The EU's Green Claims Directive Is on Hold: What It Would Have Meant for Influencer Sustainability Content

Short answer: on hold, not formally withdrawn

On 20 June 2025, the European Commission announced its intention to withdraw the proposed Green Claims Directive — three days before a third round of trilogue negotiations between Parliament, the Council and the Commission, scheduled for 23 June 2025, which was then cancelled. The proposal has not been formally withdrawn: the Commission's own 2026 Work Programme, adopted 21 October 2025, still listed it as pending, and several independent legal trackers that follow the file report no progress expected in the foreseeable future. This is a separate, distinct matter from the EU's Empowering Consumers for the Green Transition Directive (ECGT), which is already in force and is covered in full in Make Influence Academy's article on environmental and sustainability claims.

This is practical guidance from Make Influence, not legal advice. This status is actively moving — check the European Parliament's Legislative Train Schedule for the latest development before relying on anything in this article for a decision.

What would the Green Claims Directive have required?

The proposal, tabled by the Commission on 22 March 2023, would have introduced a requirement ECGT doesn't have: that explicit (voluntary) environmental claims and sustainability labels — for example "climate neutral," "100% recyclable material composition" or a self-designed green logo — be verified by an independent, accredited third party before being used with consumers ("ex-ante" verification), and be backed by "recognised scientific evidence and the latest technical knowledge." For climate-specific claims such as "net zero" or "carbon neutral," companies would additionally have had to report offsetting and emissions data separately, state whether the offset represented an actual reduction or a removal elsewhere, and disclose the accounting methodology used. Member states would designate a national competent authority for ongoing monitoring and verification.

Micro-enterprises (fewer than 10 employees and under EUR 2 million in turnover) would have been exempt by default, unless they chose to opt in — an exemption the European Parliament had already agreed to in its negotiating position.

Timeline: from proposal to pause

Why hasn't it simply been withdrawn, if the Commission says it wants to?

Because the legal mechanics aren't that simple. Once the European Parliament and the Council have both adopted their own negotiating positions on a proposal — which is the case here — EU case law holds that the Commission cannot unilaterally withdraw it without justification, unless both institutions support the withdrawal. Parliament's responsible committee chairs have publicly said they're ready to resume negotiations. A further sticking point is the micro-enterprise exemption itself: the Commission has signalled that reconsidering the withdrawal is only relevant if micro-enterprises are brought back within the directive's scope — the opposite of the exemption Parliament has already accepted. The result is a proposal that is neither adopted, dead, nor formally closed.

How is this different from ECGT, which already applies?

It's easy to conflate the two, because both concern environmental claims. The difference is the mechanism: ECGT (the Empowering Consumers for the Green Transition Directive, transposed into Danish law and applying from 27 September 2026) bans a list of specific, named practices after they're used — automatically misleading, with no prior approval required. The Green Claims Directive would have required prior verification by an independent third party before an explicit environmental claim or sustainability label was used at all — regardless of whether the claim itself was accurate and documented.

See environmental and sustainability claims in influencer marketing: what Danish law requires for the full walkthrough of ECGT and the Danish rules that already apply.

What would this have meant for influencer content specifically, if adopted?

If an influencer today calls a product "climate neutral" or displays a sustainability label in a paid or gifted collaboration, ECGT's requirement is that the brand can document the claim if Forbrugerombudsmanden asks — a burden of proof that arises after the fact. Under the proposed Green Claims Directive, the requirement instead would have been that an independent verifier had approved the claim before it ever reached an influencer's brief — turning the approval step itself into part of campaign planning, not just a documentation exercise if someone later questioned it.

Decision framework: what should a Danish brand do right now?

IF you're planning a campaign with environmental or sustainability claims → comply with ECGT, which is already law from 27 September 2026 — not the Green Claims Directive, which isn't law and doesn't look likely to become one soon.

