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Explainer

Green Claims Directive: may I still call my transport "green" or "carbon-neutral"?

Adopted 2026-06-16 · ≈ 2 min read · Dirk Baaijen

For now, yes, but the EU proposal COM(2023) 166 would require environmental claims like "green" or "carbon-neutral" to be substantiated and verified up front. It is a proposal, not law yet. Start substantiating your claims measurably now.

Short answer: For now, you may still call your transport "green" or "carbon-neutral", because the Green Claims Directive is still a proposal and not law. But the proposal would require such claims to be substantiated and independently verified up front. If you substantiate your claims measurably now, you will not be caught out later.

What the proposal wants

In 2023 the European Commission published a proposal for a Green Claims Directive (COM(2023) 166). It targets explicit environmental claims that companies make voluntarily towards consumers, such as "green transport", "climate-neutral delivery" or "carbon-neutral shipping".

The core of the proposal:

  • Substantiate up front: an environmental claim must rest on recognised scientific evidence, covering the full life cycle.
  • Verify up front: an independent body must check the substantiation before you use the claim.
  • Vague claims banned: generic terms like "green", "eco" or "environmentally friendly" without proof would no longer be allowed.

The proposal builds on the Empowering Consumers Directive, which tackles misleading sustainability claims (greenwashing).

Important: this is still a proposal

The Green Claims Directive has not yet been adopted and is still under negotiation between the EU institutions. The outcome is uncertain; there has even been talk of reconsidering the whole file. So treat it as a proposal that signals direction, not as law you can base obligations on today.

What already applies is the broader ban on misleading claims through the Empowering Consumers Directive and general consumer law. An unsupportable "carbon-neutral" claim can already be deemed misleading today.

What to do now

Do not wait for the final text. The practical line is the same, whatever the proposal becomes:

  • Make claims measurable: calculate transport emissions using a recognised method. For transport and logistics, ISO 14083 is the standard for calculating and reporting greenhouse gas emissions across transport chains.
  • Be specific: replace "green" with a concrete, substantiated figure, or avoid the term.
  • Document: keep the calculation, assumptions and sources so you can prove a claim on request.
  • Be careful with "neutral": offset-based claims are under pressure; substantiate the actual reduction first.

Read more: the Transport & Logistics overview. Take the scan.

Sources

  1. https://environment.ec.europa.eu/topics/circular-economy/green-claims_en
    European Commission — Green Claims (substantiation of environmental claims).
  2. https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52023PC0166
    Proposal COM(2023) 166: Green Claims Directive (not yet adopted).

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