🪦Can the Green Claims Directive be brought back to life?

❎ According to the EU Commission, 56% of all corporate environmental claims are bogus. This is exactly what it aimed to tackle with two key regulations: Empower Consumers Directive (hashtag#ECD) and Green Claims Directive (hashtag#GCD).

🏛️ Back in June, I reported about the drama when the GCD was put on ice just before its final trilogue negotiation. Led by Germany and German MEPs, which even triggered a constitutional crisis with the Commission.

🇩🇰 The Danish Presidency is now trying to resurrect the GCD by brokering a new compromise. But their time is running out, as they hand over the reins to Cyprus on December 31st.

Two key modifications they are suggesting:

1️⃣ Exemptions for micro-enterprises

2️⃣ Much more importantly - a move towards voluntary verification.

🏢 Companies would still have to substantiate environmental claims with robust evidence, but third-party verification would be voluntary and largely ex-post: enforcement would depend on authorities and litigants rather than a prior approval system.

⚠️ Without mandatory verification, the GCD becomes primarily a “super-guidance” instrument clarifying expectations and methodologies, rather than a uniform EU gatekeeper preventing unsubstantiated green claims from reaching the market.

🇪🇺 As a reminder: from 2026, the ECD already regulates (=basically bans) any environmental claims for products or services. Further, case/national law provides guidance within the 27 member states.

🛡️ For CDR, removing mandatory verification means the GCD would no longer guarantee that claims have been independently validated up-front, making voluntary adoption of credible standards (CRCF alignment, like-for-like rules, independent MRV) the primary marker of integrity.

↕️ This risks creating a two-tier system: a best-in-class tier of corporates and public buyers who opt into robust verification and CRCF-aligned removals, and a residual tier continuing to make weaker climate claims under general consumer law, enforced only case-by-case.

🤔 Overall, I am still on the fence and unsure what the value add of such a compromise GCD would be. It will likely still be better than no GCD and provide a bit of additional clarity, but could also be watered down to the point of proving meaningless.

👀 More to come, soon, which I will report on.

❓ What’s your take, especially for the corporate sustainability leaders out there potentially affected by this: what do you want to see?

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