The European Union's green policy is increasingly reaching into the day-to-day operations of businesses in concrete ways. New regulations are substantially changing how companies may make claims about the environmental impact of their products and how those claims must be substantiated. In recent years, two important pieces of legislation have been adopted or are under consideration. The first is Directive (EU) 2024/825, the so-called Empowering Consumers Directive. Its purpose is to protect consumers from misleading environmental claims, and Estonia has already transposed the directive through amendments made to the Consumer Protection Act in 2025. The second EU legal act will be the Green Claims Directive, which is intended to establish scientific substantiation and verification requirements for environmental claims. Although the Green Claims Directive has not yet entered into force, its impact is already clear. Together, the rules laid down by these legal acts are changing the rules of the game in the internal market for manufacturing companies that market their products as environmentally friendly or sustainable.
The European Union's goal in making these changes is to accelerate the transition to a circular economy and reduce so-called greenwashing. Studies have shown that a large share of the environmental claims made on the market are either vague, difficult to verify, or outright misleading. The European Commission therefore wants to ensure that consumers and businesses operate under equal and transparent conditions. Under the new rules, companies may no longer use generic environmental claims; such claims must be clearly substantiated. Problematic claims might include, for example, "environmentally friendly," "green product," "climate neutral," "sustainable production," or similar. If a company wants to use such terms in its marketing, they must be substantiated either through scientific analysis or an appropriate methodology, and the information underlying the analysis must be transparent and verifiable. In practice, this often means that a life cycle assessment (LCA) must be carried out for the product, an Environmental Product Declaration (EPD) must be drawn up, or a carbon footprint must be calculated.
The idea behind the proposed Green Claims Directive is to render generic environmental claims effectively prohibited, meaning they may only be used if substantiated by very broad and robust analysis. The Empowering Consumers Directive (EU) 2024/825, on the other hand, amends the rules on unfair commercial practices and bans several practices. For example, it will no longer be permitted to use environmental labels that lack official certification; to make generic environmental claims without evidence; or to create the impression that a product is environmentally neutral when that claimed neutrality has actually been achieved through an offsetting measure, such as purchasing carbon credits. This means that all marketing materials must be reviewed, from websites and packaging to individual advertisements. All references made in them to sustainability or environmental friendliness must be accurate and verifiable.
At the same time, the European Union wants to reduce confusion in the use of environmental labels, which is why it is restricting the ability to create new, self-declared environmental labels and encouraging preference for trustworthy certification schemes such as the European Union's official ecolabel, the EU Ecolabel. This is a voluntary scheme whose purpose is to promote products with a high level of environmental performance, provide consumers with a trustworthy label, and steer the market toward more sustainable products. To obtain the label, strictly defined criteria must be met, but the opportunity it creates for companies to differentiate themselves in the market is seen as a bonus.
The new rules on the use of green claims directly affect, above all, companies that manufacture construction materials, produce consumer goods, or sell products on the EU internal market. The following key changes must be taken into account:
✔ accurate environmental data must be collected;
✔ environmental claims used in marketing must be substantiated;
✔ generic "green" claims must be avoided;
✔ standardized methodologies (e.g. LCA) must be used
✔ independent verification must be carried out where necessary.
In conclusion, it is clear that the internal market of the future will be based on verifiable environmental data. Companies that prepare early can avoid the marketing risks arising from unsubstantiated green claims, improve their competitiveness, and meet the green criteria increasingly required in public procurement. The official EU Ecolabel is by no means the only way to substantiate a green claim, but it should be noted that in public procurement, holding the label will be practically the only form of evidence that cannot be challenged. Below, therefore, are the most important steps that must be taken to obtain the EU Ecolabel.
Check whether the product falls within an ecolabel product group
Since the EU Ecolabel can only be applied for in respect of products for which specific criteria have been established, the first step is to check whether your product falls within one of the ecolabel's product groups. This can be checked on the website of the European Commission's Environment Agency. If it does, then obtaining the ecolabel is possible, and you should review the environmental criteria for your product group, see which criteria apply to that product group, and find links to the specific criteria documents. You should also contact the Environment Agency to discuss the product's compliance requirements and ask for guidance on preparing the application.
The application must be registered in the ECAT system
Since applications for the EU Ecolabel are submitted digitally, the company must register in the EU Ecolabel Catalogue (ECAT) system and enter both its company and product data there. ECAT functions both as an application system and as a public database that displays all products that have received the ecolabel.
A technical file must be prepared
The most labor-intensive part of the application is demonstrating the product's compliance with the environmental requirements. To do this, a file must be compiled containing all the data needed to substantiate the environmental criteria, using the product's technical specifications, data on materials and chemicals, and supplier declarations or test results. If laboratory testing is also required, only a laboratory holding ISO 17025 accreditation may be used.
An assessment must be completed
Once all the necessary materials have been gathered, the application form must be completed, all supporting documents attached, and the file submitted to the Environment Agency. The application may cover either a single product or several products within the same product family. The application must be submitted in the European Economic Area country (which comprises all EU Member States, Norway, Iceland, and Liechtenstein) where the product is manufactured. If the product is manufactured outside the European Economic Area, the application must be submitted in the country where the product is placed on the market. The Environment Agency reviews the submitted documents, may request additional information, and may carry out an on-site inspection at the company or its suppliers. This is a normal part of the application process.
Use of the label is based on a licensing agreement
Once the application is approved, a licensing agreement is concluded and the company receives a certificate and a licence number. The EU Ecolabel logo and licence number may then be used on products and in marketing. All supporting documents must be retained, the product's compliance with the criteria must continue to be ensured going forward, and the Environment Agency must be notified of changes such as new materials or new suppliers.
Once all of this has been done, the label may be added to the product:
