Journal
Regulation05 October 2026 5 min read

Green Claims Directive: Why Your DPP Is Now Your Legal Evidence

The EU Green Claims Directive requires brands to substantiate every environmental statement — and the Digital Product Passport provides exactly the data trail you need.

The era of vague sustainability messaging is ending. When the EU Green Claims Directive enters into force, every "eco-friendly," "sustainable," or "made with recycled materials" claim will require documented proof — and that proof must exist before the claim is made public.

For fashion brands already preparing for the Digital Product Passport under ESPR, there's an unexpected advantage: the same data infrastructure that enables DPP compliance also provides the evidentiary foundation the Green Claims Directive demands.

What the Green Claims Directive Actually Requires

Proposed in March 2023 and currently in trilogue negotiations, the Green Claims Directive (Directive on Green Claims, COM/2023/166) establishes that environmental claims must be:

  1. Substantiated by widely recognised scientific evidence
  2. Verified by an accredited independent body before use
  3. Communicated with supporting information accessible to consumers

This isn't a soft guideline. The Commission's 2020 study found that 53.3% of environmental claims in the EU were vague, misleading, or unfounded, and 40% had no supporting evidence whatsoever (European Commission, Screening of Websites for Greenwashing, 2020). The GCD is the legislative response.

The DPP as Evidentiary Infrastructure

The Digital Product Passport, mandated under the Ecodesign for Sustainable Products Regulation (ESPR), requires structured disclosure of:

  • Material composition and origin
  • Manufacturing processes and locations
  • Environmental impact data (carbon footprint, water use)
  • Durability and repairability information
  • End-of-life handling instructions

This is precisely the data the Green Claims Directive requires brands to have — documented, verifiable, and traceable.

From Claim to Compliance
💬
Marketing Claim
"50% recycled polyester"
→
📋
DPP Data
Bill of Materials + GRS certificate
→
✓
Verification
Third-party auditor confirms data
→
✅
Compliant Claim
Published with evidence link
The DPP creates the documented chain from raw data to verified public claim

What This Means in Practice

Consider a claim many brands make: "This jacket is made with 50% recycled polyester."

Under the GCD, before publishing that claim, the brand must:

  1. Document the actual recycled content percentage (not estimated, not "up to")
  2. Identify the certification standard used (GRS, RCS, or equivalent)
  3. Maintain chain-of-custody records from supplier to finished product
  4. Have the claim verified by an accredited third party
  5. Make supporting information accessible to consumers

A properly structured DPP already contains fields for material composition, supplier certifications, and traceability data. The verification step becomes a matter of auditing existing records rather than scrambling to create documentation after the fact.

The Cost of Non-Compliance

The GCD introduces meaningful penalties. Member states must ensure sanctions are "effective, proportionate and dissuasive," with fines of at least 4% of annual turnover in the relevant Member State for serious infringements (Green Claims Directive proposal, Article 17).

Beyond fines, remedies include:

  • Withdrawal of products from the market
  • Prohibition of the claim
  • Publication of the infringement decision
  • Corrective statements at the trader's expense

For brands with thin margins and established market positions, reputational damage may exceed direct financial penalties.

Frequently asked questions

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