How much evidence is really behind terms such as “green”, “sustainable” or “carbon neutral”?
This is becoming increasingly important for both businesses and consumers. According to the European Commission, 53% of environmental claims assessed in the European Union contain vague, misleading or unfounded information, while 40% are not supported by evidence. The EU also has around 230 sustainability labels, with widely varying levels of transparency and verification.
The environmental context shows why this goes far beyond communication. In 2023, the European Union generated 79.7 million tonnes of packaging waste, equal to 177.8 kg per person. Globally, the Food and Agriculture Organization of the United Nations (FAO) estimates that around 420 million hectares of forest were lost to deforestation between 1990 and 2020.
Against this backdrop, the EU regulatory framework is increasingly connecting environmental communication, product data, supply chain information and traceability. This includes consumer protection rules as well as regulations such as the EU Deforestation Regulation (EUDR) – Regulation (EU) 2023/1115, the Packaging and Packaging Waste Regulation (PPWR) – Regulation (EU) 2025/40, and the Ecodesign for Sustainable Products Regulation (ESPR) – Regulation (EU) 2024/1781, together with the latest changes introduced by the Omnibus I package on sustainability reporting and due diligence and the EU Forced Labour Regulation (EUFLR) – Regulation (EU) 2024/3015.
At the same time, the European Union is working to simplify the regulatory framework, reducing certain obligations and making them more proportionate for businesses. This does not remove the need for reliable information. On the contrary, collecting and reusing structured supply chain data can help reduce duplication and make compliance with different regulatory requirements more efficient.
What changes from 27 September 2026
From 27 September 2026, the provisions introduced by Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 will apply in Italy. The Directive amends Directive 2005/29/EC on unfair commercial practices and Directive 2011/83/EU on consumer rights.
Italy transposed the Directive through Legislative Decree No. 30 of 20 February 2026, which entered into force on 24 March 2026. Article 2 of the Decree, however, expressly states that its provisions apply from 27 September 2026.
From that date, the rules governing how companies can use green claims, sustainability labels and other environmental claims aimed at consumers will change significantly.
Practices considered misleading include, among others, generic environmental claims where a company cannot demonstrate recognised excellent environmental performance; claims relating to an entire product or business when they concern only one specific aspect; sustainability labels that are not based on a certification scheme or established by a public authority; and claims that a product has a neutral, reduced or positive climate impact when these are based on greenhouse gas emission offsetting.
Claims concerning future environmental performance must also be based on clear, objective, publicly available and verifiable commitments, supported by a realistic implementation plan with measurable targets and defined deadlines.
Consumer protection rules also change from 27 September 2026
Directive (EU) 2024/825 introduced new EU rules against greenwashing and to improve transparency around environmental information. In Italy, Legislative Decree No. 30 of 20 February 2026 transposed these provisions by amending Legislative Decree No. 206 of 6 September 2005 – the Italian Consumer Code, particularly the rules on unfair commercial practices.
From 27 September 2026, the new rules will apply: unsupported generic green claims, non-compliant sustainability labels and certain climate claims based on emission offsetting may therefore be treated as unfair commercial practices.
The Decree does not introduce a specific penalty for greenwashing. Instead, these practices fall under the existing enforcement system of the Consumer Code. Where a violation is established, the Italian Competition Authority (AGCM) may impose, under Article 27, an administrative fine ranging from €5,000 to €10 million, depending on the seriousness and duration of the infringement and the company’s financial position.
For businesses, the accuracy of green claims is therefore not only a reputational issue, but also a matter of regulatory compliance and risk management.
Green Claims Directive and Directive (EU) 2024/825: don’t confuse the two
The so-called Green Claims Directive is the proposal COM(2023) 166, designed to introduce specific requirements for substantiating and communicating voluntary explicit environmental claims, including verification by independent and accredited third parties.
On 20 June 2025, the European Commission announced its intention to withdraw the proposal if obligations considered disproportionate for microenterprises remained in the text. The trilogue scheduled for a few days later was cancelled.
However, the withdrawal has never been formalised, and the proposal remains pending in the EU legislative process. The stricter framework envisaged by the Green Claims Directive — based on specific substantiation of environmental claims and independent verification — is therefore not currently in force, while the future of the proposal remains uncertain.
PPWR: linking packaging claims to technical evidence
Another key date has already passed: the Packaging and Packaging Waste Regulation (PPWR) – Regulation (EU) 2025/40 has applied across the European Union since 12 August 2026.
The Regulation is particularly relevant to the relationship between sustainability claims and the evidence needed to support them.
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Article 14, which covers environmental claims on packaging, states that claims relating to characteristics regulated by the PPWR may only be made where performance exceeds the applicable minimum requirements. Companies must also specify whether the claim refers to the entire packaging unit, one part of it, or all packaging placed on the market by the operator.
Crucially, compliance with these requirements must be demonstrated in the packaging’s technical documentation.
The PPWR also progressively strengthens the use of harmonised labels and digital tools to communicate packaging information, supporting a more structured approach to data throughout the packaging life cycle.
It also introduces digital traceability requirements. For reusable packaging placed on the market from 12 February 2029, or 30 months after the relevant implementing act enters into force if that date is later, information on reusability must also be made available through a QR code or another open, standardised digital data carrier, supporting packaging traceability and the calculation of reuse rotations.
