Proposal COM(2023) 166
For sustainability and legal teams tracking the Green Claims Directive proposal and how it compares with the rules in force. This page covers what you need to know and ways to avoid running into issues.
What we've seen reported
The Green Claims Directive, proposal COM(2023) 166, would set rules for substantiating, communicating and verifying explicit environmental claims to consumers in the EU. It remains a proposal; the Commission said in June 2025 it meant to withdraw it.1,2
Last updated October 2026 · General information only, not legal advice. Sources.
What the rules cover
These are the kinds of claims the Green Claims Directive proposal describes, according to its text, and what it would expect behind each one.1
| Phrase or term | In practice |
|---|---|
| "Better for the planet", "lower impact" | Backed by an assessment using recognized scientific evidence and a life-cycle perspective. |
| "30% less CO₂ than our last model" | Comparisons built on equivalent data and methods, with improvements achieved in the last five years. |
| "Climate neutral", "CO₂ compensated" | Any offsets reported separately from emissions, saying whether they are reductions or removals. |
| "Made with recycled plastic" | Covering only the aspects assessed, and showing whether the claim fits the whole product or one part. |
| Environmental labels and scores | New private schemes approved before use; aggregated scores only where set at EU level. |
| "Independently verified" | Each claim checked by an accredited verifier before it appears in commercial communications. |
| "Learn more" behind a claim | The substantiation, the certificate of conformity and the verifier details available alongside the claim. |
Where it goes wrong
One approved claim ends up in many channels, markets and languages. Along the way it gets shortened, translated and reworded, and some versions end up using the very phrases you are trying to avoid.
"Aria 8 heat pump: 30% lower lifecycle emissions than Aria 7."
How Arbitr helps
Manually review everything? Or do what modern teams do and use AI to check that what you publish matches what you approved.
FAQ
Well beyond the pack. The Green Claims Directive proposal covers explicit claims in commercial communications to consumers,1 and we usually find them in:
Get them in order for the rules already in force. Directive (EU) 2024/825 applies from September 27, 2026,3 and one record per claim, with its evidence, owner and cleared markets, helps whichever way the proposal goes.
Our page on generic environmental claims covers the rules in force.
Treat the comparison as part of the approved wording. "30% lower than Aria 7" often becomes "30% lower" once it is shortened or translated, and the reference point disappears. Give translators the full comparison, its baseline and an approved short version for each language, then check your brand wording across markets.
How it applies to a specific claim is a question for your legal adviser. Where that claim appears across your markets and languages is a question Arbitr answers.
Usually sustainability and legal, but marketing, packaging and e-commerce publish the claims, and agencies and retailers republish them. A shared note on where the proposal stands, kept next to your approved claims list, keeps everyone working from the same picture. Rules in other markets are on our environmental claims hub.
Not formally, according to the European Parliament's Legislative Train. The Commission announced on June 20, 2025 that it intended to withdraw the proposal, and its 2026 work program, adopted October 21, 2025, lists it as pending.2
They're two different texts that headlines often merge. The ECGT Directive, Directive (EU) 2024/825, was adopted in February 2024 and applies from September 27, 2026.3 The Green Claims Directive is a separate proposal that has not been adopted.2
No. Your reviewers stop reading everything and read only what has been flagged, with the rule and the reason attached.
