Green Claims is on the withdrawal list. The ban on generic environmental claims stays.

The proposed Green Claims Directive is on the European Commission’s list of pending proposals for withdrawal. The Commission intends to withdraw it within six months, which by our calculation means roughly early May 2027. The ban on generic environmental claims made to consumers stays in place, because it comes from a different act that has already been adopted and applies from 27 September 2026. It also covers manufacturers of textiles, furniture, construction products and steel when their claims reach consumers.

If Green Claims were withdrawn, the check before use that the proposal provided for would fall away. Under the current rules nobody tells you in advance that a claim is fine, and the evidence has to be in your hands on the day the enforcement authority asks for it.

The withdrawal of the Green Claims proposal has been announced but has not yet happened

The Green Claims proposal, COM(2023) 166 final, 2023/0085(COD), is item 4 in Annex III to the European Commission’s 2027 work programme, COM(2026) 710 final, adopted on 4 November 2026. The annex lists 18 pending proposals, and a footnote states that the Commission intends to withdraw them within six months. By our calculation that means roughly early May 2027.

The Commission’s stated reasons are that the co-legislators have been examining the text for more than three years, that the Council presidency’s attempts in 2025 failed, and that the proposal is unlikely to win the Council’s support within a reasonable time. The reasons mention no replacement proposal. Whether parts of the text will return in another one is not known.

An intention is not yet a withdrawal. In the European Parliament’s terminology for procedure status, a proposal counts as “withdrawn” only once the withdrawal has been published in the Official Journal. Headlines with words like “scrapped” are getting ahead of events.

The Commission has announced this intention once before, on 20 June 2025, and the interinstitutional talks (trilogue) scheduled for 23 June 2025 were cancelled. The 2026 work programme, COM(2025) 870, still listed the proposal as pending. This time the intention is set down in an adopted Commission document, with a time limit attached. We keep the chronology on our regulatory changes page.

Withdrawing Green Claims would remove the check before use

The Green Claims proposal was placed on the withdrawal list on 4 November 2026. On withdrawal, the check by an independent body before use would fall away with it. The text of 22 March 2023 would have required explicit environmental claims to be substantiated with recognised scientific evidence, taking the life cycle into account, and to be verified by an accredited independent body before they were used. Directive (EU) 2024/825 contains no such check.

Without that check you have one procedure fewer, but no independent body will tell you before the catalogue goes to print whether a claim holds up. The current rules offer no such answer: no authority approves claims in advance.

Enforcement comes once the product is on the market, and it falls to the national consumer protection authority. Whether the evidence is good enough remains your call until someone asks to see it.

Directive 2024/825 cannot be on the withdrawal list, because it has already been adopted

Directive (EU) 2024/825, known as the Empowering Consumers Directive, applies from 27 September 2026. The list in Annex III to the 2027 work programme covers pending proposals, so an adopted act cannot appear on it and the directive is unaffected.

The directive adds new practices to the EU blacklist of unfair commercial practices. One of them is the generic environmental claim (“eco-friendly”, “green”) where the trader cannot show recognised excellent environmental performance. We have set out the six practices that concern environmental claims in detail, along with what changed on day one and where.

The directive is applied through national law. Member states had until 27 March 2026 to transpose it, and it applies from 27 September 2026. On 28 May 2026 the Commission opened infringement procedures against 20 member states for failing to communicate complete transposition. The rules travel with the market you sell into, so goods sold to consumers in another member state fall under that country’s national rules.

The EU rule on penalties is Article 13(3) of Directive 2005/29/EC. Where penalties are imposed under Article 21 of Regulation (EU) 2017/2394, which governs coordinated action on widespread infringements, the maximum fine must be at least 4% of the trader’s annual turnover in the member state or member states concerned. That 4% is the lowest level at which the maximum can be set. It is neither a minimum penalty nor a share of global turnover, and the size of an individual fine is decided nationally.

Names are in scope too. The directive’s definition of “environmental claim” covers brand names, company names and product names, and the Commission’s Q&A says that “eco” or “green” in a brand or product name may constitute an environmental claim.

Does the ban on generic environmental claims affect a manufacturer that sells through a retail chain?

Directive (EU) 2024/825 concerns dealings with consumers (B2C). On our practical reading, a manufacturer that sells through a retail chain is affected by the rules from 27 September 2026 as well: we expect the retailer making the claim to the consumer to ask the manufacturer for the data.

Corporate websites with mixed content for consumers and businesses probably fall within scope if they address consumers, the European Commission says in its non-binding Q&A.

Behind a specific claim sit verified composition, measured recycled content, environmental footprint, and durability and repair data. Data of this kind will probably also go into the Digital Product Passport under the ESPR: the delegated act for textiles is expected around 2027 and the requirements for furniture around 2028. A company that puts this data in order for its claims will have at least part of it ready for the passport.

The passport and the EU registry do not, however, check whether a claim is true, so having a passport does not prove it.

What to keep for every environmental claim before the authority asks for evidence

The national consumer protection authority enforces the new prohibitions in Annex I to Directive 2005/29/EC once the product is on the market. So for every claim, keep a record of:

• the exact wording;
• where it appears, including the product name and the catalogue;
• the date it was used;
• the document behind it;
• the name of the person responsible in the company.

Here is an example, invented for this article. “Eco-friendly mattress” is a generic claim. “Cover made from 60% recycled polyester” is specific and can be checked, provided you keep the document for the batch in question. It applies only to the cover, though, and not to the whole mattress. Presenting a claim about part of a product as a claim about the whole product is another of the prohibited practices.

The date matters because enforcement comes after the product is on the market, and in our view what data you held on the day the claim was used will count. That is why our platform writes every change to a passport to an append-only audit trail. The trail shows what was recorded and when; it does not prove that the claim is true. You can keep the same discipline in an ordinary spreadsheet, as long as old rows are never rewritten.

If the national consumer protection authority asked tomorrow for the evidence behind the environmental claim on your best-selling product, which document would you send, and what date would it carry?

You can see what organised product data looks like in our demo passports.

Sources: COM(2026) 710 final, Annex III, item 4; COM(2025) 870; COM(2023) 166 final; Directive (EU) 2024/825; Directive 2005/29/EC, Art. 13.