Green Claims Directive: auditing environmental claims before the greenwashing ban
Green Claims directive and EmpCo directive (EU 2024/825): from 27 September 2026, an environmental claim without traced evidence becomes prohibited. Sourced figures, penalties and a 4-step audit method.
TL;DR: The proposal nicknamed the "Green Claims directive" was indeed withdrawn in June 2025 — but the greenwashing ban keeps advancing through another channel: the EmpCo directive (EU 2024/825), voted, published and in force, applies from 27 September 2026. From that date, an environmental claim without traced evidence becomes prohibited. The European Commission examined 150 claims in 2020: 53% turned out vague, misleading or unfounded, 40% were backed by no evidence at all. The way out is not legal — it is methodical: inventory, qualify, prove, trace.
On a Tuesday morning, your marketing manager hands you a pack and asks whether you can still print 'eco-friendly' on it. You read the word again, you frown, and one very simple question crosses your mind: what exactly are we basing that claim on. You call quality, then procurement, then your long-time supplier, and everyone points you to someone else without ever producing a precise document. Yet the word is everywhere at your company: product sheet, website, ongoing campaign. And that morning, it hits you: nobody knows where it comes from. This video starts from that scene and gives it a deadline: September 27, the day from which an environmental claim without traced evidence becomes prohibited. The proposal nicknamed Green Claims was indeed withdrawn as a text, and the video keeps the logic of that withdrawal: a withdrawn text does not mean an abandoned subject, because the ban on greenwashing keeps advancing through other channels. The figures come from the European Commission, which examined 150 environmental claims in 2020: 53% turned out vague, misleading or unfounded, and 40% were backed by no evidence at all. In other words, more than one claim in two would not survive an audit, and nearly one in two rests on nothing. On penalties, French law leaves little room: 100,000 euros in administrative fines for a legal entity in case of a non-compliant carbon-neutrality claim, under article L229-69 of the Environmental Code, and up to 10% of revenue in criminal fines for misleading commercial practice, a ceiling raised to 80% of advertising spend for environmental claims, under article L132-2 of the Consumer Code. Against that backdrop, the proposed way out is not legal — it is methodical: four concrete verbs, inventory, qualify, prove, trace. First, inventory every claim you publish, wherever it appears. Then qualify each one, deciding between vague and precise, because only the precise is defensible. Then prove, by attaching each precise claim to a dated, named piece of evidence. Finally, trace, by keeping the evidence trail so you can pull it out on inspection day. The central message fits in one sentence: a claim without traced evidence becomes illegal on September 27, and four inventory steps are enough to go from missing proof to traced proof. This episode continues the Taranis AI series on method: the same thesis as the previous parts — diagnosis before tools — applied this time to environmental-claim compliance.
This article is the written version of the video episode "Green Claims: the audit starting September 27" — the full transcript is kept below. It belongs to the Taranis AI series on regulatory compliance, alongside our guide AI Act 2026: Industrial AI Compliance.
Green Claims directive and EmpCo directive: what are we really talking about?
No, this is not the famous green-claims directive you keep reading about. That proposal, the one nicknamed Green Claims, was indeed withdrawn in June 2025 — and plenty of people concluded the subject was buried. Classic mistake: the real text lives elsewhere. European directive 2024/825, nicknamed EmpCo — for empowering consumers for the green transition — is voted, published and in force, and its application deadline is 27 September 2026. Hold on to this logic: a withdrawn text doesn't mean a dropped subject, because another text, a broader one, has already taken over. This video gives no legal advice, only a field method to take you from no evidence to traced evidence.
Green Claims directive: which environmental claims are prohibited?
What awaits you on that date is a clean ban on generic claims without proof, on every surface your customers can see: "eco-friendly", "sustainable", "carbon neutral", "green", "natural" — without solid, accessible evidence behind them, these words simply become forbidden. Faced with that finding, Europe decided to flip the burden of proof: from now on, whoever makes the claim must prove it. Period. Even in B2B, you are caught in the cascade: your consumer-facing customers will have to prove what they claim, and it is to you they will turn for your evidence — your technical data sheet becomes their supporting document, and your silence becomes their risk. Add reputation: public doubt about your commitments heals far more slowly than a package that gets reprinted in a few weeks. On packaging, the same inventory reflex applies to PPWR compliance; on reporting, to CSRD reporting.
Green Claims directive: penalties for non-compliant claims
The cost of doing nothing is already written into French law. A non-compliant carbon neutrality claim exposes you to 100,000 euros in administrative fines for a legal entity, for a single mention — and it takes just one inspection for the bill to land (Environmental Code, art. L229-69). On the criminal side, the ceiling climbs to 10% of revenue for misleading commercial practice, with the calculation based on your advertising spend — raised to 80% of advertising spend for environmental claims (Consumer Code, art. L132-2). Take thirty seconds to run that rate against your own accounts and feel what it weighs.
