Green Claims Code: Ensuring B2B procurement compliance against greenwashing risks

Summary

Environmental claims are proliferating in B2B supplier catalogues, yet their reliability is rarely verifiable. Faced with this reality, the European Union and the United Kingdom have engaged in a comprehensive reform of the legal framework governing green claims. For buyers, CSR managers and procurement directors, these developments are redefining the rules of supplier relationships and non-financial reporting right now. The end of supplier self-declaration is compelling organisations to review their selection processes, risk management and CSR reporting.

Contents

• Green Claims and Green Claims Code: What do these new anti-greenwashing regulations say exactly?
• The pillars of compliance: what the law concretely requires of businesses
• Green Claims and B2B procurement: the end of supplier self-declaration
• How to adapt your procurement processes to this new transparency requirement?
• Beyond the constraint: making environmental transparency a procurement performance driver

Environmental claims are proliferating in B2B supplier catalogues. “Eco-friendly”, “carbon neutral”, “sustainable”: these labels adorn an increasing number of product pages, yet their reliability is rarely truly verifiable. In this context, the European Union and the United Kingdom have engaged in a fundamental reform of the legal framework governing green claims. For buyers, CSR managers and procurement directors, these developments are no longer a distant prospect: they are redefining the rules of the supplier relationship and non-financial reporting right now.

Green claims and Green Claims Code: what do these new anti-greenwashing regulations say?

B2B buyers are exposed daily to hundreds of unverifiable environmental claims. The regulatory urgency is now twofold: on one side, the European Union is finalising a binding framework; on the other, the United Kingdom is already applying its own rules. Understanding these two systems is the first step towards securing your procurement and your value chain.

The Green Claims Directive Proposal (EU): prohibiting unsubstantiated environmental claims

The European Commission’s Green Claims Directive proposal, under reference COM/2023/166, aims to strictly regulate environmental claims relating to products and services, whether generic (“green”, “sustainable”), comparative (“less polluting than”) or label-based. This text is intended to apply to both B2C businesses and B2B operators who formulate or relay such claims. The adoption and implementation timeline remains subject to change, but businesses are already being encouraged to strengthen the robustness of their environmental evidence.

The Green Claims Code (UK): providing a parallel post-Brexit framework for green claims

In the United Kingdom, the Green Claims Code, published by the Competition and Markets Authority (CMA) in 2021 and regularly updated, constitutes the functional post-Brexit equivalent of the EU directive. It rests on six fundamental principles: accuracy of claims, clarity of message, absence of significant omission, fairness of comparisons, consideration of the full life cycle of the product, and verifiability by third parties.

In Switzerland, the State Secretariat for Economic Affairs (SECO) regulates environmental claims according to similar principles. In Norway, the Forbrukertilsynet[1] (the Norwegian Consumer Authority) applies comparable rules under the Nordic framework on unfair commercial practices.

Application timeline: deadlines for businesses

The UK Green Claims Code is already operational, and the CMA has launched sector-specific investigations. On the EU side, the Green Claims Directive is expected to be transposed by Member States from 2026 onwards, with compliance deadlines granted first to large businesses, then to SMEs.

B2B buyers are well advised to anticipate now: documentary compliance takes time, and suppliers themselves need to be supported through this transition in order to be able to produce the required evidence.

The pillars of compliance: what the law concretely requires of businesses

Compliance with the new anti-greenwashing requirements cannot be reduced to removing a few product catalogue mentions. It requires building a chain of documented, verifiable and scientifically recognised evidence. Three pillars structure this requirement, common to both the EU directive and the UK Green Claims Code.

The obligation of proof and now-prohibited claims

The Green Claims Directive and the UK Green Claims Code converge on one central point: all environmental claims must be clear and must rest on recognised and verifiable scientific data. Generic misleading claims without justification now fall under these regulations: “eco-friendly”, “green”, “sustainable”, “environmentally friendly”, or “carbon neutral” without supporting documentation. The B2B buyer who incorporates a product bearing an unsubstantiated claim into their procurement also engages their own liability: relaying a non-compliant claim means becoming jointly responsible for it in the eyes of the competent authorities.

This liability is part of a broader regulatory movement, where the duty of vigilance (A00560) requires businesses to document and prevent environmental and social risks across their entire value chain.

LCA, PEF and Third-Party Verification as reference standards

The European Commission recognises life cycle assessment (LCA) and the Product Environmental Footprint (PEF)[2] as the reference methodologies for substantiating environmental claims. LCA assesses the impact on the environment of a product across its entire life cycle, from the extraction of raw materials to end of life. The PEF constitutes a standardised framework enabling reliable environmental comparisons between products. For comparative claims, verification by an accredited third-party body is mandatory. These standards also apply under the UK Green Claims Code, with equivalences recognised by the Swiss SECO and Norwegian authorities. The CSRD (Corporate Sustainability Reporting Directive) also requires businesses within its scope to report on their environmental data, including that arising from their procurement, which reinforces the need for documentation at source.

