How fashion brands can meet the EU Green Claims Directive and CSRD standards

The new reality: say less, prove more

Greenwashing is no longer a low-risk brand tactic, it’s a legal liability.

The intention behind the EU Green Claims Directive is to create a single set of EU-wide rules to combat greenwashing. Although the EU Green Claims Directive has been deferred in the new Commission work programme (removed from the fast track, with implementation likely in 2027), its principles are already being enforced through:

• the 2024 updated EU Unfair Commercial Practices Directive (UCPD) [binding across the EU],

• enhanced consumer protection rules, and

• strict national green claims laws in markets such as France, the Netherlands, Germany, the Nordics, and the UK.

These rules require that any environmental claim be specific, evidence-based, traceable, and independently verifiable. Regulators have already executed on their authority to demand substantiation, issue fines, or require the withdrawal of misleading marketing.

This enforcement sits alongside CSRD (Corporate Sustainability Reporting Directive), which is now fully in force for thousands of larger companies, expanding both the depth and scope of ESG reporting. CSRD demands comprehensive ESG reporting based on the European Sustainability Reporting Standards (ESRS), with deep disclosures across Scope 1, 2, and 3 emissions, material usage, waste, water, and more.

For fashion brands, the legal expectation is unchanged despite the Directive’s deferment:

Every sustainability message is now a legal statement, and must be documented, traceable, and kept aligned across platforms.

This applies to product tags, ecommerce descriptions, influencer content, sustainability reports, paid ads, and investor communications.

What do today’s EU and UK Green Claims rules actually require from fashion brands?

Across the EU (and the UK), existing law already requires that any public-facing environmental claim be:

• Specific and substantiated

• Based on a recognized methodology

• Supported by accessible, verifiable evidence

• Kept up to date and consistent across channels

France and the Netherlands go even further:

• Claims like “climate neutral”, “eco-friendly”, “biodegradable”, or “recyclable” must meet stringent evidence standards.

• The French AGEC law bans misleading claims and mandates evidence-based product disclosures.

• The Netherlands ACM publishes strict sector guidance and actively audits fashion.

The deferment of the Green Claims Directive does not ease compliance pressure. If anything, enforcement is expanding through existing law.

Inconsistent claims between marketing campaigns and sustainability reports will no longer be tolerated. Alignment is essential.

When does CSRD enforcement begin for different types of fashion and apparel companies?

How do CSRD, Green Claims rules, and PEFCR work together - and what does that mean for fashion brands?

These three frameworks in the EU market are interlinked but differ in scope:

1. CSRD

A company-level ESG framework requiring disclosures on:

• climate governance

• Scope 1, 2, and 3 emissions

• material use

• water and waste

• impacts across the value chain

• double materiality (financial + environmental/social impact)

2. Green Claims requirements (via UCPD + national law)

These apply at the product and marketing level, ensuring consumer-facing claims are not misleading.

3. PEFCR (Product Environmental Footprint Category Rules)

A harmonized LCA methodology for apparel and footwear, providing the scientific backbone for product-level impact claims.

In 2025, the EU approved the final PEFCR methodology for apparel and footwear, setting common rules for product-level impact calculations adopted by the EU for use in future regulatory requirements.

To avoid contradictions, fashion and apparel brands must ensure that:

• product claims based on PEFCR match the emissions data used in CSRD disclosures;

• supplier certifications used in claims also appear in traceability records and Digital Product Passports; and

• forward-looking commitments (e.g., ‘net zero by 2030’) are reflected consistently across all published materials, such as sustainability reports, websites, and marketing content.

To comply, brands must triangulate these frameworks, ensuring product-level claims match operational reporting and are grounded in credible impact calculations.

What evidence do fashion brands need to prove sustainability claims under EU law?

Let’s take an example: a garment marketed as 'made with 70% recycled cotton.' To support this claim under the Green Claims Directive, the brand would require this evidence:

• a certified chain-of-custody certificate (e.g., GRS - Global Recycled Standard transaction certificate);

• traceable input-output records from material origin through the spinning of yarn and fabrication of materials used in the garment;

• evidence of third-party verification; and

• alignment with actual product composition disclosed in the Digital Product Passport (DPP).

CSRD would then require the company to include:

• Scope 3 emissions from cotton cultivation, recycled feedstock, transport, and processing;

• risk assessments related to recycled material sourcing and future availability; and

• dependencies, performance, and progress toward stated circularity or impact-reduction targets.

Misalignment across these systems (claims vs. DPP vs. CSRD) is now a compliance risk, and could result in reputational damage, product withdrawal, or legal challenge.

Why are environmental claims facing new regulatory scrutiny, and what proof is required?

