What changes
- Generic claims are out. “Eco-friendly”, “green”, “climate-friendly” without recognised, demonstrable performance behind them become unfair commercial practices.
- Sustainability labels need a certification scheme or a public-authority basis. Self-made labels are not allowed.
- Offset-based climate neutrality claims are banned. “Carbon neutral through offsetting” cannot be used for a product.
- Future claims need a plan. “Net zero by 2030” must come with a detailed, verified implementation plan.
The separate Green Claims Directive proposal was withdrawn in 2025; the Empowering Consumers Directive is the law that applies.
Where packaging comes in
PPWR adds its own claim rules: recycled-content and bio-based claims on packaging must follow the EU calculation method (Article 12(4)), and labels must not mislead about recyclability. From 2028, the harmonised sorting label replaces national schemes. A recycled-content figure you print needs the same supplier evidence as your PPWR technical file.
How to substantiate a climate claim
A product carbon footprint calculated under ISO 14067 and the GHG Protocol Product Standard, with an open methodology, traceable data, and a change log, is the evidence base. Comparative claims (“30% lower than last year”) need the same method on both sides of the comparison. CarbonCloud footprints are built for exactly this: every number is traceable to its inputs and every input has a source.
Sources: Directive (EU) 2024/825; Regulation (EU) 2025/40 Art. 12. This guide is not legal advice.