Green Claims Directive explained: What it is and how it impacts UK construction

The Green Claims Directive (GCD) would require businesses to substantiate any “green” claims about products or services with robust, verifiable data, taking a full life-cycle perspective. For example, claims like “carbon neutral product” or “made with 30% recycled material” would need proof via life-cycle assessment (LCA) and independent verification before being used in marketing.

Why is the GCD needed? Regulators found that green marketing often misled consumers, eroding trust and unfairly disadvantaging genuinely sustainable firms. The directive’s goal was to create a level playing field by weeding out false claims and making environmental labels credible and comparable across the EU. In short, it sought to protect consumers from greenwashing and push companies to “prove” any eco-claims with data or certifications.

EU status and related initiatives

The European Commission introduced the Green Claims Directive in March 2023 as part of its Green Deal agenda. The European Parliament and Council reached positions by mid-2024, and it seemed poised to become law. However, in June 2025 the Commission announced its intention to withdraw the proposal, amid concerns it would over-burden small businesses. Critics argued the required proof and third-party checks could impose too much red tape on the EU’s 30 million microenterprises. This pause — effectively shelving the EU directive — does not signal that greenwashing is acceptable; existing consumer protection laws (like the Unfair Commercial Practices Directive) still require claims to be truthful and substantiated. But it does mean the EU may rely on broader consumer law rather than a dedicated new regime for green claims.

Importantly, the GCD was just one piece of a larger puzzle. It complemented proposals to empower consumers in the green transition (ensuring product durability information and anti-greenwash rules) and linked with other initiatives like the Ecodesign for Sustainable Products Regulation (ESPR). Under ESPR, manufacturers will need Digital Product Passports documenting product environmental data. Together, these policies support the EU’s 2050 climate neutrality goal by pushing transparency on product impacts. 

In essence, even without the GCD, the direction is clear: companies will face increasing pressure to provide accurate environmental performance data for their products.

UK perspective: Green Claims Code and carbon reporting

How does this relate to the UK and Ireland (UK&I)? The UK, no longer in the EU, has taken its own robust approach. The UK Competition and Markets Authority (CMA) introduced a Green Claims Code in 2021, which lays down six principles for environmental claims:

• Claims must be truthful and accurate,
• Claims must be clear and unambiguous, 
• Claims must not omit or hide important relevant information,
• Comparisons must be fair and meaningful,
• Claims must consider the full life-cycle of the product or service,
• Claims must be substantiated.

Unlike the shelved EU directive, the UK’s code isn’t just guidance — it’s backed by consumer protection law. In fact, new legislation in 2024 gave the CMA power to fine companies up to 10% of global turnover for misleading environmental claims. The message is clear: Britain is not backing down on greenwashing. If anything, UK regulators are strengthening enforcement, putting firms on notice to back up green claims with evidence or face legal consequences.

For UK construction product manufacturers, this push for credible claims aligns with other carbon-related regulations and initiatives:

• Building Regulations Part Z (proposed): An industry-backed initiative to mandate whole-life carbon assessments for buildings. If adopted, it would require builders to report embodied carbon, indirectly forcing manufacturers to provide verified product carbon data (e.g. via EPDs) in order to stay on specs and meet future building codes. Many major projects already ask for environmental product declarations as evidence of product carbon footprints.
  
  
• Public procurement and carbon limits: Public sector clients are embedding carbon criteria in tenders. For example, UK government procurement policy now requires large suppliers to have carbon reduction plans (per PPN 06/21) and is moving toward considering embodied carbon in contracts. Elsewhere in Europe, new rules like France’s RE2020 and the EPBD already mandate an LCA and EPD for every new building, a trend UK firms cannot ignore if they export or compete internationally.
  
  
• Standards and frameworks (ISO, BSI, RICS): International standards such as ISO 14040/44 (for LCA methodology) and ISO 14025 / EN 15804 (for EPDs in construction) provide the accepted methods to quantify and declare product carbon impacts. The Green Claims Code explicitly says claims should cover the full life cycle of products, echoing these standards. Meanwhile, professional bodies like RICS and IEMA encourage using these standardised and verified LCAs and EPDs to ensure data consistency in carbon reporting. Adhering to such standards not only helps with regulatory compliance but also lends credibility to any green claim you make about a product.

Credible environmental claims: LCA and EPD as proof points

Ultimately, both the (now stalled) EU directive and the UK’s approach emphasise one thing: credibility through evidence. This is where life-cycle assessment (LCA) and environmental product declarations (EPDs) come in. An LCA is a scientific analysis of a product’s environmental impact from cradle to grave (resource extraction to end-of-life), governed by ISO 14040/44. The result of an LCA can be distilled into an EPD — a third-party-verified document detailing a product’s life-cycle impacts (e.g. carbon footprint) according to EN 15804 and ISO 21930 standards. EPDs are essentially the “nutrition labels” for a product’s environmental performance, verified by independent experts. They provide credible, comparable data that clients and regulators trust. In fact, third-party verified EPDs are increasingly seen as a key tool to combat greenwashing by providing verifiable claims of environmental performance. For instance, instead of vaguely branding a product “eco-friendly,” a manufacturer can cite an EPD showing the product’s carbon impact is, say, 20% lower than the industry average — with audited data to support that claim.

This reliance on data and verification is exactly what the Green Claims Directive and UK Code call for. Companies that invest in robust LCAs and EPDs will be well-placed to meet current and future requirements. 

“Investing in EPDs shows that you believe in sustainability and transparency. It’s not just about compliance — it’s about positioning your company for the future,” Panu Pasanen, CEO of One Click LCA

In practical terms, providing honest, data-backed carbon information doesn’t just keep you compliant — it builds trust with customers, specifiers, and regulators.

“We’re concerned that too many businesses are falsely taking credit for being green, while genuinely eco-friendly firms don’t get the recognition they deserve,” Andrea Coscelli, Chief Executive of the UK CMA 

This sentiment underpins why stringent measures like the Green Claims Directive and Code exist — to reward authenticity and penalise false claims. Manufacturers who prove their environmental performance with solid data will stand out as credible, while those who rely on fluffy marketing risk both reputational and legal consequences.

Key takeaways for construction manufacturers

• Green claims must be proven: Whether under EU or UK regimes, environmental claims (e.g. “low-carbon concrete”) need backing by data. Use LCA results, verify them, and publish EPDs to substantiate such claims.
• The UK is enforcing green marketing rules now: Don’t assume the absence of an EU directive means a free pass. The UK’s laws already require truthfulness and full life-cycle consideration in product claims, with hefty penalties for non-compliance.
• Align with standards: Integrating ISO-compliant LCA processes and obtaining EN 15804 EPDs for your products will not only prepare you for emerging regulations like Part Z or ESPR, but also improve your market credibility and access. Many architects and clients now insist on EPDs in specifications .

In summary, the Green Claims Directive’s journey reflects a broader trend: demand for transparency in sustainability is rising on all fronts. Construction product manufacturers in the UK and Ireland should seize this moment to get their environmental data in order. By doing so — adopting LCA tools, publishing verified EPDs, and following best-practice guidelines — you turn compliance into an opportunity. You’ll be helping buyers make informed, carbon-conscious choices while also differentiating your products in a market that increasingly values proof over promises.