Green Claims: How to Make Them and Actually Back Them Up

Key Takeaways

Over half of all environmental claims in the EU have been found to be vague, misleading, or unverified, making substantiation a legal as well as reputational priority.
The Empowering Consumers for the Green Transition Directive (ECGT) is already law, banning generic environmental claims and offset-based “climate neutral” product labels from September 2026.
A global survey revealed that 91% of consumers believe at least some brands engage in greenwashing, indicating widespread distrust in environmental marketing claims.
Life Cycle Assessment (LCA) following ISO 14040/44 is the method regulators and scientists consistently point to for substantiating product-level green claims with credible, comparable data.
Knowing where your emissions come from, raw materials, manufacturing, packaging, use phase, is the first step to making claims that are both accurate and defensible.

The Problem With “Eco-Friendly”

“Eco-friendly.” “Sustainable.” “Climate positive.” These phrases appear on packaging, websites, and social media every day. Most of them are unsupported. An EU study found that over half of environmental claims are vague, misleading, or unverified. That is not a minor compliance footnote. It is a systemic credibility problem, and one that regulators and consumers are increasingly unwilling to tolerate.

Green claims, in the regulatory sense, are any explicit or implied statements about a product’s environmental benefits: from “made with recycled materials” to “carbon neutral” to “lower environmental impact.” The challenge is that these phrases carry real weight with consumers while costing almost nothing to print on a label. The gap between what is stated and what can be proven is where trust collapses.

Over half of UK consumers are prepared to boycott brands over misleading green claims, with almost one in five having already changed their purchasing decisions due to greenwashing. Brands that treat sustainability language as marketing copy rather than verifiable fact are not just taking a legal risk. They are eroding the very consumer trust that sustainability positioning is supposed to build. Research using Structural Equation Modeling has revealed that greenwashing has a significant negative impact on both consumer trust (β = -0.68) and brand loyalty (β = -0.45).

The Regulatory Landscape in 2026

The policy environment around green claims has shifted considerably. The original EU Green Claims Directive proposal, which would have required third-party verification of all voluntary environmental claims before they could be published, has been paused. In June 2025, the European Commission announced its intention to withdraw the proposal, effectively putting it on hold amid political concerns about administrative burden on small businesses.

But the withdrawal of that specific proposal does not mean the pressure is off. Far from it.

The Empowering Consumers for the Green Transition Directive (ECGT) is already law, banning generic environmental claims and offset-based “climate neutral” product labels from September 2026. The ECGT amends the EU’s Unfair Commercial Practices Directive by adding new banned practices to the blacklist, with the most relevant being generic environmental claims without recognised excellent environmental performance: terms like “environmentally friendly,” “climate friendly,” “green,” or “biodegradable” are prohibited unless you can demonstrate outstanding, relevant performance that has been certified or officially recognised.

Any claim that a product has a “neutral, reduced or positive impact in terms of greenhouse gas emissions” when it is based on offsetting is flatly banned. For companies that have been relying on carbon offset purchases to underpin their “carbon neutral” badges, this requires an immediate rethink.

The financial stakes are concrete. Fines for noncompliance can be up to 4% of a trader’s annual turnover in the relevant EU Member State, or more if the relevant Member State sets a higher maximum under national law. The relevant consumer laws are also in scope of the EU’s Representative Actions Directive, which allows claimants to bring class-action-style claims in the EU based on noncompliance with these obligations.

For a deeper breakdown of what the regulatory framework specifically requires and how penalties work, see EU Green Claims Directive Explained and EU Green Claims Penalties Explained.

Why Vague Claims Always Backfire

There is a temptation to think that softening language reduces risk. If you write “more sustainable” instead of “sustainable,” or “lower impact” instead of “zero impact,” surely that is harder to challenge? Not really. Vague terms such as “green,” “eco-friendly,” or “sustainable” cannot be used without clear explanation and objective evidence. Businesses must be able to demonstrate what the claim covers and how it has been assessed.

The real problem with vague claims is not just legal. It is strategic. Consumers are more literate about environmental marketing than brands tend to assume. More consumers are becoming sceptical of environmental claims and are questioning whether companies are motivated by actual responsibility or simply attempting to manage their image. Results show that consumers are becoming more sensitive to environmental claims, and the perceived honesty and openness of those claims is a major factor in whether they will trust a brand.

There is also a compounding effect: when a brand is exposed for greenwashing, the damage extends beyond that brand. Research across European markets confirms that experienced, environmentally aware consumers lose trust when they suspect greenwashing, and that such consumers become more doubtful about all sustainability claims, not just those of the offending brand.

What “Substantiation” Actually Requires

So what does it mean to properly substantiate a green claim? At minimum, it means knowing where your product’s actual environmental impact comes from, expressed in quantitative terms, calculated using a recognised methodology such as Life Cycle Assessment.

This is where the numbers become genuinely instructive, and often surprising.

Take a t-shirt. You might assume the biggest environmental lever is the choice of material. But according to Devera’s ISO 14040/44 LCA benchmark data, manufacturing alone accounts for 60.1% of a t-shirt’s carbon footprint, with raw materials contributing 23.5% and the use phase (washing, drying) adding 11.8%. The median footprint sits at 3.01 kg CO₂e per garment, ranging from 2.12 to 4.12 kg CO₂e. A brand claiming “sustainable cotton” as its headline green credential is addressing less than a quarter of the actual problem. That kind of selective framing is exactly what regulators mean by a misleading claim, not because the statement is false, but because it implies a greater environmental benefit than the full lifecycle picture supports.

