Green Claims Directive
Navigating the new environmental claims landscape in the EU
The Green Claims Directive will be a game-changing regulatory framework aiming to eliminate “greenwashing” – the practice of making misleading or unsubstantiated claims about a product's environmental benefits.
In the rapidly evolving landscape of environmental consciousness, the European Union is taking decisive steps to ensure that companies' environmental claims are transparent, accurate and substantiated. The Green Claims Directive (GCD) will be a game-changing regulatory framework that aims to eliminate “greenwashing” – the practice of making misleading or unsubstantiated claims about a product's environmental benefits1. With over half of all green claims in the EU found to be vague or misleading and 40% lacking supporting evidence, the need for the regulation is clear2.
The GCD is a crucial part of the EU’s broader sustainability strategy, mandating strict criteria for making environmental claims. It requires companies to provide clear and accurate communication while mandating independent third-party claim verification before these claims are applied to commercial communications. The GCD will have a broad impact, affecting a vast majority of EU-operating companies, including non-EU companies trading within the EU.
What does the Green Claims Directive cover?
The GCD covers an “explicit environmental claim voluntarily made” and is considered as “any message or representation” related to the positive or neutral (present or future) environmental aspects, impact, or performance of a product, service or the trader itself3. For example:
- Textual: the brand’s name
- Graphic: the colour(s) used
- Comparative: "fewer resources used"
- Labels and labelling schemes
It should be made “voluntarily” in the context of commercial communication, meaning that they are used in the context of business-to-consumer (B2C) relationships. This definition thus excludes environmental claims already regulated or substantiated by rules established in the EU or under national regulation.
Example claims covered could include:
Empowering consumers and companies: compliance and challenges
The GCD signifies a substantial shift in the conventional marketing of environmental claims and labels. Companies will need to overhaul their marketing strategies to ensure compliance, facing substantial fines if requirements are not met. The GCD also extends beyond B2C companies, impacting business-to-business (B2B) relationships as suppliers must ensure compliance in their offerings.
One of the GCD's core objectives is to empower consumers by providing them with accurate information, thus enabling informed choices. This shift also presents an opportunity for companies. Those actively reducing their negative environmental impact stand to gain a competitive edge in an increasingly environmentally aware market.
What comes next?
As the directive comes into effect, companies must adapt quickly. This involves conducting thorough assessments to substantiate explicit environmental claims, understanding and adhering to new labelling requirements, and potentially re-strategising their marketing and communications approach. Collaboration with approved verifiers will become crucial, as will the adoption of life cycle assessments and other compliance measures.
The Green Claims Directive timeline:
2023 –2024:
- Proposal of EU Green Claims Directive put forth
- Proposal is adopted and becomes law
2024–2027:
- Initiation phase for directive implementation
2027–ongoing:
- The directive enters full-scale operation
AFRY can holistically assist companies to prepare for the Green Claims Directive
At AFRY, we understand the challenges and opportunities presented by the Green Claims Directive.
Our expertise in sustainability consulting positions us ideally to assist companies in navigating this new regulatory landscape. From life cycle assessments to communication strategies and compliance checks, we offer tailored solutions to ensure your company not only meets but excels under the new directive.
Life cycle assessments to calculate a product’s environmental impact and performance in accordance with EU requirements and screening environmental label use.
Conducting a health check of current marketing and communications materials, such as screening for vague and potentially misleading claims, claims where no proof is provided, etc.
Providing guidelines and training tailored to our clients’ specific needs to upskill their marketing and communications staff to be adequately prepared to communicate effectively and authentically about the environmental impact of their products and services.
Benchmarking to respective industry peers and geographical risk mapping (NGOs and authorities) based on cases of greenwashing litigation currently occurring globally.
Our approach will bring client promotional materials to the level required by the GCD, producing a comprehensive report and presenting the results in a workshop:
- Kick-off: determining the scope and timeline, such as selecting marketing and communication materials for review.
- Health check: scanning clients’ marketing and communications materials on a high level in relation to best practices and the latest information available to identify risks and start preparing for the final implementation of the GCD. Findings will be synthesised into a written report.
- Workshop and presentation: recapping the health check findings and sharing examples of best practices – how to recognise environmental claims and how to communicate them effectively and authentically.
Preparing for a greener future
The Green Claims Directive represents a significant step towards more sustainable business practices in the EU. It challenges companies to be more honest and transparent in their environmental claims, aligning corporate practices with consumer values and environmental needs. In this new era of sustainability, companies must be proactive and thorough in their approach to green claims, ensuring authenticity and compliance in all aspects of their operations and communications.
