Review of existing initiatives to inform potential climate-related delegated act(s) under the Green Claims Directive

As consumers increasingly demand products with a low climate impact, being ‘green’ has become a competitiveness factor for companies in the European Union (EU). However, if these products and services do not have the claimed environmental benefits, it could hamper the green transition and mislead consumers. Climate-related claims, such as “carbon neutral” or “net zero”, are especially prone to being unclear and ambiguous. Such claims could be misinterpreted as that the product is not associated with any emissions or that the company has reduced its own emissions to zero. Moreover, there is growing evidence that many of the carbon credits that back these claims have questionable environmental integrity (Haya et al. 2023). To address these risks, the European Commission (hereafter: Commission) put forward a proposal for a directive on substantiation and communication of explicit environmental claims (the 'green claims directive', GCD) on 22 March 2023, which is currently in co-decision.1 In later stages of the legislative process, delegated act(s) may provide further specifications regarding the implementation of the directive, including provisions on the substantiation of explicit environmental claims. This report aims to inform potential delegated act(s) under the GCD through an analysis of existing initiatives that aim to address integrity of climate-related claims, in particular in relation to the generation and use of carbon credits. The potential delegated acts could strengthen the integrity of green claims through either endorsing existing initiatives or using criteria from existing initiatives as basis for developing specific requirements.