On Hold: EU pulls the plug on Green Claims Directive

Background & Status

The Green Claims Directive Proposal was already in the final phase of interinstitutional trilogue negotiations. The Directive was proposed in March 2023 and aims to set standards for companies to substantiate their environmental claims, thereby protecting consumers from misleading information.

The European Parliament adopted its first reading position on the file in March 2024 and the European Council agreed its position in June 2024. Negotiations on the final text of the draft law started in January 2025 and were expected to come to a conclusion on Monday 23 June at a meeting that the Council then officially cancelled.

Existing EU Anti-Greenwashing Framework remains in force

It should be noted, however, that irrespective of whether or not the EU will resume the Green Claims Directive Proposal, the withdrawal of the proposal will not affect the existing EU framework to protect consumers against greenwashing, including the Empowering Consumers for the Green Transition (“ECGT”) Directive. The ECGT already entered into force in March 2024 and needs to be transposed by March 2026 and applied as of September 2026.

Whilst the ECGT (as a lex generalis) provides for general rules against green washing (and social washing), the Green Claims Directive was intended to complement the ECGT by setting minimum requirements on the substantiation and communication of environmental claims and environmental labels (as lex specialis). For this purpose, the Green Claims Directive aimed at providing stringent criteria and requirements on how companies should prove their environmental claims and labels, as well as mandatory advance third-party verification for all environmental claims and labels.

Whilst this general verification requirement is on hold for now, verification requirements will nevertheless apply under the ECGT for:

1. Private sustainability labels promoting environmental and/or social benefits and
2. Forward looking environmental claims (such as „climate neutral until 2050“).

   In addition, ECGT will also prohibit the following greenwashing practices:

3. Generic environmental claims (such as “climate-friendly”, “CO2-neutral”, “energy-efficient”, “green”, “biodegradable”, “eco”, or “environmentally friendly”) without providing a clear and prominent specification of the claim on the same medium (e.g. on the packaging) or demonstrating the recognized excellent environmental performance e.g. by the EU Ecolabel;
4. Environmental claims about the entire product or the entire business, if they can only be substantiated for a certain aspect of the product or a specific business segment;
5. Climate claims (such as “climate neutral” or “carbon neutral”) based on CO2 compensation schemes; and
6. Promotion of compliance with statutory sustainability requirements when presenting a feature as distinctive for a particular product, if that feature simply meets a requirement imposed by law on all products within the relevant product category.

What’s next?

So, what's the current situation and what will happen next?

• The legislative talks have been paused indefinitely.
• The Commission signalised it may withdraw the proposal.
• The future of the Green Claims Directive is now uncertain - it could be delayed, reworked, or even abandoned.

In any case, it’s important to note that the restrictions of Empowering Consumers for the Green Transition Directive aiming to combat greenwashing are still to be transposed and applied by the EU Member States. The already existing regulation on greenwashing in the Member States, for example under national advertising laws, will also remain unaffected.

Authored by Dr. Christiane Alpers, Mareike Hunfeld, and Andrea Menzel.