EUDR: traceability back to the origin of raw materials
Traceability plays an even more direct role in Regulation (EU) 2023/1115 of 31 May 2023 on the making available on the Union market and the export from the Union of certain commodities and products associated with deforestation and forest degradation, commonly known as the EU Deforestation Regulation (EUDR).
The EUDR covers cattle, cocoa, coffee, oil palm, rubber, soy and wood, as well as derived products listed in Annex I. Due diligence information includes the geolocation of the plots of land where the relevant commodities were produced.
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Following the changes introduced by Regulation (EU) 2025/2650 of 19 December 2025, which amended EUDR obligations for operators and traders, most provisions will apply from 30 December 2026. For micro and small enterprises established by 31 December 2024, the deadline is 30 June 2027, subject to specific provisions for wood and derived products.
For companies in scope, linking geographic origin, suppliers, raw materials, products and documentation turns digital traceability into a practical compliance tool.
From products to the Digital Product Passport
The same trend can be seen in Regulation (EU) 2024/1781 of 13 June 2024 establishing a framework for setting ecodesign requirements for sustainable products, known as the Ecodesign for Sustainable Products Regulation (ESPR).
The ESPR establishes the regulatory framework for the Digital Product Passport (DPP), which will progressively collect and make available information on product groups covered by specific delegated acts.
A concrete application is already approaching. Regulation (EU) 2023/1542 of 12 July 2023 concerning batteries and waste batteries requires that, from 18 February 2027, batteries for light means of transport, industrial batteries with a capacity above 2 kWh and electric vehicle batteries must be electronically registered through a battery passport.
Further obligations will later apply under Directive (EU) 2024/1760 on corporate sustainability due diligence, commonly known as the Corporate Sustainability Due Diligence Directive (CSDDD).
Following the changes introduced by Directive (EU) 2026/470 of 24 February 2026, which amends, among other measures, Directive (EU) 2024/1760 with regard to certain corporate sustainability due diligence obligations, Member States must complete transposition by 26 July 2028 and apply the measures from 26 July 2029. The new general scope includes, among the cases covered by the Directive, EU companies with more than 5,000 employees and worldwide net turnover exceeding €1.5 billion.
From claims to evidence: the role of digital traceability
The rules on environmental claims, the EUDR, PPWR, ESPR, CSDDD and EUFLR have different objectives and scopes, but they point in the same direction: data is becoming an increasingly important part of sustainability and regulatory compliance.
This shift from claims to evidence is where digital traceability can play a strategic role. Meeting different regulatory requirements is not simply about having information available. Companies need to connect data on suppliers, raw materials, geographic origin, batches, products, packaging and documentation, while keeping that information structured and verifiable over time.
This is the principle behind Trusty’s technology, developed to support end-to-end supply chain traceability and the management of information needed for regulatory compliance. It is particularly relevant to the EUDR, where origin and geolocation of raw materials are core elements of due diligence, but is also increasingly relevant to the PPWR and other regulations introducing digital tools and information requirements throughout the product life cycle.
As the EU also moves towards simplifying compliance requirements, the ability to collect data once, structure it and reuse it for different purposes can help reduce duplication and operational complexity. Technology does not replace the obligations imposed by individual regulations, but it can make compliance more efficient, traceable and easier to demonstrate.
Key dates to monitor
- 12 August 2026: the Packaging and Packaging Waste Regulation (PPWR) became applicable.
- 27 September 2026: the new rules on environmental claims introduced by Directive (EU) 2024/825 become applicable in Italy.
- 30 December 2026: most obligations under the EU Deforestation Regulation (EUDR) become applicable.
- 18 February 2027: the battery passport required under Regulation (EU) 2023/1542 becomes applicable to batteries for light means of transport, industrial batteries above 2 kWh and electric vehicle batteries.
- 30 June 2027: the main EUDR obligations become applicable to operators established as micro or small enterprises by 31 December 2024, subject to the specific exceptions for products already covered by the previous EU Timber Regulation (EUTR).
- 14 December 2027: Regulation (EU) 2024/3015 (EUFLR) becomes applicable, prohibiting products made with forced labour from being placed or made available on the EU market or exported from the EU.
- From 12 August 2028, or later depending on the relevant implementing acts: new harmonised PPWR packaging labelling requirements will progressively apply.
- 26 July 2029: the obligations under the Corporate Sustainability Due Diligence Directive (CSDDD) become applicable to companies falling within the revised scope following Omnibus I.
Main sources
European Commission, Green Claims; Directive (EU) 2024/825; Italian Legislative Decree No. 30 of 20 February 2026; Italian Legislative Decree No. 206 of 6 September 2005 – Consumer Code; European Parliament, procedure 2023/0085(COD); Regulation (EU) 2025/40 on packaging and packaging waste; Regulation (EU) 2023/1115 on deforestation and forest degradation and Regulation (EU) 2025/2650; Regulation (EU) 2024/1781 establishing a framework for setting ecodesign requirements for sustainable products; Regulation (EU) 2023/1542 concerning batteries and waste batteries; Directive (EU) 2024/1760 on corporate sustainability due diligence and Directive (EU) 2026/470; Regulation (EU) 2024/3015 prohibiting products made with forced labour on the Union market; Eurostat, Packaging waste statistics; FAO, Global Forest Resources Assessment 2020.
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