“Eco-friendly”, “green”, “natural”: generic environmental claims explained

What makes a claim “generic”

EmpCo defines a generic environmental claim as an environmental claim, made in writing or orally (including audiovisual media), that is not included on a sustainability label, and where the specification of the claim is not provided in clear and prominent terms on the same medium.

So the test is not the word itself but whether the specific meaning is given right there. “Eco-friendly packaging” is generic. “Packaging made from 100% recycled cardboard” is specific.

Typical generic words

Recital 9 of the directive gives examples such as environmentally friendly, eco-friendly, green, nature's friend, ecological, environmentally correct, climate friendly, gentle on the environment, carbon friendly, energy efficient, biodegradable, biobased and similar statements suggesting or creating the impression of excellent environmental performance. In shop copy this often also includes:

• sustainable, conscious, responsible, planet-friendly, clean;
• natural, earth-friendly, ethical (when used in an environmental sense);
• green icons, leaves and globes used to suggest an environmental benefit.

Some terms, such as “biodegradable” or “energy efficient”, become acceptable when you state the specifics: biodegradable under which standard and in which conditions, energy efficient by which measure.

The only exception: recognised excellent environmental performance

A generic claim stays allowed only if you can demonstrate recognised excellent environmental performance relevant to the claim. That means one of:

• the EU Ecolabel under Regulation (EC) No 66/2010;
• a national or regional EN ISO 14024 type I ecolabel that is officially recognised in a Member State (for example the Nordic Swan or the Blue Angel);
• top environmental performance under other applicable EU law.

The performance must be relevant to the claim. An ecolabel for low emissions in production does not justify calling the product “biodegradable”.

The whole-product trap (point 4b)

Even a specific claim is banned if it presents an aspect as if it applied to the entire product or business. “Recycled backpack” when only the lining is recycled, or “sustainable brand” because one product line uses organic cotton, falls under point 4b.

How to rewrite: before and after

Evidence to keep

For every specific claim, keep the certificate, test report, supplier declaration or calculation that proves it, with the date and the product it applies to. Under consumer law the trader must be able to substantiate its claims when an authority asks.