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ORIENTING feedback to the European Commission’s proposal for Green Claims Directive

The European Commission, with the proposal for a Directive on substantiation and communication of explicit environmental claim, also known as Green Claims Directive, is working on regulating the environmental claims in commercial practices. This directive will introduce mandatory requirements for an assessment to accompany explicit environmental claims.

ORIENTING welcomes this proposal, as we believe that is needed to hinder the proliferation of false environmental claims and reduce the risk of greenwashing. But we also point at the importance of providing a standard and harmonized methodology (or methodologies) and clear guidance on how to implement the Directive.

From the ORIENTING point of view, the present proposal wouldn’t reach this objective. That is why we have presented our feedback, urging the European Commission to reconsider the adoption of the Product Environmental Footprint as the preferred baseline methodology for substantiating green claims. Not doing so, would also put at risk the success of current policies in the field of Sustainable Products Initiative.

The main arguments to support our view are:

  1. the proposal on Green Claims Directive lacks the technical details necessary to create a true level playing field for substantiating environment performance. The use of general terms such as “claims need to be life cycle based”, “rely on widely recognized scientific evidence”, “considering significant environmental impacts” and “be proven with scientific evidence” allows for subjective choices and assumptions in impact assessment models, databases, datasets, and methodological choices.
  2. Today a harmonized methodology exists to assess the environmental impact of products along the life cycle, the Product Environmental Footprint (PEF) Method. It contains detailed instructions on how to model and calculate the environmental impacts of products and organizations. It seems illogical therefore not to use the PEF method as the preferred baseline methodology, unless the EC contradicts its own legislative acts.
  3. Currently, there is no scientific consensus on how to deal with environmental concerns such as biodiversity and microplastics littering: these shortcomings affect PEF, as stated in the proposal, and all available methodologies. To overcome these limitations in the impact assessment methods for specific product categories and environmental aspects, the European Commission could subsequently introduce methodological updates in the preferred method as supplementary options as they become available over time.

For these reasonings, we urge the EC to suggest the PEF as the preferred baseline method for substantiating green claims, provided that further measures are put in place to make the methodology affordable for SMEs.

If you want to read the full statement sent to the European Commission, you can read it here.

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