What happened
The European Commission adopted its work programme for 2027 on 4 November 2026. Its Annex III lists 18 pending proposals the Commission intends to withdraw within six months, and number four is the proposed directive on substantiation and communication of explicit environmental claims, known as the Green Claims Directive. As Mark Segal reported for ESG Today, the proposal had been effectively paused since June 2025.
The Commission's reason, in the annex: the file has been pending for more than three years, the Council failed to agree a negotiating position in June 2024, attempts in 2025 to move it on did not succeed, and it is unlikely to win support in the Council within a reasonable time. The directive would have required businesses to substantiate environmental claims with evidence, have them independently checked before use, and limit new private eco-labels.
What it means for your business
The EU's other green claims law is already in force. Directive (EU) 2024/825, on empowering consumers for the green transition, applies in EU countries from 27 September 2026. It bans generic environmental claims such as "eco-friendly" without proof of recognised excellent performance, bans claims that a product has a neutral, reduced or positive environmental impact because of offsetting, and only allows sustainability labels based on a certification scheme or set by public authorities. What has gone is the extra layer of upfront independent checks.
In the UK nothing changes. The CMA's Green Claims Code still applies to every business that markets to consumers, and since April 2025 the CMA can fine a business up to 10% of its global turnover for breaking consumer law. Our guides on the Green Claims Code for small businesses and on how to word a net zero target cover the UK rules.
Wherever you sell, the safest claim is one backed by numbers you can show. A claim about cutting emissions is only as strong as the calculation behind it, and an easy slip is mixing your own savings with changes in the grid.
A worked example: checking an emissions claim
Take an illustrative UK maker that sells to EU customers. It used 60,000 kWh of electricity in 2024 and 48,000 kWh in 2026, and wants to tell customers its electricity emissions are down.
- 2024: 60,000 kWh × 0.20705 (2024 factor) = 12.42 tonnes CO2e.
- 2026: 48,000 kWh × 0.13096 (2026 factor) = 6.29 tonnes CO2e.
- Reported emissions fell by 49%, but its electricity use fell by 20%.
- The gap between 49% and 20% is the government's grid factor changing between 2024 and 2026, which the business did not cause. Its own saving is the 20% cut in kWh.
Both figures are correct for a carbon report, which uses each year's factor. In marketing, a fair claim says which one you mean, for example "we cut our electricity use by 20% between 2024 and 2026", and keeps the calculation on file.
What to do now
- List every environmental claim you make on packaging, your website and sales material, in the UK and in each EU market.
- Remove generic words and offset-based product claims in EU marketing, such as "eco-friendly" without proof or "climate neutral" based on offsets.
- Keep the numbers behind each claim: the kWh, fuel or materials, the factors and the years, so you can show it if asked.
- Separate your own cuts from grid changes when you compare years, as in the example above.
