Sustainability messaging is now central to apparel and footwear branding, with claims like “eco-friendly” and “climate neutral” appearing widely. Yet 53% of such claims in the EU are vague, misleading, or unsubstantiated, exposing a major gap between marketing and actual environmental performance.
The Green Claims Directive is designed to guide apparel and footwear brands on how to verify environmental claims using the Product Environmental Footprint (PEF) methodology in the EU. Its companion legislation, the Empowering Consumers Directive — also known as the Unfair Commercial Practices Directive (UCPD) — outlines which types of green claims are prohibited altogether.
Recently, the European Commission announced its intention to withdraw the Green Claims Directive. In its official communication, the Commission stated that “the current discussions around the proposal go against the Commission’s simplification agenda, notably regarding microenterprises.”
The EU Parliament and Council have voiced concerns about its implications. The withdrawal is not yet confirmed and requires approval from the College of Commissioners, which is set to make the decision in the upcoming weeks.
So what is at stake? In the sections below, we explore the original scope of the Green Claims Directive, what it was designed to change, and what its potential withdrawal could mean for environmental marketing 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.
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 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.
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
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
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
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, 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.
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
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. However, the withdrawal is not yet official; it must still be approved by the College of Commissioners and the negotiators from the European Parliament and Council have expressed willingness to continue talks.
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.
Understanding the original timeline and preparing accordingly remains an important step:
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:
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:
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”).