Green Claims & DPP: Fighting Greenwashing
More and more companies want to communicate the environmental merits of their products, yet EU law is tightening the rules for that communication. The Empowering Consumers Directive aims to curb greenwashing — misleading environmental claims. This article explains how a well-prepared Digital Product Passport (DPP) helps make such claims credible and lowers your legal and reputational risk.
What the Empowering Consumers Directive is
The Empowering Consumers Directive, Directive (EU) 2024/825, tightens the rules on environmental claims and on generic "green" claims. Its overriding purpose is to protect consumers from misleading marketing.
Among other things, the directive restricts vague, unsubstantiated slogans such as "eco" or "environmentally friendly" when a company cannot back them with evidence. Misleading sustainability labels and marks are also in scope. The underlying expectation is simple: a claim should be specific and verifiable.
Greenwashing under the regulator's lens
Greenwashing means presenting a product as greener than it really is. It can take the form of exaggerating benefits, using imprecise wording, or highlighting a single positive trait while staying silent about significant drawbacks.
Typical risky messages include:
- generic slogans ("green", "eco") that never say what they refer to,
- claims with no accessible data to support them,
- labels or symbols implying a certification the product does not hold.
The new rules shift the burden onto the company: if you make an environmental claim, you must be able to prove it. Unsupported generalities become a legal and reputational risk, not just a matter of tone.
Why this is not the same as ESPR and the DPP
Empowering Consumers is a separate legal instrument and should not be confused with other regulations. It governs the content of marketing messages aimed at consumers, not the obligation to keep a product passport.
ESPR (Regulation 2024/1781) and the Digital Product Passport obligation are a different layer: they concern the structure of product data, not advertising rules. Yet the two worlds meet — and it is exactly at that meeting point that a DPP proves useful. We keep these regimes distinct on purpose.
The DPP as an evidence base for claims
A product passport gathers structured, verifiable data: composition, environmental and life-cycle information, and material traceability. This is precisely the kind of information that lets you back an environmental claim with specifics rather than a slogan.
If you state that a product contains a given share of recycled material, the data in the passport can document it. Instead of a blanket "eco-friendly", a company can point to checkable parameters — which genuinely reduces the risk of a greenwashing accusation and makes the message easier to defend.
Example: from a slogan to specifics
Picture the phrase "environmentally friendly product". On its own it is unverifiable, and claims like this carry the most risk. Replace it with something specific — a share of recycled material, or data on durability and reparability — and the message gains a factual basis.
The data in the passport lets you tie that specific point to a particular product and its documentation. When a customer or authority asks for the basis of the claim, the answer is ready and consistent.
What a DPP does and does not do
An important caveat: the passport itself is not a compliance tool for the claims directive. It does not judge whether your marketing message is lawful — that remains the job of the company and its advisers.
The DPP plays a supporting role: it supplies an organised, consistent factual basis. That makes it easier to build an evidence-based message and to demonstrate it if customers or authorities ask. It is a credibility tool, not a substitute for legal assessment.
Connecting data to communication
In practice, it helps to treat passport data as a single source of truth shared by the product, quality and marketing teams. The same dataset that feeds the DPP can substantiate content on a product page or in sales materials.
- Base environmental messaging on concrete parameters, not generalities.
- Keep the data current and versioned so the claim stays true over time.
- Keep the evidence linked to the product and ready to show.
A broader direction: substantiating claims
Substantiating environmental claims is a broader direction in EU policy that reaches beyond any single directive. The general logic is consistent: a claim should be backed by reliable, available data.
A company that already tidies its product data into a passport will be better prepared for these expectations. We describe similar data synergies in ESPR, batteries and CBAM and in the CBAM de-minimis threshold.
Key takeaways
- The Empowering Consumers Directive (EU) 2024/825 tightens the rules on environmental claims and targets greenwashing.
- It is separate from ESPR and the DPP obligation — it governs communication, not data structure.
- A DPP supplies verifiable data that helps substantiate environmental claims.
- The passport is not a compliance tool for the directive, but it supports a credible, evidence-based message.
- Responsibility for the content of claims stays with the company.
See how CyfroPass helps you organise product data and build a Digital Product Passport that is ready to demonstrate. Visit cyfropass.pl and start with your first product.