Is the material B2C advertising, a product label, e-commerce content or a corporate statement? Check relevant EU, national and sector-specific obligations.
BuVNK · Green Claims · Practical business guidance
Green Claims Checklist 2026: 10 Checks Before You Advertise
This free BuVNK checklist helps marketing, product and compliance teams review environmental claims before publication, with practical examples, warning signs and official EU sources.
10 practical checksEmpCo law in 2026Official EU sources
Legal status as of 14 October 2026: Directive (EU) 2024/825 (EmpCo) applies from 27 September 2026 and amends EU consumer protection rules. The separate Green Claims Directive (COM(2023) 166) remains a legislative proposal, not an adopted EU law; it does not currently create a general duty to have every green claim pre-certified. This checklist provides practical orientation, not legal approval.
01 / Practical review
10 checks to make before publication
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Record the precise wording, imagery, iconography, hashtags and placement. Consider how the average consumer may interpret the combined message.
Does the claim concern the whole product, its packaging, one material, one site or one activity? Avoid implying an overall benefit from a limited characteristic.
For terms such as “green”, “eco-friendly” or “environmentally friendly”, assess the strict EmpCo conditions for generic environmental claims. Prefer specific, substantiated statements.
Keep measurements, test results, relevant standards and calculation methods, including dates, geography, system boundaries and uncertainties.
If claiming “30% lower CO₂”, identify the baseline, comparison product, unit, reference period and methodology. Document the data and its limitations.
Do not base product claims of neutral, reduced or positive greenhouse-gas impact on emissions offsetting outside the product value chain. Distinguish factual investments in climate initiatives.
Establish whether a label is based on an appropriate certification scheme or established by public authorities. Record its scope, rules and independent oversight.
For “net zero by 2030”, examine clear and verifiable commitments, a realistic plan, measurable interim targets, resources and independent verification.
Assign owners, approval records, evidence packs and review dates. Reassess claims whenever underlying products, evidence or messages change.
02 / Legal framework
What already applies – and what remains proposed?
Applicable rules: EmpCo
Directive (EU) 2024/825 strengthens rules covering generic environmental claims, offset-based product climate claims and sustainability labels. Applying them in practice also requires checking relevant national law and the individual circumstances.
Not yet an adopted law: Green Claims Directive
The separate COM(2023) 166 proposal on substantiating and communicating explicit environmental claims has not been adopted. Suggested pre-verification requirements must not be described as generally binding today.
03 / Examples
Recognise risks and improve claim precision
High risk without credible evidence
“100% environmentally friendly” or “climate-neutral product” based solely on the purchase of carbon credits. Such claims may be vague, misleading or expressly prohibited.
A more verifiable approach – still review the facts
“The packaging contains 30% recycled plastic by total weight of plastic components; as of September 2026.” This still requires reliable supporting data and an accurate denominator.
04 / Frequently asked questions
Green Claims checklist FAQ
Is the Green Claims Directive binding in 2026?
No. As checked on 14 October 2026, the separate legislative proposal remains pending. Existing unfair commercial practices rules and applicable EmpCo requirements must be distinguished from it.
Must every environmental claim be certified today?
No general pre-certification requirement for every green claim follows from the pending proposal. Specific products, schemes or regulated sectors may be subject to separate obligations.
Are purchased carbon offsets enough for a “climate neutral” product claim?
EmpCo specifically prohibits product claims of neutral, reduced or positive greenhouse-gas impact when based on offsetting. Other claims about climate investments must still avoid misleading consumers.
Is an internal checklist sufficient?
This checklist supports internal screening; specialist review may be appropriate for complex claims, labels or higher-risk communications. It is not a legal opinion.
05 / Official sources
Primary EU reference materials
- Directive (EU) 2024/825 – EmpCo / EUR-Lex
Binding directive text, definitions and prohibited practices - European Commission – Sustainable consumption
EmpCo application date and guidance - European Commission – Green claims
Objectives and scope of the separate proposal - EUR-Lex – Procedure 2023/0085/COD
Status of the Green Claims legislative proposal
This page is general guidance, not binding legal advice. Product-specific and national rules must be assessed separately.
Review your claims – and understand the bigger picture
BuVNK provides independent information on environmental marketing, greenwashing, EmpCo and related EU requirements. Explore the knowledge pages and consult the relevant original sources.