Replace broad green adjectives with a defined, evidenced fact
Directive 2024/825 gives examples of generic claims such as environmentally friendly, eco-friendly, green, climate friendly, biodegradable and biobased. A generic claim is prohibited where recognised excellent environmental performance relevant to the claim cannot be demonstrated. Adding leaves, green colours or nature imagery can also contribute to an implied claim, so the review is not limited to written slogans.
Specific wording is safer only when it is accurate, prominent and verifiable. The Directive contrasts “climate-friendly packaging” with a specific statement such as all energy used to produce the packaging coming from renewable sources. Even a specific statement remains subject to the rest of consumer law, so evidence, scope, period and calculation method still matter.
- Delete undefined “eco” and “green” copy
- State the measurable attribute and packaging component
- Keep the evidence current and available
- Review imagery, icons and brand names for implied claims
Do not turn a packaging fact into a whole-product claim
A recycled paper box does not prove that the product inside is made from recycled material or that the whole product is sustainable. Directive 2024/825 prohibits environmental claims about an entire product or business when they concern only one aspect or an unrepresentative activity. Place packaging facts next to packaging language and avoid a headline that changes their scope.
Use precise nouns: outer carton, paperboard sleeve, insert or total packaging by weight. If only the folding carton is FSC-certified or contains a stated recycled fibre share, do not extend that statement to a plastic tray, the product or the entire company. Evidence should use the same boundary as the artwork.
- Name the exact component covered
- Separate product claims from packaging claims
- State weight or calculation basis where relevant
- Do not imply one SKU represents the full portfolio
Remove offset-based climate-neutral product claims and check labels
The Directive prohibits claims, based on greenhouse-gas offsetting, that a product has a neutral, reduced or positive climate impact. Examples include climate neutral, CO2 neutral certified, carbon positive and climate compensated. A company may still communicate investments in environmental initiatives when the information is not misleading and follows EU law, but that communication should not be converted into a neutral-product badge.
Voluntary sustainability labels must be based on a certification scheme or established by a public authority. A self-created leaf seal that looks like third-party approval can therefore create risk. For FSC or another scheme, confirm chain-of-custody status, logo approval and the exact claim before artwork release; possession of a material invoice alone does not authorise every label.
- Remove offset-based neutrality badges from product packaging
- Verify scheme owner, certification and logo approval
- Do not create a seal that implies independent verification
- Keep approved artwork and authorisation records together
Environmental packaging wording: risk and rewrite direction
These are drafting directions, not pre-approved claims. Final wording needs evidence and a destination-market legal review.
| Draft wording | Main risk | Better information direction | Evidence needed |
|---|---|---|---|
| Eco-friendly packaging | Generic environmental claim | Name a specific material or measured attribute | Relevant recognised performance or specific substantiation |
| Sustainable product | Scope may rely only on the box | State the exact outer-carton property | Component-level data |
| Climate-neutral box | Offset-based neutrality claim may be prohibited | Report a verified operational fact without product neutrality | Method, boundary and non-misleading context |
| Our green certification | Label may not come from a valid scheme | Use an authorised scheme mark only | Certification and artwork approval |
| 100% recyclable | Absolute claim may exceed available evidence | State assessed component and applicable system | PPWR/category method and destination evidence |
Add the PPWR Article 14 test to every packaging claim
PPWR Article 14 addresses environmental claims about packaging properties for which PPWR sets legal requirements. Such a claim may be made only for performance beyond the applicable minimum requirement and must specify whether it concerns the packaging unit, part of the unit or all packaging placed on the market by the operator. Compliance must be shown in the packaging technical documentation.
Build an artwork claim register with the exact words, language versions, visual symbol, covered component, metric, evidence owner, source date and expiry or review date. Regulatory, sustainability, marketing and packaging teams should approve the same register before print files are released. If evidence is incomplete, use factual material identification without adding an environmental superiority message.
- Claim text and every language version
- Covered packaging unit or component
- Metric, method, period and minimum baseline
- Evidence location, owner and review date
Reference sources
Official sources for further verification
- EUR-Lex: Directive (EU) 2024/825 on empowering consumers for the green transition
- EUR-Lex: Summary of Directive (EU) 2024/825
- EUR-Lex: PPWR Article 14 environmental claims
Regulations, standards and distribution requirements change. Verify the current requirements for the product and destination market before production.
