Publication of RCI’s position paper on the Green Claims Directive proposal

This September, the Renewable Carbon Initiative (RCI) has released a position paper concerning the Commission’s Proposal for a Green Claims Directive (GCD) from March 2023

The proposed Directive seeks to establish consistent EU-wide rules for substantiating, communicating, and verifying voluntary green claims, with the ultimate goal of providing consumers and businesses with trustworthy environmental information. This initiative is geared towards enhancing environmental protection and promoting the transition to an eco-friendly, circular, and carbon neutral economy in the EU. Additionally, it aims to shield both consumers and businesses from deceptive environmental claims and labels, while empowering consumers to make well-informed purchasing decisions based on credible environmental data.

The Renewable Carbon Initiative (RCI) wholeheartedly endorses the Directive’s mission to provide consumers and businesses with reliable, comparable, and verifiable information to facilitate sustainable choices.

In our position paper, we emphasise three aspects that, in our view, require additional attention to maximise the impact of the GCD and support products and solutions derived from non-fossil, renewable-carbon-based feedstock from biomass, CCU or recycling.

  • 1. Science-Based Life-Cycle Assessment Methodologies: RCI welcomes the acceptance of several life-cycle assessment methods for substantiating environmental claims and emphasises the practical importance of maintaining flexibility in the upcoming trilogue negotiations. We also call for clarification on how to determine if an environmental impact is considered “significant.”
  • 2. Differentiated Biogenic Carbon Accounting Methodology: The RCI advocates for enabling the possibility to better reflect uptake of atmospheric CO2 via biogenic carbon (and principally any process that captures CO2 from the atmosphere) in product assessments. In general, biogenic carbon in LCA is neither credited with carbon uptake through biomass at the beginning nor with the emissions (e.g. from incineration) at end of life. While this is valid and recommended from a proper LCA point-of-view, it leads to issues for companies reporting their biogenic product’s carbon footprint at factory gate, because the uptake of atmospheric carbon cannot be shown and the conceptual advantage over fossil products gets lost. At the same time, we are aware of misleading “carbon negative” claims and argue that only full cradle-to-grave LCAs should qualify for such B2C claims.
  • 3. Ensuring a Reliable Verification Mechanism: Recognising the need for mandated verification of environmental claims before B2C communication, RCI acknowledges the potential challenges posed by these resource-intensive processes. We want to stress the importance of an efficient approach and an extended transition period to enable authorities, verifiers, and the industry to smoothly adapt to these processes and mitigate potential delays in communicating claims for innovative products.


Renewable Carbon Initiative, press release, 2023-09-11.


European Commission
European Union
Renewable Carbon Initiative (RCI)


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