common practice” within the relevant product group.

Use of Recognized Standards and Primary Data

• All assessments should 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) should 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 should 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”) should be explicitly stated to ensure comparability.

Non-Equivalence to Legal Minimums

• Any claim should 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 should 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 should 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) should be disclosed.

Third-Party Verification

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

Transparent Documentation and Accessibility

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

Comparative Green Claims

Under the Commission’s proposal, 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 proposal, 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.

Green Claims Directive explicitly recognizes PEFCR 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 would also empower 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

Will the Green Claims Directive Be Implemented?

As of June 2025, the implementation of the Green Claims Directive is uncertain. The European Commission has announced its intention to withdraw the proposal following political pressure. 

Despite this uncertainty, fashion brands should not dismiss the fact that regulatory pressure to curb greenwashing is likely to intensify in the coming years. Even if the Green Claims Directive is withdrawn or delayed, the existing Unfair Commercial Practices Directive (UCPD) still prohibits misleading environmental claims, and enforcement is expected to tighten. 

Here is the original Green Claims timeline:

• 2023: European Commission publishes the Green Claims Directive proposal
• 2024: European Union provisionally approves the proposal
• Late 2025 (originally expected): Entry into force
• Mid-2027 (tentative): Member state transposition deadline, 18 months after entry into force, requiring countries to adopt national laws, appoint competent authorities, and establish verification mechanisms
• Early 2028 (tentative): Full application of the directive’s requirements, including life-cycle assessments, third-party verification, and disclosure standards. At this point, fashion brands would no longer be allowed to make new environmental claims unless fully compliant.

Green Claims Directive Penalties

Under the Green Claims Directive proposal, 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. 

The proposal introduced 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 could 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

Whether through the Green Claims Directive or the upcoming stricter enforcement of the Unfair Commercial Practices Directive  (UCPD), environmental messaging will soon be regulated, and every claim will require robust, verifiable data. 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”).