Jo Stephenson, MD at PHD Marketing, looks at the EU Green Claims Directive and its importance for print and packaging supply chains as the legislation comes into effect.
The European Commission's proposal for the Green Claims Directive is laying the groundwork for major packaging industry change.
Designed to counter greenwashing and enhance consumer trust, the proposal imposes strict requirements on businesses operating in the European Union. Under these rules, substantiating environmental claims using life cycle assessment, accurate communication, and external verification will become paramount, and could come with significant financial penalties for external communications that do not meet guideline criteria.
Jo Stephenson, managing director at PHD Marketing, explains: "It’s not often that we see such a seismic shift in marketing communications as changes tend to be incremental, so it’s vital that print and packaging businesses, and their in-house teams, are fully up to speed on the EU Green Claims Directive. At the heart, it’s a fundamental shift in how we can talk about sustainability, and more importantly, how we cannot. It will apply to all external communications; as well as advertising, marketing collateral, websites and digital communications, it will also include claims made on packaging. The potential impact is truly enormous!
“The packaging industry, for example, has made colossal leaps in reducing its environmental footprint and reducing waste. We see fantastic innovation across the board and at every level of the supply chain, so we don’t want to collectively trip up when it comes to how sustainability is communicated. For instance, EU Commission figures found that more than 50% of ‘green’ claims in marketing are misleading, vague or use unfounded information. And what’s more, 40% of claims were found to have no supporting evidence - so it’s no surprise that something’s being done in this area.
“It's clearly not just about compliance; it's about genuine transparency and accountability. As one of the go-to names in our field, we’ve been helping our clients get well ahead of the curve on EU Green Claims Directive compliance. However, we also want to extend our insight to the wider market, because there’s an opportunity for real grassroots change, and that’s extremely exciting for us as packaging evangelists."
Similar in approach to the UK Government’s Green Claims Code, the EU Green Claims Directive's scope applies to the majority of EU companies, ranging from small to large entities, even those outside the EU targeting EU consumers. Under the regulations, only micro-SMEs with fewer than 10 employees or generating less than 2m Euro in annual turnover would be exempt.
The Directive further prohibits common phrases like 'net zero,' 'carbon neutral,' and 'eco-friendly' in marketing materials, unless substantiated and verified sufficiently.
Jo shares her top tips for navigating the EU Green Claims Directive: “Language is extremely powerful, and specifically with the proposed directive, it’s about specificity. Catch-all phrases like ‘sustainable’ or ‘eco-friendly’ are out. To give steer to in-house teams, as we create content for our clients, we are re-reading everything in the context of the directive. We take away the jargon, examine at face value, and ask whether what we’ve created is compliant with the tenements of the regulations: clear, honest, verifiable and backed by data. With fines that could cost businesses up to 10% of annual turnover, it’s vital that we’re always on top of our game, but what does a comprehensive plan look like?
Our first recommendation is to establish a robust framework for all external comms, focusing on integrity, transparency, and data verification. Data is currency in today’s world, so the first port of call should be setting comprehensive processes to gather and analyse environmental data across the full value chain, ensuring compliance with substantiation requirements.
We also advocate for creating new or updated Life Cycle Assessments to comprehensively understand the environmental impacts of products, without relying on historical data only. This information can form the basis of your environmental claims and substantiation. For marketing teams, it’s advisable to audit all external communications to check for any incursions and revise internal guidelines for communications to ensure compliance moving forwards. Always ask “Does this have the context it needs for a customer to make an informed decision? It is clear, honest and fair, and can what we’re saying be proven if it were challenged?”
Finally, don’t forget the power of people. While dedicated in-house ESG and CSR teams are becoming more common for SMEs in the face of initiatives such as Extended Producer Responsibility and the Corporate Sustainability Due Diligence Directive, it’s not yet standard practice. Adapting organisational structures to bring sustainability, data management and communications together is a great way to harness various perspectives and areas of expertise within one business.”
As the EU Green Claims Directive looms, companies can choose to view it as an opportunity to bolster their CSR initiatives, enhance brand value, and guide better decision-making. Compliance may be challenging, but it also offers strategic planning benefits, unlocking new insights for innovation and development.
Jo concludes: "What we don’t want to see is printers, packaging converters and their brand partners panic and pull the plug altogether on sustainability in marketing. If we’re more careful about how we’re presenting products and services, and we’re putting context and data first, we’ll be well on the way to creating a fairer, more authentic and more robust industry – and that should excite everyone.
Naturally, as a communications specialist, we’re more focused on the impacts of the EU Green Claims Code than a typical packaging manufacturer would be - words, language and content are our bread and butter, and that’s a huge component of this regulation. However, we’re confident that the industry can rise to the challenge, and excitingly, we see compliance with the Green Claims Directive as a real catalyst for positive change."