Green Claims directive audit in 4 steps: inventory, qualify, prove, trace
Four steps, one person in charge, less than a week of focused work — starting tomorrow morning with one person, a spreadsheet, and no experts on the payroll.
Step one, inventory
List every visible claim — packaging, product sheets, website, brochures, campaigns — without forgetting or downplaying anything. No inventory, no audit: the same rule as in an AI audit, where knowing what you have conditions everything else.
Step two, qualify
For each claim, decide between vague and specific, verifiable and not — and accept that this step stings a little. Only the specific is defensible.
Step three, prove
Dig out the study, the calculation, or the certificate behind every promise, then rephrase or drop anything that still stands unsupported.
Step four, trace
Archive every piece of evidence, dated and named, in one single folder — because evidence you can't find again is evidence that doesn't exist.
Keep the compass: an environmental claim without traced evidence becomes illegal on September 27th, and the way out isn't legal, it's methodical.
Full transcript of the video "Green Claims: the audit starting September 27"
You're at your desk on a Tuesday morning when your head of marketing drops a package in front of you and asks: can we still print eco-responsible on this?
You read the label again, you frown, and one very simple question crosses your mind: what exactly are we basing that on?
You call quality, then procurement, then your long-time supplier. Everyone points you to someone else, and nobody ever pulls out an actual document.
And the word is everywhere at your company: on the product sheet, on the website, on the brochure handed out at the last trade show.
And that morning, it hits you: nobody knows where that word came from, who approved it, or where the proof is sleeping.
So stay with me, because by the end of this video you'll hold a simple four-step grid to audit every claim before the deadline.
Inventory, qualify, prove, trace: four concrete verbs you can start tomorrow morning with one person, a spreadsheet, and no experts on the payroll.
One honest warning before we go: this video gives no legal advice, only a field method to take you from no evidence to traced evidence.
And first, let's clear up a confusion that trips everyone up: no, this is not the famous Green Claims directive you keep reading about.
That proposal, the one nicknamed Green Claims, was indeed withdrawn in June two thousand twenty-five, and plenty of people concluded the subject was buried.
Classic mistake, because the real text lives elsewhere: European directive two thousand twenty-four, eight hundred twenty-five, voted, published, and in force.
Its nickname, EmpCo, for empowering consumers for the green transition, and its application deadline is September twenty-seventh, twenty twenty-six.
Hold on to this logic: a withdrawn text doesn't mean a dropped subject, because another text, a broader one, has already taken over.
What awaits you on that date, I've chosen to call the September twenty-seventh audit, because that is exactly what the rule will demand of you.
Not an inspector knocking on your door one morning, but a clean ban on generic claims without proof, on every surface your customers can see.
Eco-responsible, sustainable, carbon neutral, green, natural: without solid, accessible evidence behind them, these words simply become forbidden.
Why such a harsh rule, you might ask. The answer lies in a survey the European Commission ran in two thousand twenty.
One hundred fifty environmental claims put under the microscope, on everyday products, across every aisle and every product category.
Hold on to your seat: fifty-three percent of them turned out to be vague, misleading, or unfounded, well over half of the entire sample.
More than one in two, in other words. And once you run your own inventory, you'll understand very quickly why this number surprises no auditor.
And that's not all: forty percent are backed by no evidence whatsoever, no study, no calculation, not a single verifiable certificate.
No calculation, no study, no certificate, and yet the promise sits there on the packaging as if it had always been self-evident.
Faced with that finding, Europe decided to flip the burden of proof: from now on, whoever makes the claim must prove it. Period.
And the cost of doing nothing is already written into French law: a non-compliant carbon neutrality claim exposes you to one hundred thousand euros in administrative fines.
One hundred thousand euros for a legal entity, for a single mention, and it takes just one inspection for the bill to land.
On the criminal side, the ceiling climbs to ten percent of revenue for misleading commercial practice, with the calculation based on your advertising spend.
Ten percent of revenue. Take thirty seconds to run that rate against your own accounts and feel what it weighs.
I can already hear you: we're business to business, all of this is for consumer brands.
Let's be honest, because on paper it's true: the rule targets practices toward consumers first, not your contracts between professionals.
Except your consumer-facing customers will have to prove what they claim, and who are they going to turn to for your evidence?
To you, obviously, in a cascade: your technical data sheet becomes their supporting document, and your silence becomes their risk.
Now add reputation: public doubt about your commitments heals far more slowly than a package that gets reprinted in a few weeks.
Now the method, because that's where everything is decided: four steps, one person in charge, less than a week of focused work.
Step one, inventory: list every visible claim, packaging, product sheets, website, brochures, campaigns, without forgetting or downplaying anything.
Step two, qualify: for each claim, decide between vague and specific, verifiable and not, and accept that this step stings a little.
Step three, prove: dig out the study, the calculation, or the certificate behind every promise, then rephrase or drop anything that still stands unsupported.
Step four, trace: archive every piece of evidence, dated and named, in one single folder, because evidence you can't find again is evidence that doesn't exist.
