No Greenwashing, please!

Key Take Aways from the Green Claims Directive for Communications and Marketing

Marketing terms such as “climate neutral”, “recyclable” or self-created environmental labels are increasingly common on consumer goods, but so far only few come with scientific proof. With the Green Claims Directive (GCD) the EU wants to change this practice. The goal is to provide more consumer protection and fair market transparency, yet at the same time companies find themselves confronted with a new burden of regulations they need to understand.

Environmental-friendly messaging from a consumer perspective

In 20141 and 20202, the European Commission initiated two comprehensive studies based on the Unfair Commercial Practices Directive. Both surveys confirmed that around 53% of all environmental claims on products were based on vague or false information and even 40% of all environmental claims did not provide verifiable evidence. This was reason enough for the Commission to issue a further investigation as part of the Sweeps project3 in which the websites of several companies were examined for misleading sustainability claims and this again confirmed the previous results.

The huge variety of vague, misleading and unfounded green claims in combination of what consumer or NGOs often call an irritating jungle of green labels they don´t understand undermines consumer trust. This is something companies should take seriously. If costumers don´t believe in the intention of companies to provide products and services of the highest possible standard they might have a reason to doubt the quality and credibility of these companies at all. That´s where communications activities usually come in bridging the gap between consumer expectations and business requirements in order to gain back consumer´s trust.

Green Claims falling under the GCD proposal

However, what exactly is considered to be a green claim? According to the GCD proposal an environmental claim is defined as “any message or representation, which is not mandatory under Union law or national law, including text, pictorial, graphic or symbolic representation, in any form, including labels, brand names, company names or product names, in the context of a commercial communication, which states or implies that a product or trader has a positive or no impact on the environment or is less damaging to the environment than other products or traders, respectively, or has improved their impact over time”4.

With this in mind marketing and communication professionals basically must consider any voluntarily written, spoken or visual activity in environmental context to be falling under the planned GCD legislation – if the GCD proposal will be approved. And at that point the GCD states clearly: Green claims are expected to relate to the whole product and not just certain aspects, provide scientific proof for a given environmental information, validate all mentioned environmental impacts with life-cycle assessments and provide transparent and specific information on carbon offsetting. In the end all environmental claims are to be approved by an independent, officially accredited independent organisation.

A new era of sustainability communications on the horizon

From a communication perspective these obligations seem like a herculean task with no change of ever reaching the goal. Think of all the product leaflets and brochures, websites and newsletters, press mailings, speeches, social media and advertising activities – not to mention the annual and sustainability reports – that need to be checked and revised in detail. But it is not only a communicative challenge. In fact, the GCD is all about how to substantiate environmental information before you communicate. That´s where scientific proof comes in as the one solid cornerstone of validation.

At that point companies are at a crossroad: either they decide to do as little as possible hoping of not getting recognized and criticized or they accept the challenge and take the GCD as the opportunity as it is. With the first one companies may save time and money in the short run, but expose themselves to an ongoing insecurity that implies significant reputational, crisis and mitigation risks. Leading companies like Coca-Cola, Danone and Nestlé, for instance, have just been accused of misleading claims on their plastic packing.5 Given that member states will soon be able to impose fines, confiscate profits, and exclude business from public procurement for up to 12 months, future damage can be even worse than just public accusation.

Take the change and substantiate your communication

But if companies choose the latter option, they can start to use the GCD as something that goes far beyond communications. In fact, GCD requirements will help to substantiate all environmental-related communicative activities of a business and give a competitive advantage to those who develop environmental products or services with scientific proof. In the long run companies, that comply with the GCD rules will then have trade-offs across borders, competitional advantages in national markets and a clear, valid sustainability messaging for consumers. In the end, this is expected to save costs and to provide necessary competitive and communicative advantages.

For more information, please contact Stefanie Fulda (Head of the Communications Department):


1 European Commission (2014) Consumer Market Study on Environmental Claims for Non-Food Product. Download at:
2 European Commission (2020) Environmental claims in the EU: Inventory and reliability assessment, Final report. Download at:
3 European Commission (2020) Sweep on misleading sustainability claims (Durchforstung von Websites zu irreführenden Nachhaltigkeitsaussagen), Sweeps ( Download at:
4 European Commission (2023) Proposal for a Directive of the European Parliament and of the Council on substantiation and communication of explicit environmental claims (Green Claims Directive). 2023/0085 (COD) Official Journal of the European Union (Ed.), 2023-03-22. Download at:
5 Simon, F. & Taylor, A. 2023: Bottled drink firms attacked over misleading green claims. 2023-11-07.


nova-Institut gmbH, press release, 2023-12-13


Alice Taylor
European Commission
European Parliament
Frédéric Simon
nova-Institut GmbH


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