What the new European regulation (Empowering Consumers Directive) brings, why generic “green” language is no longer enough, and how to build a claim file that protects you.
From impressions to evidence: new rules for environmental claims
A few years ago, it was enough to describe a product as environmentally friendly, add a green leaf to the design and consider the packaging done. Today, the landscape is changing fundamentally. The European Union is tightening the rules and adding accountability and a clear burden of proof to marketing creativity.
The proposed Empowering Consumers Directive makes it clear: if you claim to be “green”, you must be able to substantiate it with methodology, data, and, in many cases, independent verification. Otherwise, many commonly used statements will be regarded as misleading commercial practices. Companies risk fines, bans on using certain claims or having campaigns withdrawn from the market.
Let’s look at 13 typical examples that are becoming high-risk – and how to communicate them safely.
1. “We are an eco-friendly company.”
This is a textbook example of an overly broad environmental claim. It does not define scope, area or specific impact. Under the new rules, such wording will be unacceptable unless supported by a comprehensive assessment of all relevant impacts.
Risk: A vague claim with no defined scope or measurable impact. Without a full assessment of company activities, it is not defensible.
Safer alternative:
👉 “Between 2022 and 2024, we reduced our Scope 1 and 2 emissions by 18% in line with the GHG Protocol.”
2. “Our product is sustainable.”
The term “sustainable” has no single legal definition. Unless you clearly explain in what sense the product is sustainable (materials, manufacturing, logistics, lifecycle), the claim is open to challenge.
Risk: It creates the misleading impression that the product has no negative impact, which is virtually impossible.
Safer alternative:
👉 “The product contains 62% recycled plastic and has a 25% lower carbon footprint compared to the previous generation.”
3. “We are carbon neutral.”
Regulators are specifically targeting cases where neutrality is achieved primarily through offsets rather than genuine emission reductions. The Empowering Consumers Directive explicitly restricts claims based solely on compensation mechanisms.
Risk: Claiming neutrality based only on carbon credits is prohibited.
Safer alternative:
👉 “By 2024, we reduced our own emissions by 35%. The remaining emissions are offset through certified projects.”
4. “100% natural.”
“Natural” is problematic where products contain synthetic ingredients or where production itself has environmental impacts. Claims must reflect the actual composition and not mislead when viewed across the entire lifecycle.
Risk: Even minimal synthetic content or environmentally intensive production undermines the claim.
Safer alternative:
👉 “The product contains no synthetic colourants and is made from 98% natural fibres.”
5. “Eco-friendly packaging.”
Without specifying whether the packaging is recyclable, compostable or contains recycled content, this is vague. The new rules also limit the use of environmental labels without proper certification.
Risk: A non-specific claim or the use of self-created eco labels.
Safer alternative:
👉 “The packaging is 100% recyclable and contains 70% recycled paper.”
6. “Environmentally friendly.”
Like “eco-friendly”, this is a generic claim without measurable substance.
Risk: No concrete, verifiable benefit across the product lifecycle.
Safer alternative:
👉 “We reduced water consumption in production by 30% compared to 2021.”
7. “We use green energy.”
If renewable electricity is only used partially or through guarantees of origin, this must be communicated clearly.
Risk: Creating the impression that production runs entirely on solar or wind when it does not.
Safer alternative:
👉 “100% of the electricity used in our manufacturing is purchased with guarantees of origin from renewable sources.”
8. “We will be circular by 2030.”
The Empowering Consumers Directive prohibits claims about future environmental performance unless supported by clear, objective, and publicly available targets.
Risk: Promises without a detailed, public roadmap and milestones.
Safer alternative:
👉 “By 2028, 95% of our formulations will meet OECD biodegradability standards. Our implementation roadmap is available on our website.”
9. “Microplastic-free.”
You cannot present compliance with legal requirements as a unique benefit. It must also be clear whether the claim refers to the content, the packaging or both.
Risk: Presenting legal minimum standards as competitive advantages.
Safer alternative:
👉 “The formula contains no intentionally added solid microplastic particles as defined by EU REACH. The packaging is paper-based.”
10. “100% biodegradable.”
Absolute claims such as “100%”, “completely” or “always” are extremely risky. Without a timeframe and recognised standard (e.g. OECD), they are misleading.
Risk: No timeframe or environmental conditions specified (home vs industrial composting).
Safer alternative:
👉 “More than 95% of the organic ingredients biodegrade within 28 days according to OECD standards.”
11. “Ethical and transparent sourcing.”
Strong superlatives such as “100% transparent” are highly risky unless you can instantly verify data across the entire supply chain.
Risk: Full transparency is rarely achievable without direct control over all tiers of suppliers.
Safer alternative:
👉 “We ensure full traceability of our cotton back to certified farms in India. A list of our direct suppliers is available via the QR code on the label.”
12. “Kinder to the planet.”
Comparative claims require a clear reference point.
Risk: It is unclear whether the comparison is against a previous version, competitors or the market average.
Safer alternative:
👉 “This packaging has a 20% lower carbon footprint compared to our previous generation of products (verified using LCA methodology).”
13. Misuse of nature symbolism (visual greenwashing)
Regulation looks at overall impression, not just wording. Images of pristine landscapes or green leaves on products without substantiated benefits increase enforcement risk.
Risk: Visual cues create a false perception of environmental benefit.
Safer alternative:
👉 Use design elements that reflect actual certifications or the real origin of ingredients (e.g. authentic photography of the specific herb used).
How to navigate the new anti-greenwashing rules
Under the new regime, it will no longer be enough simply “not to lie”. You must be able to prove your claims within days. To ensure your communication stands up to scrutiny:
Claim file documentation:
Create a documented evidence file for every environmental claim (certificates, OECD tests, ISO methodologies). No documentation, no claim.
Audit existing communication:
Review packaging, websites and social media. Either support generic terms like “eco” with hard data or remove them.
End of self-created labels:
Forget attractive leaf icons designed in-house. Rely only on recognised third-party certifications such as EU Ecolabel, FSC, or Ecocert.
Align internal teams:
Greenwashing often stems from misalignment between marketing and sustainability teams. Establish an internal glossary of approved terminology.
Honesty as a competitive advantage:
Admitting that you are still improving in certain areas builds far more trust than projecting unrealistic perfection.
Check your claims before the regulator does
Not sure whether your campaign or product description complies with the new rules? Avoid fines and reputational damage. We have developed the online tool Flagship Greenwashing Check to help you identify risk areas in your communication and suggest safer wording based on current legislation.
