Green claims in fashion: since 27 September 2026, a label needs a scheme or an authority behind it.
Since 27 September 2026 the national rules transposing Directive (EU) 2024/825 apply across the EU. A sustainability label that is neither based on a certification scheme nor established by a public authority is an unfair commercial practice in every case, and so is a generic claim such as «eco-friendly» without recognised excellent environmental performance. The separate Green Claims Directive is blocked, not withdrawn.
What applies since 27 September 2026
Directive (EU) 2024/825 amends the two general laws that protect consumers across every sector in the EU: the Unfair Commercial Practices Directive and the Consumer Rights Directive. Member States had to adopt their measures by 27 March 2026 and apply them from 27 September 2026.
It defines an environmental claim, a generic environmental claim, a sustainability label and a certification scheme. It then adds practices to the list of those that are unfair in all circumstances, which means they are banned outright, with no case-by-case assessment. For a fashion brand these are the ones that matter most:
- Displaying a sustainability label that is not based on a certification scheme or not established by public authorities.
- Making a generic environmental claim for which the trader cannot demonstrate recognised excellent environmental performance relevant to the claim.
- Making a claim about the entire product when it concerns only one aspect of it.
- Claiming that a product is neutral, reduced or positive in greenhouse gas emissions on the basis of offsetting.
- Presenting a legal requirement that applies to all products of the category as a distinctive feature of the offer.
The Green Claims Directive: blocked, not withdrawn
The Green Claims Directive is a separate file: proposal COM(2023) 166 of 22 March 2023. It would require explicit environmental claims to be substantiated with a life-cycle assessment and verified by an accredited third party before publication. On 20 June 2025 the Commission announced that it intended to withdraw it. The withdrawal was never carried out.
The Commission's 2026 work programme lists the proposal among pending proposals, not among withdrawals, and the European Parliament describes its status as blocked. The prohibitions of Directive (EU) 2024/825 apply regardless of what happens to it.
Why a single score is off the table
The Product Environmental Footprint Category Rules for apparel and footwear, version 3.1 of 29 April 2025, are the method the sector agreed with the Commission's green light. Their own disclaimer does not allow the single score in business-to-consumer communication, nor its use to compare a product against the representative product.
A grade, a letter or a coloured scale built by a brand or a software vendor is a sustainability label. Without a certification scheme or a public authority behind it, displaying it is now an unfair practice in every case.
France adds its own rule. Anyone who communicates an environmental score on a textile sold in France must also communicate the official environmental cost, and from 1 October 2026 that duty applies without conditions.
What a claim needs
A claim that gives its specification in clear and prominent terms on the same medium is not a generic claim under the directive. It still has to be accurate, and it cannot present one aspect of a garment as the whole garment.
«Organic cotton» or «recycled polyester» is a statement about materials. Standing behind it means holding the certificate, checking its validity on the day, knowing the composition of the garment and knowing the chain that carried the fibre. Those are supply-chain data, and they come from suppliers.
Figures with their sources, the State's score where there is one, and the documents behind each claim.
Figures, never grades
Tramaproof assigns no grade, letter or label. The Impact tab shows figures in kg CO2e, per product and per stage, each with its sources and the share that rests on supplier documents rather than on averages.
The official score, with its date and version
For the French environmental cost, Tramaproof shows the figure returned by the State's Ecobalyse calculator, with the day it answered and the version of the method. Its own estimate appears only where that calculator has not answered, marked as provisional.
The documents behind one sentence
For a claim on material content, origin, certification, recycled content or chemical compliance, Tramaproof lists the requirements that substantiate it, each satisfied or missing, and produces a dated PDF with a third-party timestamp. The dossier does not certify the claim; the claim remains the brand's.
Questions about green claims
Has the Green Claims Directive been withdrawn?
No. The Commission announced on 20 June 2025 that it intended to withdraw the proposal, and did not do so. Its 2026 work programme lists the file among pending proposals, and the European Parliament describes it as blocked. It has no application date.
What has applied since 27 September 2026?
The national rules transposing Directive (EU) 2024/825. They make unfair in all circumstances: sustainability labels without a certification scheme or a public authority behind them, generic claims without recognised excellent environmental performance, whole-product claims that concern one aspect, and neutrality claims based on offsetting.
Can a brand print a PEF single score on a label?
Not under the PEFCR for apparel and footwear. Version 3.1 does not allow the single score in communication to consumers, nor its use to compare a product against the representative product.
What makes a sustainability label lawful?
Being based on a certification scheme or established by a public authority. A certification scheme, as the directive defines it, is third-party verification open to every trader on fair terms, with procedures for non-compliance and monitoring by a party independent of both the scheme owner and the trader.
Does Tramaproof say whether a claim is lawful?
No. Tramaproof shows which documents stand behind a claim and which are missing. It does not judge the wording of a claim, and a dossier does not certify it.