Environmental claims for non-food products

Rising consumption around the globe has increased pressure on the environment and created greater competition for resources. Reaching the EU climate, energy and resource efficiency targets depends also on consumer engagement. But for consumers to be able to make informed choices, businesses need to ensure that environmental claims are clear, accurate and reliable, in accordance with the Unfair Commercial Practices Directive (UCPD).  This is also a prerequisite for the market for ‘green’ or environmentally-friendly products to function properly.

Green products have the advantage of combining societal benefits of reduced environmental damage with higher satisfaction of consumers. There can be also relevant economic benefits for consumers, notably through more efficient use of resources, energy savings or a longer lifetime of products.

A report of the Multi-stakeholder Dialogue on Environmental Claims pointed to different challenges in this area. As a follow-up, the European Commission undertook an EU-wide  study to examine: the presence of environmental claims in different markets, aspects of consumer understanding and behaviour, the level of compliance with EU legal requirements, and different enforcement and self-regulatory instruments in a selection of EU and third countries.

Key findings of the study

• Environmental claims are widespread on both product packaging and in advertising. 76% of all the products assessed in shops contained an environmental claim, i.e. a message or suggestion that a product, or its packaging, has certain environmental benefits.
• Most of the environmental claims take the form of a logo, however also many textual messages as well as more implicit environmental claims (such as images and colours) were found.
• Consumers have a low level of understanding of green claims.  61% of consumers state that they find it difficult to understand which products are truly environmentally friendly, and 44% indicate that they do not trust this type of information. Consumers also appear unable to understand the meaning of environmental logos, and make no distinction between non-certified (self-declarations) and third party certified labels.
• Almost 60% of the respondents stated that they prefer to buy a product with an environmental label. Half of the consumers also look specifically for environmental information on the packaging when purchasing a product.
• A sample of claims was analysed against the Unfair Commercial Practices Directive to determine whether consumers are provided with clear, accurate and reliable information in relation to environmental claims in non-food products. Overall, the assessment pointed to possible non-compliance with EU legal requirements, as many of the analysed claims used vague terms and did not meet the requirements of accuracy and clarity. In addition, some claims seemed to contain untruthful statements.
• In several EU countries (such as CZ, DK, FR, FI, UK), guidelines on environmental claims have been published by public authorities, providing businesses and authorities with best practices for making and enforcing such claims. By providing businesses with best practices and guidelines, misleading claims can be prevented up front rather than being prohibited at a later stage.
• There is room for improvement on enforcement of environmental claims. Proactive surveillance or inspections are rather limited and in some cases inspectors have a limited knowledge about how to correctly interpret the Unfair Commercial Practices Directive with reference to environmental claims.

Study recommendations and next steps

The study includes a range of recommendations for the short, medium and longer term with the overall aim of assisting and encouraging consumers to be able to make sustainable purchasing choices. It includes recommendations on: a) the update of the Commission's UCPD Guidance document, b) strengthening of enforcement of environmental claims, c) consumer education and awareness campaigns and d) legal initiatives.

As a follow-up to the study, the Multi-stakeholder Dialogue on Environmental Claims is developing multi-stakeholder advice to support the implementation/application of the UCPD in this area. This work will be feeding into review process of the Commission's UCPD guidance document.

Related documents 

• Consumer market study on environmental claims for non-foods products
• Appendix 1 - Selection criteria and stakeholder consultation
• Appendix 2 - Inventory/presence green claims
• Appendix 3 - Consumer understanding
• Appendix 4 - Guidelines
• Appendix 5 - Assessment against UCPD, the 2009 guidance document and the voluntary food labelling guidelines
• Appendix 6 - Enforcement
• Environmental claims: factsheet
• 2013 Report from the Multi-stakholder dialogue on environmental claims
• Unfair commercial practices directive 2005/29/EC
• 2009 Guidance document on the implementation of the unfair commercial practices directive 2005/29/EC