Say it, prove it: green claims are becoming a data problem.

For years, "eco-friendly" on a label cost nothing to write. That era is closing. The EU has adopted rules banning generic environmental claims made without substantiation, and a further proposal — the Green Claims Directive — would go further still on how claims must be verified. Marketing departments now face an engineering question: where does the evidence behind each claim live, and can an authority inspect it? The Digital Product Passport is the natural answer — the substantiation layer green marketing has never had.

Last updated: 17 July 2026

In one line: the EU is banning unsubstantiated green claims, and a sealed Digital Product Passport is the substantiation layer — every environmental statement tied to structured, inspectable, tamper-evident evidence at the product itself.

What is changing for green marketing

Two EU instruments frame the shift. The Empowering Consumers Directive is adopted law: it amends the EU consumer-protection framework to ban generic environmental claims — "eco-friendly", "green", "climate neutral" and the like — when they are not backed by recognised substantiation, alongside restrictions on sustainability labels that lack certification behind them. The Green Claims Directive is a Commission proposal, not adopted law, and its status is still evolving — but as proposed it would require explicit environmental claims to be substantiated with evidence and verified before use. The common thread is unmistakable: environmental statements are moving from the domain of copywriting into the domain of evidence.

The greenwashing risk is now a business risk

An unsubstantiated claim used to be, at worst, a reputational scrape. Under the tightening framework the exposure is broader: consumer authorities can act against misleading claims, competitors can challenge them, and retailers — themselves liable for what they sell — increasingly push substantiation requirements down to suppliers. The quiet cost is internal: companies begin stripping environmental language from packaging and websites because nobody can locate the evidence, forfeiting real advantages they legitimately have. The problem is rarely that the product isn't what marketing says; it is that the proof is scattered across supplier PDFs, lab reports and someone's inbox.

The DPP as the substantiation layer

A Digital Product Passport solves exactly this. Instead of a claim floating free of its evidence, the passport binds them together:

Claims tied to data — recycled content, material composition, carbon footprint and durability sit as structured fields, not adjectives, so a stated percentage traces to a source document.
Sealed — eIDAS qualified sealing (QTSP onboarding in its final stage) makes the record tamper-evident and attributable to your legal entity; the substantiation cannot be quietly edited after the fact.
Inspectable — the passport resolves from a GS1 Digital Link QR on the product, so a consumer, a competitor's lawyer or a market authority reads the same record. Access tiers keep commercially sensitive detail restricted while the substantiating facts stay checkable.

The same structure ESPR mandates for product groups under delegated acts doubles, voluntarily, as green-claims insurance for everything else you sell.

From adjectives to evidence: what to do now

Start with an audit: list every environmental claim on your packaging, website and sales decks, and ask of each — where is the evidence, and could a third party inspect it? Claims with no locatable substantiation are the liability list. Then build the evidence layer once rather than per claim: PassPer's AI reads the documents you already hold — spec sheets, test reports, certificates, supplier declarations — and assembles them, with human review, into a sealed, registered passport per product. Marketing then writes only what the passport can back, and every claim carries its proof. The free readiness check shows how far your current documentation gets you.

Frequently asked questions

Is the Green Claims Directive already law?

No. The Green Claims Directive is a Commission proposal and its status is still evolving — it is not adopted law, and its final shape and timing are uncertain. What is adopted is the Empowering Consumers Directive, which amends EU consumer law to ban generic environmental claims made without recognised substantiation. The direction across both is the same: no proof, no claim.

Which claims are at risk under the new rules?

Generic, unsubstantiated ones: "eco-friendly", "green", "climate neutral", "environmentally friendly" and similar labels with no recognised evidence behind them. Specific, verifiable statements — a stated recycled-content percentage backed by data, a documented carbon footprint — remain possible precisely because they can be substantiated.

How does a DPP substantiate a green claim in practice?

The passport holds the underlying data as structured fields — material composition, recycled content, carbon footprint, durability results — sourced from real documents, sealed — eIDAS qualified sealing from QTSP activation — and resolvable from the product's QR code. When a consumer, competitor or authority questions the claim, you point to the record instead of assembling a defence.

We make no green claims at all. Are we safe?

From greenwashing rules, largely — but silence has its own cost, since buyers increasingly filter on environmental data. And if your products fall under ESPR delegated acts, passport data becomes mandatory regardless of your marketing. The stronger position is claims you can prove, which is what a passport enables.

See where you stand — three ways, all free.

Take the 2-minute readiness check, watch the 10-minute interactive walkthrough, or download the full 2026 compliance guide. No account needed.

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