Compare this with a body cream, where you might assume packaging is the dominant concern. Devera’s benchmark data tells a different story: raw materials account for 47.7% of a body cream’s carbon footprint, nearly triple the packaging contribution of 17.1%, with manufacturing adding 24.1%. The median footprint is 2.50 kg CO₂e, with a wide range of 1.78 to 3.85 kg CO₂e depending on formulation and sourcing. For a cosmetics brand, a green claim focused purely on “recyclable packaging” captures less than one-fifth of the actual impact. That is not nothing, but it is not the whole story either, and regulators increasingly expect the whole story.

The pattern is consistent across categories. For a wine bottle, raw materials dominate at 52.4%, followed by manufacturing at 38.9%, with transport contributing just 5.5%. A wine producer that positions itself on “local distribution” is highlighting the smallest slice of its footprint. Meanwhile, the median bottle generates 1.89 kg CO₂e, and the spread from 1.54 to 2.29 kg CO₂e suggests that the choice of glass weight and vineyard energy source matters far more than the last mile.

For safety-critical industrial products, the picture is equally revealing. Devera’s data for a safety equipment container shows raw materials driving 57.5% of impact, with a median of 4.47 kg CO₂e per kilogram. A manufacturer focusing green claims on “optimised manufacturing” is addressing 35.9% of the problem while the majority lies upstream. Switching to recycled polymer inputs would have a greater impact than any process improvement, and that is the kind of specific, directional claim that is both honest and compelling.

For electronically-intensive products, the calculus changes entirely. A laptop’s footprint of 215.10 kg CO₂e median, ranging from 157.88 to 286.70 kg CO₂e, is driven primarily by the use phase at 38.3%, followed closely by raw materials at 36.5%. A laptop brand claiming “sustainable manufacturing” is speaking to 24.7% of lifetime impact. Designing for energy efficiency or longevity would have roughly three times the effect.

The point is not to shame any particular kind of claim. It is to illustrate that without LCA data, brands routinely make green claims that emphasise the wrong phase of the lifecycle, not out of bad faith, but out of ignorance of where the impact actually lives.

What Makes a Green Claim Credible

Credibility has a few non-negotiable components in the current regulatory environment.

Scope matters. A claim should specify what it covers. “Lower carbon footprint in manufacturing” is more credible than “lower carbon footprint” when the data only covers one phase. Precision protects you.

Methodology matters. Claims must rely on widely recognised scientific evidence, use accurate information, and take into account relevant methods and international standards. ISO 14040/44 and ISO 14067 are the frameworks regulators recognise for product carbon footprint claims. Proprietary or internal methodologies are much harder to defend.

Comparability matters. Saying your product is “30% lower carbon” requires a defined baseline and a clear explanation of what was compared. Statements like “net zero by 2035” must be backed by a clear implementation roadmap, measurable targets, and monitoring mechanisms. Future claims without a credible plan are now explicitly in scope of consumer protection enforcement.

Verification matters. For future environmental claims and sustainability labels, third-party verification will be necessary. Even where the ECGT does not yet mandate pre-verification for all claims, having independent review of your methodology is the clearest way to demonstrate good faith.

For brands working through what all of this means for specific product categories, Sustainable Cosmetics: From Claim to Proof in 2026 is a useful starting point, and 12 Best Ways to Avoid Greenwashing and Comply With the Green Claim Normative offers practical, step-by-step guidance.

From Claim to Proof: The Role of LCA

Life Cycle Assessment is not just a compliance tool. When done well, it reframes how brands think about their products entirely. The phase breakdowns reveal where reduction efforts will have the most leverage, and where superficial changes will have the least.

The grades in Devera’s benchmark data illustrate this clearly. A laptop scoring below 176.3 kg CO₂e earns an A grade, while one above 259.63 kg CO₂e lands at D. That 103 kg CO₂e gap between the best and worst performers is not random: it reflects real decisions about component sourcing, energy efficiency, and expected product lifespan. A brand with an A-grade product has a genuinely defensible claim. A D-grade product claiming “sustainable” has a significant exposure.

The same principle applies across every category. The range for a body cream runs from 1.78 to 3.85 kg CO₂e, more than a twofold difference, entirely driven by choices made in formulation and supply chain. That variance is the story green claims should be telling.

Calculate your product carbon footprint to see where your product sits within its category benchmark, what your score grade is, and which phases offer the highest-impact reduction opportunities.

Frequently Asked Questions

What are green claims in a regulatory context? Green claims are any explicit or implied statements a business makes about the environmental benefits of its products, services, or operations, covering everything from “made with recycled materials” to “carbon neutral” to “environmentally friendly.” In the EU, these claims are governed by consumer protection law, including the Empowering Consumers for the Green Transition Directive, which applies from September 2026 and bans vague, unsubstantiated environmental language.

How do you substantiate a green claim under EU law? Substantiation requires quantitative evidence calculated using a recognised scientific method, such as Life Cycle Assessment following ISO 14040/44. The evidence must cover the relevant lifecycle phases, use accurate and up-to-date data, and be made available to consumers, for example via a QR code or web link. Claims based solely on carbon offsets are banned under the ECGT for product-level neutrality assertions.

What happens if a brand makes an unsubstantiated green claim? Under the ECGT, which applies from 27 September 2026, fines can reach up to 4% of annual turnover in the relevant EU Member State, with some national laws setting higher maximums. Brands can also face class-action-style representative actions under the EU’s Representative Actions Directive. Beyond legal penalties, the reputational damage from a greenwashing exposure can reduce consumer trust and purchase intent significantly.

Why is Life Cycle Assessment the right method for backing green claims? LCA is the only methodology that captures a product’s environmental impact across its full lifecycle, from raw material extraction through manufacturing, transport, use, and end of life. This matters because the phase that drives the most impact is often not the one brands intuitively focus on. Without LCA data, claims risk being technically true but contextually misleading, which is precisely the kind of selective framing that regulators now explicitly target.