Getting Ready for the Green Claims Directive: How C2C Certified® Helps You Communicate with Confidence

Environmental claims are no longer optional marketing add-ons – they are becoming a matter of compliance and credibility. With the upcoming EU Green Claims Directive* (GCD), companies will need to back up every environmental statement with solid evidence. The aim is clear: protect consumers from greenwashing, create a level playing field for businesses, and ensure that sustainability claims are reliable, comparable, and verifiable.

At Vugge til Vugge, we know that not all certifications provide the same level of assurance. Cradle to Cradle Certified® offers one of the strongest and most holistic foundations for substantiating environmental and social claims. Its rigorous framework ensures that claims can stand up to the highest level of scrutiny – exactly what the Directive requires.

The Green Claims Guidance, prepared by the Cradle to Cradle Products Innovation Institute (C2CPII), explains how the Directive works and how C2C Certified® can support companies in meeting its requirements. As an accredited assessment body of the Institute, we summarise the key points here and invite you to consult the full guidance on the Institute’s website.

What is the Green Claims Directive?

The Green Claims Directive is part of the European Union’s agenda to make sustainable consumption the norm. The official proposal is titled:

Directive of the European Parliament and of the Council on the substantiation and communication of explicit environmental claims (COM(2023)166 final, procedure 2023/0085 COD).*

It specifically targets voluntary environmental claims and labels relating to a product or company’s environmental impact, performance, or practices.

• Scope: The Directive focuses only on environmental claims, not the broader ESG spectrum. It regulates statements such as “carbon-neutral,” “100% recyclable,” or “made from recycled materials” — ensuring they are specific, substantiated, and independently verified.

• Who it applies to: All companies operating in or selling to the EU single market (with exemptions for microenterprises with fewer than 10 employees and turnover below €2 million).

• Timeline: The Directive is expected to be finalized in 2025, with Member States required to transpose it into national law and apply it 24 months later.

• Why it matters: Companies will need to rely on robust, science-based methods and third-party verification to support their environmental claims.

How Cradle to Cradle Certified® Supports You

For companies preparing for the Directive, Cradle to Cradle Certified® offers a unique advantage:

The scope of Cradle to Cradle Certified® is holistic, covering five categories – Material Health, Product Circularity, Clean Air & Climate Protection, Water & Soil Stewardship, and Social Fairness. This means claims are not only specific but also consider potential trade-offs across environmental and social dimensions.

Examples of clear, verifiable claims include:

• “Our product contains 75% of recycled polyester.”

• “The packaging is fully recyclable after removing the plastic handle.”

• “This T-Shirt is made of 30% organic cotton.”

By contrast, vague and misleading claims such as “environmentally-friendly,” “eco,” “climate-neutral,” or “our product is sustainable” will no longer be acceptable.

Key Principles for Making Green Claims

The Directive outlines a set of principles that every environmental claim must meet. To make these principles more tangible, here are a few examples of how they work in practice:

1. Be specific – Always state clearly what the claim refers to.

Correct: “This packaging is made of 75% recycled paper.”

Incorrect: “The packaging is recyclable.”

2. Provide scientific evidence – Claims must be backed with data and recognized certification.

Correct: “Our panels are made from 100% recycled materials tested for potential contaminants against the X analytical test.”

Incorrect: “This product does not harm the environment.”

3. Consider the full lifecycle – Look beyond one single aspect of performance.

Correct: “Our company develops durable packaging solutions that withstand temperature fluctuations and harsh conditions during transportation, ensuring product freshness and extending shelf life.”

Incorrect: “Our product is environmentally friendly because it uses biodegradable packaging.”

4. Go beyond legal compliance – Demonstrate achievements that exceed the minimum required by law.

Correct: “Our LED light bulbs use 50% less energy than the industry standard.”

Incorrect: “My product is made with materials from countries where no child labor is involved.”

5. Be transparent on GHG emissions – Distinguish clearly between reductions and offsets.

Correct: “Between 2020 and 2023, we reduced our operational GHG emissions by 55% through electrification and solar panels. To address the remaining emissions, we purchased offsets from the Verified Carbon Standard program.”

Incorrect: “Carbon neutral, climate neutral, 100% CO2 compensated.”

Communicating Clearly with Consumers 

The Directive also regulates how claims are communicated. For example:

• If the claim relates to the use phase, consumers must be told how to achieve the benefit:

• Correct: “Our energy-efficient washing machine reduces water and electricity usage by 30%. To achieve these savings, use the machine with full loads and select the eco-wash setting.”

• If the claim relates to future performance, it must be measurable and time-bound:

• Correct: “By 2025, we commit to reducing our water usage across all operations by 40%, and ensuring that 100% of our wastewater is treated and reused.”

Supporting studies, standards, certifications, and assumptions will also need to be disclosed in an accessible way — for example via QR codes or online links.

Enforcement and Penalties

Each Member State will appoint an authority to enforce the Directive. Non-compliance will come with serious consequences, including:

• Fines – up to 4% of annual revenue in the affected country.

• Confiscation – of revenue gained through misleading claims.

• Bans – exclusion from government contracts for up to a year.

Beyond Environmental Claims: Supporting Broader ESG Efforts

While the Green Claims Directive focuses narrowly on environmental communication, companies are also preparing for broader regulatory requirements such as the Corporate Sustainability Reporting Directive (CSRD), which covers the full ESG spectrum.

We explored this in more depth in our earlier article on how C2C Certified® supports companies in meeting CSRD and other ESG obligations. Read the article here.

Download the Full Guidance 

This article is a summary of the main requirements. The full Green Claims Guidance, developed by the Cradle to Cradle Products Innovation Institute, provides in-depth explanations, detailed examples, and links to recognized standards. 

👉 Download the full Green Claims Guidance here and see how C2C Certified® can help your company prepare for the Directive – and build trust with claims that are transparent, verifiable, and future-proof.

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* Official reference: Proposal for a Directive of the European Parliament and of the Council on the substantiation and communication of explicit environmental claims, COM(2023)166 final, procedure 2023/0085 (COD). Read the full Directive on EUR-Lex: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:52023PC0166