And here we are, back in your Tuesday-morning office, except this time that questionable package doesn't scare you anymore, because you're holding the file.
An environmental claim without traced evidence becomes illegal on September twenty-seventh. The way out isn't legal, it's methodical: four inventory steps, from no evidence to traced evidence.
Keep the compass: an environmental claim without traced evidence becomes illegal on September twenty-seventh, and the way out isn't legal, it's methodical.
If this analysis speaks to you, let's dig into it at TARANIS AI: the diagnosis, the method, the experience, everything is there to support you. You'll find all the links in the comments of this video.
Share your experience in the comments, I read everything and I answer each one. But tell me: have you ever had to hunt for the proof behind your own claims and come up empty?
Green Claims directive: the greenwashing figures
Why such a harsh rule? The answer lies in a survey the European Commission ran in 2020: 150 environmental claims put under the microscope, on everyday products. Hold on to your seat: 53% of them turned out to be vague, misleading, or unfounded — more than one in two, in other words. And 40% are backed by no evidence whatsoever: no study, no calculation, not a single verifiable certificate.
| Figure | Scope | Source |
|---|---|---|
| 53% of claims vague, misleading or unfounded | 150 environmental claims examined | European Commission, 2020 study |
| 40% of claims backed by no evidence | Same scope, same study | European Commission, 2020 study |
| €100,000 administrative fine (legal entity) | Non-compliant carbon-neutrality claim | French Environmental Code, art. L229-69 |
| Up to 10% of revenue in criminal fines (80% of advertising spend for environmental claims) | Misleading commercial practice | French Consumer Code, art. L132-2 |
Honest framing: 53%/40% come from the European Commission's 2020 study of 150 claims; €100,000 and 10% of revenue are the French-law ceilings cited in the video. Any reuse keeps this framing, without extending it.
FAQ — Green Claims directive
Has the Green Claims directive been dropped? No. The proposal nicknamed "Green Claims" was indeed withdrawn in June 2025, but the greenwashing ban keeps advancing through another channel: the EmpCo directive (EU 2024/825), voted, published and in force, applicable from 27 September 2026. A withdrawn text doesn't mean a dropped subject.
What is the EmpCo directive (EU 2024/825)? European directive 2024/825, nicknamed EmpCo — for empowering consumers for the green transition — bans generic environmental claims without proof. Its application deadline is 27 September 2026.
Which environmental claims will be prohibited? Generic claims without solid, accessible evidence: "eco-friendly", "sustainable", "carbon neutral", "green", "natural". From 27 September 2026, a claim without traced evidence becomes prohibited on every visible surface.
Does the Green Claims directive affect B2B companies? On paper, the rule targets practices toward consumers first, not contracts between professionals. In practice, B2B companies are caught in the cascade: their consumer-facing customers will have to prove what they claim and will turn to their suppliers for evidence — the supplier's technical data sheet becomes the customer's supporting document.
What are the penalties for greenwashing? Under French law: €100,000 in administrative fines for a legal entity in case of a non-compliant carbon-neutrality claim (Environmental Code, art. L229-69), and up to 10% of revenue in criminal fines for misleading commercial practice — a ceiling raised to 80% of advertising spend for environmental claims (Consumer Code, art. L132-2).
Where to start when auditing your environmental claims? With an inventory: list every visible claim, then qualify (vague or specific), prove (study, calculation or certificate) and trace (dated, named, archived evidence). Four steps, one person in charge, less than a week of focused work.
Call to action
TARANIS AI — diagnosis, method, experience: https://taranis-ai.com. And for short formats: send DIAG by direct message.
Go further
- Video hub: /en/videos
- Episode 001 "The dynamo and the diagnosis" — same thesis, first part
- Episode 003 "Agent reporting" — third part, same method
- AI compliance: AI Act 2026: Industrial AI Compliance
- Packaging: PPWR packaging compliance
- Reporting: CSRD directive and sustainability reporting
- Request a diagnosis (keyword DIAG)
Program
On the program: the Tuesday-morning scene, the logic of a withdrawn text, the European Commission figures, the penalties, then the four-step grid.
Sources
Sources: European Commission, 2020 study of 150 environmental claims (53% vague, misleading or unfounded; 40% backed by no evidence); French Environmental Code, art. L229-69 (€100,000 administrative fine for a legal entity, non-compliant carbon-neutrality claim); French Consumer Code, art. L132-2 (misleading commercial practice: criminal fine up to 10% of revenue, raised to 80% of advertising spend for environmental claims).
Final question
Have you ever hunted for the proof behind a claim you have printed for years? Share your experience in the comments, I read everything and I answer each of your questions.
Article written by Damien Godard, founder of Taranis AI, from the video episode "Green Claims: the audit starting September 27" (full transcript kept above). Figures and penalties: European Commission (2020 study of 150 claims), French Environmental Code (art. L229-69), French Consumer Code (art. L132-2).