Environmental claims such as “carbon neutral”, “reduced impact”, “eco materials”, “sustainably made”, or “closed-loop collection” must be backed by:

• Lifecycle-based environmental impact data

• Supplier-verified material and process data

• Auditable proof accessible to consumers and regulators

• Independent verification (where applicable)

Meanwhile, under CSRD, brands must also disclose:

• ESG risk exposure and value chain impacts

• policies

• reduction targets and transition plans

• governance structures

• actual impact performance

Marketing, product claims, DPPs, and CSRD filings must now align seamlessly.

How will Digital Product Passports (DPPs) change sustainability reporting for fashion brands?

DPPs are a cornerstone of the EU's strategy to create a digital traceability system for consumer goods. They are not just product 'ID cards', they are living records of environmental, material, and compliance data designed for use across the product lifecycle.

In fashion, DPPs will facilitate:

• Evidence of product content and origin, recycled content, and durability.

• Clear guidance on care and repair, and easy access to these services.

• Accurate end-of-life sorting and recycling.

• Second-hand resale and return programs.

• Green public procurement.

• Automated claim validation via QR codes or NFC tags (and RFID for scaling circularity operator processes) = packaging free digital labelling.

For brands, the challenge is integrating diverse data streams - LCA calculations, supplier declarations, certifications, and care instructions - into a single, accessible profile. BlueCherry ESG can serve as the system of record for all these datapoints.

DPPs will become mandatory for most fashion products under the Ecodesign for Sustainable Products Regulation (ESPR) by 2027/28 (exact dates yet to be confirmed by the EU). They are expected to require product composition, material origin, recycled content and target (25-35%), durability test results, recyclability, certifications, care & repair instructions, environmental data and later eco-scores (PEFCR).

DPPs act as compliance infrastructure, connecting brand claims with regulatory disclosures and consumer-facing transparency.

Why is data accuracy now a legal requirement for sustainability claims?

In addition to consistency, brands must demonstrate data accuracy. This means:

• Using primary data from suppliers and facilities wherever possible.

• Maintaining version control and timestamps for every data update.

• Ensuring all claims are linked to supporting documents (certifications, LCA models, audit results).

• Avoiding use of outdated, templated, average-based, or unverifiable information.

These requirements increase the cost of compliance, but they also raise the quality of sustainability communication. Brands that invest in robust infrastructure today will avoid costly remediation, product delisting, or regulatory action down the line.

Gone are the days of spreadsheets and static PDFs. Under CSRD and Green Claims, brands must:

• Centralize their ESG, product, and supplier data.

• Ensure consistency across platforms.

• Provide clear audit trails and evidence of accuracy.

This requires reliable infrastructure that links primary data sources with reporting and marketing outputs.

This is both a compliance requirement and an operational efficiency opportunity.

How can BlueCherry ESG help fashion brands verify claims and comply with CSRD and Green Claims rules?

BlueCherry ESG enables fashion brands to manage product-level and corporate sustainability data in one auditable platform:

• Capture traceability data, from material origin and chain of custody to process, energy, GHG emissions, water, waste, and circularity data across the value chain.

• Validate claims using PEF-based scores, supplier declarations, and certification evidence.

• Generate and populate EU-compliant Digital Product Passports.

• Produce CSRD-ready disclosures aligned with ESRS.

• Maintain a complete audit trail for claims, data sources, and certifications.

The result is a single source of truth, reducing compliance risk and improving brand credibility.

What happens when fashion brands can’t substantiate their sustainability claims under EU and UK law?

Enforcement of these regulations is not hypothetical. Several countries, including France, the Netherlands, and Germany, have already begun investigating and penalizing misleading claims.

• France has fined brands for misleading “carbon neutral” claims

• The Netherlands ACM has sanctioned fashion retailers over unverifiable sustainability messaging

• Germany has issued injunctions against ambiguous environmental terms

• The UK CMA continues to enforce its Green Claims Code

• EU consumer authorities regularly conduct coordinated “sweep” investigations

The deferment of the EU Green Claims Directive does not weaken enforcement - national authorities are increasingly assertive.

For fashion brands, now is the time to audit your sustainability messaging across all touchpoints, from labels to leadership reports, and build a system that ensures every claim is supported by verifiable evidence.

From investors to regulators and consumers, the expectation is clear: don’t just say it, prove it.

By aligning product claims, regulatory reports, and ESG data, brands can avoid risk while building long-term trust and differentiation.

The new bar isn’t transparency for its own sake, it’s verifiable, consistent evidence. Those who prepare now will lead in 2026 and beyond.

Want to build an integrated, auditable, and future-ready ESG data ecosystem?

Explore how BlueCherry ESG can help you bridge compliance and competitiveness, from DPPs to CSRD. Reach out to us today to learn more.