Green Claims (prop.)
Proposal COM(2023) 166 — Directive on substantiation and communication of explicit environmental claims
Topic : Green claims · Level : Regional
Today
Blocked: trilogues on hold since 23 Jun 2025; not formally withdrawn; listed as pending in CWP 2026 (EP train, 20 Sep 2026).
Summary
Proposed EU directive requiring prior third-party verification of explicit environmental claims. Talks stalled in June 2025 after the Commission announced it would withdraw it. Directive 2024/825 already applies to claims.
Who is concerned
- Turnover
- Micro firms exempt (<EUR 2m) in proposal
- Employees
- Micro firms exempt (<10) in proposal
- Listed company
- cotées et non cotées
- Sectors
- All B2C sectors
- Triggering activities
- Explicit environmental claims to consumers
- Environmental labelling schemes
- Extraterritorial reach
- Yes
Would apply to any trader making claims to EU consumers.
- Examples
- Brand claiming '50% recycled' packaging
- Retailer running its own eco-label
What the law requires
- Substantiate explicit claims with life-cycle based evidence before use
- Have claims verified by an accredited third party before publication
- Communicate claims with the supporting information accessible to consumers
Penalties
Commission proposal and EP position: max fines of at least 4% of annual turnover, revenue confiscation, exclusion from public procurement.
What this changes for a supplier in China
No legal effect now. If revived, buyers would need life-cycle data and verified evidence from suppliers for each explicit claim.
Expected evidence
- LCA or PEF data for the product
- Recycled content chain of custody
- Verification certificate of the claim
Tiers : Tier 1-2