Green Claims Directive: Withdrawal Planned, EmpCo Stays

The Green Claims Directive proposal is headed for withdrawal. In its 2027 work programme, published on 4 November 2026, the European Commission announces plans to withdraw it. Annex III includes the proposal among files intended for withdrawal within six months. This is an announced intention: the programme alone does not establish that the formal withdrawal is complete. Businesses must continue to comply with existing rules against misleading environmental advertising.

What the Green Claims Directive was meant to add

The March 2023 proposal was designed to complement the EmpCo rules. It envisaged more detailed requirements for voluntary explicit environmental claims and environmental labels, generally with independent verification before use. The Council’s 2024 position also included simplified procedures. This was an additional framework under negotiation, rather than an adopted directive already imposing those duties.

Negotiations stalled in summer 2025. The Commission now considers sufficient Council support within a reasonable timeframe unlikely. Businesses should distinguish that political direction from completion of the formal withdrawal procedure.

Which rules still apply?

The EmpCo Directive (EU) 2024/825 remains in place. Germany’s corresponding UWG rules have applied since 27 September 2026 to the consumer marketing covered by them. The UWG Annex prohibits, among other things:

• Generic environmental claims without the required recognised excellent environmental performance.
• Sustainability labels that are neither based on a certification scheme nor established by public authorities.
• Overstated scope, such as attributing one component’s environmental benefit to the entire product.
• Offset-based product climate claims, including claims of a neutral climate impact based on emissions compensation.

For the last category, evidence of purchased carbon credits does not remove the prohibition. Specific wording also needs to be accurate and must not mislead consumers.

How business representatives have responded

Germany’s Wettbewerbszentrale welcomes the announced withdrawal. It regards the existing unfair-commercial-practices framework, strengthened by EmpCo, as sufficient and criticises the added burden of mandatory prior verification. This is its policy assessment, not an exemption for individual advertising statements.

What manufacturers and retailers should do now

No existing general pre-approval duty under the Green Claims Directive is being repealed: the proposal had not become applicable law. Separate product-specific or certification requirements must still be checked where relevant.

Businesses should continue reviewing packaging, online listings and social media. Describe precise characteristics, retain the underlying data and methods, and verify the basis of any labels used. A packaging recyclability claim should identify the component and conditions it concerns, rather than suggest an unsupported benefit for the whole product.

ECOPV-EU supports manufacturers and retailers with packaging and EPR compliance in Germany and the EU. This article provides general information and does not constitute legal advice.

Sources: 2027 Commission work programme and Annex III; Wettbewerbszentrale, 4 November 2026; UWG Annex; Directive (EU) 2024/825. Editorially checked on 6 November 2026.

AI-generated concept illustration of green claims and evidence; not official documents or certification.