An EPD can provide evidence for a precise environmental claim. It does not give a manufacturer permission to call a product “green”, “eco-friendly” or “climate neutral”. That distinction becomes commercially important when Member States start applying Directive (EU) 2024/825 on 27 September 2026.
What the Directive changes
Directive (EU) 2024/825 amends the Unfair Commercial Practices Directive and the Consumer Rights Directive. It adds practices concerning environmental claims, sustainability labels, durability and greenhouse-gas offsetting to the list of practices regarded as unfair in all circumstances. It also strengthens the information basis for assessing other environmental communications.
The rules concern business-to-consumer commercial practices. They matter most directly when a product is promoted to an individual acting outside their trade or profession. Product type does not create an automatic exemption: consumer-facing construction products, furniture, electronics, packaging and medical devices may all carry claims that require review.
An environmental claim can be explicit or implied. Text, a product name, colours, pictures, symbols and their combination can create an environmental message. The legal review therefore starts with the overall impression of the same medium, not with a search for a small set of prohibited words.
Why an EPD is relevant but not decisive
An environmental product declaration (EPD) is a structured disclosure based on life-cycle assessment (LCA), product-category rules and programme instructions. A third-party-verified EPD can establish a traceable source for environmental indicators within its defined scope. It is evidence, not an environmental performance award.
This matters because the Directive distinguishes a substantiated, specific statement from a generic environmental claim. A value such as “the declared global warming potential is 18.4 kg CO₂e per declared unit for modules A1–A3” conveys a defined result. “Low-carbon product” or “environmentally friendly product” conveys a broader superiority message. The EPD value does not automatically prove that broader message.
Even a numerical claim must be accurate, current, material and presented without creating a misleading overall impression. Verification of the source document does not verify every sentence later written by the EPD owner, distributor or retailer.
The six-part scope check
Before an EPD result is converted into public-facing copy, match the proposed claim to six elements of the declaration:
- Product identity. The model, formulation, manufacturing site and geographical representativeness must cover the product being advertised.
- Declared or functional unit. A result per kilogram, cubic metre, square metre or unit of delivered function cannot be presented as though these denominators were interchangeable.
- System boundary. A1–A3, cradle-to-gate data do not describe the complete life cycle. A claim must not silently add transport, use or end-of-life performance that was not assessed.
- Indicator. Global warming potential (GWP) is not a complete environmental score. A carbon result should not be restated as proof that the product is better for “the environment” overall.
- Scenario and data period. Electricity, transport, service life, reuse, recycling and end-of-life assumptions must remain visible where they materially influence the message.
- Limitations and validity. The claim register should record the EPD version, publication date, validity and the event that triggers reassessment.
If one of these elements does not match, the communication should be narrowed or supported by a different study. The fact that a PDF is publicly registered does not repair a mismatch between the declaration and the marketed product.
Generic environmental claims need a different test
The Directive’s recitals give examples of generic environmental claims, including “environmentally friendly”, “eco-friendly”, “green”, “ecological”, “biodegradable” and “biobased”. Such a claim is blacklisted when the trader cannot demonstrate recognised excellent environmental performance relevant to the claim.
A clear and prominent specification on the same medium can mean the communication is no longer generic. For example, a claim confined to a named packaging component and a measured recycled-content percentage is different from “eco product”. It is not automatically lawful: the specific percentage, component, denominator and supporting chain of custody still have to be correct.
An EPD is normally designed to disclose multiple impacts, not to establish that a product meets the separate legal threshold of recognised excellent environmental performance for every broad marketing statement. Manufacturers should not present EPD registration itself as an ecolabel or a product recommendation.
Climate claims based on offsets
The Directive introduces a categorical rule for product claims based on greenhouse-gas offsetting. A trader must not claim, based on offsetting greenhouse-gas emissions, that a product has a neutral, reduced or positive environmental impact in terms of greenhouse-gas emissions. “Climate neutral product” and “carbon-neutral delivery” therefore require particular attention where the claimed result depends on credits outside the product’s value chain.
The rule should be quoted precisely. It is not an automatic ban on every compensation programme concerning every environmental topic. A “plastic neutral” initiative is not caught by this exact blacklist item merely because it finances external collection. It can still be misleading under the general rules if the statement suggests a characteristic of the product, conceals material conditions or lacks adequate substantiation.
Nor should Module D in a construction-product EPD be treated as an offset. Module D reports potential benefits and loads beyond the product system boundary under defined scenarios. It must not be subtracted from A1–A3 to manufacture a “carbon-neutral” cradle-to-gate result.
Can two EPDs support a comparative claim?
Two verified EPDs are not automatically comparable. A defensible comparison requires compatible product functions, reference units, product-category rules, life-cycle modules, scenarios, data quality and calculation methods. For construction products, the comparison generally needs to consider the product’s performance in the building context rather than isolated declared-unit values.
A claim such as “32% lower GWP than our 2023 formulation” should therefore retain the reference product, indicator, modules, unit, method, geography and data periods. The manufacturer should also document whether the change reflects the product itself, an updated background database, a revised allocation rule or another methodological change.
Comparative public copy deserves a separate technical review even when both underlying studies were independently verified.
A claims register connects evidence to communication
The practical control is not a folder called “sustainability evidence”. It is a claims register in which every public statement has its own record:
- the exact approved wording and translation;
- the product, component or packaging element covered;
- the audience, market and communication medium;
- the EPD, carbon-footprint study, test report or certification scheme used as evidence;
- the indicator, unit, system boundary, scenario and data period;
- the responsible owner, approval date and reassessment trigger.
This structure lets a reviewer see whether the public promise is narrower than, equal to or broader than the underlying evidence. It also prevents a retailer or local distributor from turning a technically limited result into an unsupported general claim.
What to do before 27 September 2026
Inventory environmental wording, product names, badges and visuals across packaging, websites, catalogues, advertisements and retailer listings. Flag generic claims, sustainability labels and every product-level greenhouse-gas statement that depends on offsets. Then match the remaining specific statements to controlled evidence and review their translations.
For EPD-based communication, the review should be performed by someone able to read the declaration’s scope and assumptions, not only its headline carbon value. Where the current evidence does not cover the intended claim, commission the appropriate LCA, product carbon footprint or verification work before approving new artwork.
EPD Portal publishes registered environmental declarations and technical guidance. For a scope assessment, send the proposed wording together with the exact product, market, EPD or study version and the medium in which the claim will appear. The useful question is not “Do we have an EPD?” but “Does this evidence cover this precise public promise?”
Medical-device manufacturers can continue with MEDDEV’s sector-specific guide: Green Claims on Medical Devices: What Manufacturers Must Change by 27 September 2026.