IF a partner or agency claims "the new EU Green Claims Directive requires X" → that isn't accurate. No directive has been adopted, and negotiations are on hold.

IF you still want a high standard for your environmental claims → voluntary, prior third-party verification (e.g. a recognised certification scheme) is already possible today, independent of whether the directive is ever adopted — it's simply not a legal requirement.

IF you're tracking the directive's progress for long-term planning → don't expect binding rules before 2027-2028 at the earliest, even if negotiations resume in 2026, given the ordinary EU legislative process.

Make Influence's perspective

In our experience, the practical risk for a Danish brand isn't an EU directive that's on hold — it's confusing it with the rules that already apply. We regularly see briefs that vaguely reference "the new EU rules on green claims" without distinguishing between ECGT (which actually takes effect on 27 September 2026) and the Green Claims Directive (which is on hold and may never happen). Our recommendation is to spend the effort complying with ECGT's documentation requirements today — see the full walkthrough — and keep a light, ongoing watch on the Green Claims Directive, rather than building a compliance process around a proposal that could change substantially or fall away entirely.

FAQ

Is the Green Claims Directive dead?

It's neither adopted, formally withdrawn, nor officially dead. The Commission has announced an intention to withdraw the proposal, but per several independent legal trackers that hasn't happened formally, and the Commission's own 2026 Work Programme (21 October 2025) still listed it as pending.

Does this mean the rules on green claims in Denmark are on hold?

No. The ECGT Directive, already transposed into Danish law and applying from 27 September 2026, is unaffected. See environmental and sustainability claims in influencer marketing for the rules that actually apply.

What was the central sticking point that led the Commission to consider withdrawal?

Per the EPP's letter of 18 June 2025, the main objection was the requirement for prior (ex-ante) third-party verification of every individual claim, which the group called overly complex, administratively burdensome and costly for businesses.

Can the Commission just withdraw the proposal if it wants to?

Not straightforwardly. Once Parliament and the Council have both adopted their negotiating positions, EU case law requires a withdrawal to be justified, unless both institutions support it. That's part of why the proposal is stuck in a legal grey zone rather than being closed.

When could the directive be adopted, if negotiations resume?

That isn't settled. Independent legal trackers that follow the process point to a possible conclusion no earlier than 2026, with full application possibly not until 2027 or 2028 — but that assumes negotiations resume at all, which hadn't happened as of this article.

Should I wait to fix my environmental claims until this directive is resolved?

No. ECGT is already law with a fixed application date (27 September 2026), independent of the Green Claims Directive's fate. See the article on ECGT and Danish rules for what actually needs action now.

Is this the only EU influencer-marketing law that's on hold?

No. The Digital Fairness Act is another EU initiative that explicitly names influencer marketing but doesn't yet exist as legal text. See the EU Digital Fairness Act for that proposal's status.

What should I do if I already have a campaign planned with an environmental claim that would need verification under the proposed directive?

Comply with the rules that actually apply today — ECGT and Forbrugerombudsmanden's recommendations — and optionally use voluntary third-party verification as extra assurance if the claim is central to the campaign. See influencer marketing in regulated industries and what to put in an influencer contract for how this kind of documentation requirement is normally written into an agreement.

Does any of this apply specifically to testimonials where an influencer names a specific environmental result?

Yes, the same underlying principle as for other factual claims: if an influencer's statement is reused by the brand as a testimonial about an effect or result, the ordinary testimonial documentation duty applies on top of the environment-specific rules. See using influencer content as a testimonial for the full walkthrough.

Is there a related EU rule that will make a product's own data publicly checkable, separate from these marketing-law claims?

Yes — the Digital Product Passport, a forthcoming product requirement under the EU's Ecodesign for Sustainable Products Regulation (ESPR), planned for textiles from Q4 2027. It doesn't regulate marketing claims itself, but it will let anyone scan a garment's tag to check specific material data directly. See the EU Digital Product Passport: what it will mean for fashion influencer campaigns.