EU Directive 2024/825 — environmental claims
Every environmental claim will have to be backed by independent substantiation

Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 — the 'Greenwashing Directive' or 'Green Claims Directive' — amends Directives 2005/29/EC (unfair commercial practices) and 2011/83/EU (consumer rights) to better protect consumers against misleading environmental claims. It requires any environmental claim made by a company, developer, communicator, asset manager or public body to be backed by independent substantiation. Transposition by Member States is due by March 2027. The party responsible for a claim is the one that makes it — with direct consequences in case of non-compliance.

Secure your claims See the CSRD hub

Legal framework

What the directive changes, in practice.

Adopted on 28 February 2024 and published in the Official Journal of the EU on 6 March 2024, Directive 2024/825 is part of the European Green Deal. It amends two existing directives to tighten the framework for environmental claims made in B2C (consumer) contexts and to strengthen the anti-greenwashing regime.

Three operational principles to remember:

  • Mandatory independent substantiation — any environmental claim ("sustainable construction", "low-carbon building", "biodiversity-positive operation", "decarbonised portfolio", "eco-responsible product"…) must rest on attested external verification, not on a mere internal declaration.
  • Claimant liability — the party that makes the claim is legally responsible for it. Not the engineering firm, not the consultant, not the certifier: the developer, the local authority, the asset manager, the manufacturer who signs the communication.
  • Immediate withdrawal in case of non-compliance — upon notification by the authorities, following certification revocation, conviction or framework withdrawal, the claim must be withdrawn within 14 to 30 days.

The 3 levels of proof

Approach · Assessment · ISO/IEC 17065 certification.

Not all environmental claims are equal. European doctrine distinguishes three levels of proof, increasingly defensible before an auditor, the authorities or in litigation.

Level 1

Internal approach

Commitment documented in internal reporting, a CSR policy or corporate communication. Low defensibility: substantiation rests on the company itself. Insufficient for Directive 2024/825 in most cases.

Level 2

Measured third-party assessment

Audit or scoring performed by a competent third party outside the ISO/IEC 17065 framework (e.g. BPS — Biodiversity Performance Score). Intermediate defensibility: documented method, published protocol, traceable results. Suitable for most factual claims.

Level 3

ISO/IEC 17065 certification

Certification issued by an independent third-party body under ISO/IEC 17065. Maximum defensibility: the standard attests to the body's independence, competence and reliability. Example: Effinature operated by IRICE.

The stronger the claim ("biodiversity-positive", "carbon-neutral", "100% sustainable"), the higher the required level of proof. Recommended strategy: use level 3 for claims with high commercial or legal stakes, level 2 for quantified ESG indicators, level 1 for internal strategic commitments.

Who is concerned

Every actor that makes environmental claims.

Developers and land planners

Any mention of "eco-district", "low-carbon project", "biodiversity-friendly operation" or "sustainable construction" in a sales brochure, website or property listing must be substantiated.

REITs and landlords

Any communication about a "green" portfolio, "decarbonised" assets or portfolio-level biodiversity commitments must rest on auditable data. Directly connected to CSRD ESRS E1/E4 reporting.

Asset managers

An SFDR Article 8/9 fund, an "SRI" product or a "net-zero" portfolio all make environmental claims. Directive 2024/825 reinforces the requirements already arising from regulators' doctrine on ESG financial claims.

Manufacturers and retailers

In-house labels, "eco" packaging, product commitments ("recyclable", "biodegradable", "sustainably sourced"), published corporate carbon footprints. Everything runs through independent substantiation.

Local authorities

A municipality's institutional communication about its "climate", "biodiversity" or "net zero land take" policies falls under the directive. Connected to public-procurement environmental clauses.

Communicators and agencies

Agencies that produce the materials (campaigns, websites, brochures) do not issue the claims in their own name, but their duty of care grows. Checking that the client holds the substantiation is now an essential precaution.

The NORMAXIS approach

Securing your claims before publication.

NORMAXIS intervenes before, during and after claims are made:

  • Pre-publication audit — review of communication materials (brochures, website, listings, annual report, CSR) to identify at-risk claims and calibrate the required level of proof.
  • Technical substantiation — mobilising the proprietary tools operated by IRICE as an independent ISO/IEC 17065 third party: Effinature (biodiversity certification — level 3), BPS (biodiversity scoring — level 2), Efficarbone (construction carbon footprint — level 2 to 3 depending on use).
  • Evidence file — building the documentary corpus that accompanies each claim: framework used, archived primary data, calculation method, third-party attestations, legal references.
  • Continuous monitoring — watching regulatory developments (national transposition, authority decisions, case law) and periodically reviewing published claims.
  • Dispute management — responding to formal notices, preparing claim withdrawals, drafting compliant alternative claims.

For companies subject to the CSRD, the data produced by NORMAXIS serves both mandatory reporting and the substantiation of claims. One process, two compliances.

Directive 2024/825 key points

The structuring elements.

28/02/2024

Directive adoption

European Parliament + EU Council

March 2027

Transposition deadline

Deadline for Member States

3 levels

Of proof

Approach · Assessment · ISO/IEC 17065 certification

14–30 days

Claim withdrawal window

After authority notification

'Potentially yes. The directive covers any "explicit or implicit statement about the environmental characteristics" of a product, service or company. Vague terms ("sustainable", "green", "ecological", "natural", "friendly") are particularly targeted because they create a favourable impression without precise content. The rule of prudence: either remove these terms, or replace them with factual, quantified and substantiated wording ("−40% CO2 vs RE2020 baseline", "X ha of renaturated area", etc.).'], ['q' => 'Can my in-house certification framework serve as proof?', 'a' => 'Insufficient at level 3. An in-house framework falls under level 1 (approach) — low defensibility. A published, documented framework assessed by a competent third party falls under level 2 — medium defensibility. Only a framework certified by an independent ISO/IEC 17065 third party (such as Effinature at IRICE) reaches level 3 — maximum defensibility. Self-proclaimed labels or those managed without an ISO/IEC 17065 framework are vulnerable under the directive.'], ['q' => 'How does the directive interact with my CSRD reporting?', 'a' => 'CSRD data (double materiality, ESRS datapoints) is auditable by design (limited assurance). It can therefore substantiate a company\'s claims, under two conditions: (1) the claim does not go beyond what the data says (no commercial extrapolation), (2) the data is actually published in the sustainability report (accessible to the consumer). A marketing claim not backed by the CSRD report, even if the reporting exists, is vulnerable.'], ]" />

Go deeper

Related pages.

NORMAXIS

CSRD hub

CSRD data feeds substantiation. Double materiality, ESRS, transition plan.

Découvrir

Irice

Effinature biodiversity certification

Accredited third-party certification under ISO/IEC 17065.

Découvrir

Irice

Independent third-party certification body

Effinature, BPS, Efficarbone operated by IRICE under ISO/IEC 17065.

Découvrir

Secure your environmental claims?

Pre-publication audit of your materials, substantiation via the proprietary tools operated as an independent third party (Effinature, BPS, Efficarbone), evidence-file preparation, continuous monitoring and dispute management.

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