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.
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.
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:
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.
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
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
Benchmarking Against a Reference
Use of Recognized Standards and Primary Data
Definition of Scope and Functional Unit
Non-Equivalence to Legal Minimums
Disclosure of Trade-Offs
Separate Reporting of Offsets
Third-Party Verification
Transparent Documentation and Accessibility
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:
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:
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
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
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:
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:
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.
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