The Green Deal vs green claims: guidance within the EU regulatory framework against greenwashing
Published on 11th November 2025
Often mentioned in connection with politics and climate protection, it is not always clear what lies behind these terms.
What is the difference between the Green Deal and green claims? In short, the European Green Deal is the European Union’s overarching political strategy for climate protection and sustainability; by contrast, green claims refers to companies’ environmental claims and titles a specific proposal for European legislation: the Green Claims Directive. This proposal and the already adopted EmpCo Directive aim to combat greenwashing, in particular by prohibiting “green claims” that cannot be substantiated.
The European Green Deal seeks to reduce emissions, among other things, by promoting sustainable investments and innovations and strengthening the circular economy. The EU also aims to empower consumers to recognise sustainable products and make informed purchasing decisions. This is becoming increasingly difficult, as products are often advertised with green promises without it being clear what actually lies behind them. Companies should therefore observe certain rules in advertising.
What is the European Green Deal?
The Green Deal strategy was launched by the European Commission in 2019 with the goal of making Europe climate-neutral in several stages by 2050: by 2030, emissions are to be reduced by at least 55%, and by 2040 by 90%.
The Green Deal addresses greenhouse gas emissions, the complete transformation of the economy and everyday life. It aims to promote, among other things, more efficient use of resources and the transition to a circular economy, the restoration of biodiversity, and the determined fight against environmental pollution. Investments in innovation, clean technologies, and green infrastructure are also central.
What impacts does the Green Deal have?
In practice, the Green Deal functions as an umbrella framework: numerous individual initiatives, programmes and legislation run under it – from stricter energy efficiency standards to new requirements for sustainable products to measures for transparent information. Examples of this type of legislation include the EmpCo Directive, which primarily seeks to combat greenwashing, and the Ecodesign Regulation, which, among other things, provides for a prohibition on destruction for certain products.
What is meant by green claims?
Green claims are environment-related advertising statements. They range from terms such as “climate neutral” or “CO2-compensated” to “100% recyclable” and “produced in a resource-conserving manner.” These statements can help consumers make purchasing decisions and reward companies that invest in sustainability. To achieve this, environmental claims must be understandable and, if in doubt, verifiable.
Many green claims are too general
Often, however, they are not: many environmental claims amount to general assertions that sound good but explain little. Consumers’ trust in environmental claims has rightly suffered in recent years. According to a European Commission study from 2020, 53.3 percent of the environmental claims examined were vague, misleading, or unfounded. Ultimately, contrary to the goals of the Green Deal, the best marketing wins out – not the best solution for the climate and the environment.
EmpCo, the Green Claims Directive and greater transparency
To counteract this, the European Commission, in addition to the already adopted EmpCo Directive, has presented a proposal for a Green Claims Directive. The aim of both directives is to provide consumers with reliable, comparable and verifiable environmental information.
Anyone who advertises a product’s environmental friendliness should do so on a solid basis and must not overstate it in advertising. In addition, environmental labels; that is, seals and labels, should only be permissible if they are established by the state or based on a robust certification system.
Under the current draft of the Green Claims Directive, companies must also set out what an environmental claim is based on, which method they use for assessment and which data underlie it. An independent body is to verify these statements before they are communicated in advertising.
It is still unclear whether and when the Green Claims Directive will enter into force. In the summer, the European Commission initially unexpectedly announced that it would withdraw the proposal but then indicated that it was sticking with it.
Green Deal: a challenge and opportunity for companies
For companies, the Green Deal’s sustainability efforts present a challenge but also an opportunity. What is needed are real improvements – fewer emissions, more sparing use of resources, better repairability and circularity – and communication that presents these advances in a verifiable way.
Even now, vague environmental claims are regularly impermissible due to their potential to mislead under the Act Against Unfair Competition (UWG). Companies that advertise with these environmental claims are already coming into focus.
Last year, the Federal Court of Justice, in proceedings brought by the German agency to combat unfair competition (Wettbewerbszentrale) against the confectionery manufacturer Katjes, ruled that the latter may not advertise its products as “climate neutral” without making it clear that there is no reduction, but merely an offsetting of CO2.
In addition, in September Environmental Action Germany (Deutsche Umwelthilfe) announced that it would take action against more than 30 companies for greenwashing and consumer deception.
Companies therefore will be already now – also with a view to the EmpCo Directive to be implemented by 2026 – looking to critically review their green claims to consumers.