Green Claims and B2B procurement: the end of supplier self-declaration

The new anti-greenwashing regulations are fundamentally changing the posture of buyers. Relying solely on suppliers’ commercial declarations is no longer sufficient: documented, structured and verifiable evidence is now required at every stage of the procurement process.

Impact on supplier selection: requiring robust environmental data

A product page mentioning “eco-designed” or “low carbon footprint” without supporting documentation is no longer sufficient to justify a purchase. Buyers must now require from their suppliers LCA reports, PEF data, certifications issued by accredited third parties and complete documentary traceability. This documentation requirement becomes a selection criterion in its own right, on a par with price or delivery time. A supplier unable to produce these elements directly exposes the buyer to a growing non-compliance risk.

The buyer’s responsibility: securing the value chain and CSRD reporting

The CSRD requires businesses within its scope to report on their environmental data, including that related to indirect procurement (scope 3). A buyer who incorporates products bearing non-compliant claims exposes their organisation to the risk of inaccurate reporting, with potential consequences for its credibility and its legal obligations. The buyer is the first link in CSR compliance: their rigour in supplier selection directly determines the reliability of the data reported in the company’s sustainability documents.

The CSR manager plays an essential coordinating role here between the procurement department and the reporting teams, to ensure that the data collected from suppliers meets the standards required by the authorities.

How to adapt your procurement processes to this new transparency requirement?

Adapting procurement processes to Green Claims requirements does not require a complete overhaul. A few structural adjustments can deliver significant gains in compliance and supplier risk management, without burdening existing processes.

Prioritising EU-Recognised Eco-Labels: EU Ecolabel, Blue Angel and Equivalents

The Green Claims Directive explicitly recognises official eco-labels as valid proof of environmental claims: the EU Ecolabel, the German Blue Angel (Blauer Engel[3]), the Scandinavian Nordic Swan, as well as FSC and PEFC certifications for wood products. These labels incorporate third-party verification by design, making them a reliable shortcut for the B2B buyer. Selecting products bearing these labels reduces the verification burden whilst guaranteeing the robustness of the chosen claims.

Relying on certified distributors to filter product claims upstream

A B2B distributor committed to an environmental compliance strategy can play an upstream filtering role: selecting products according to documented environmental criteria, making available product pages enriched with PEF data and certificates, and reducing the verification burden on the buyer’s side. This role of qualified intermediary is growing in value in an increasingly demanding regulatory context.

“Quality naturally leads us to turn to certification, to reassure ourselves as buyers and to do our job properly. In a tender, you will ask your suppliers for a number of elements: product quality and safety, fire standards, etc. Yet today, there is virtually nothing to certify that a product has genuinely been refurbished. At Manutan, we work with FCBA (the body that certifies the quality of new products) and with eco-organisations, in particular Valdelia, to create a certification that you can require from your suppliers. The objective is to ensure that the product has gone through a rigorous process and will be of quality, because the buyer then needs to be able to justify this internally, by demonstrating that they hold the right certifications.” - Pierre-Emmanuel SAINT-ESPRIT (Director of Circular Economy, Manutan Group), Interview: The challenges of the circular economy, MANUTAN, 10 January 2025, 19 min

A catalogue filtered according to current environmental requirements:

Manutan selects the products in its catalogue according to documented environmental criteria, enabling B2B buyers to access structured product data: certifications, recognised eco-labels (EU Ecolabel, Blue Angel, Nordic Swan), detailed technical data sheets. This approach facilitates Green Claims compliance without burdening internal procurement processes. This service is available in the countries where Manutan is present, at the date of content publication.

Integrating green claims criteria into your supplier evaluation grids

To structure supplier selection, several criteria can be integrated right now into an evaluation grid:

• Availability of an LCA report or PEF data by product reference;
• Third-party certification for comparative claims;
• List of eco-labels held, with validity date;
• Documented commitment on scope 3 within the CSRD reporting framework;
• Policy for updating environmental data and revision frequency.

These criteria are intended to progressively become contractual requirements in supplier specifications.

This development redefines the profile of the procurement manager, whose skills must now incorporate mastery of environmental reference frameworks on a par with price negotiation or contract management.

Beyond the constraint: making environmental transparency a procurement performance driver

Compliance with Green Claims requirements may be perceived as an additional constraint. In reality, it represents a strategic opportunity for procurement functions that choose to anticipate rather than endure it.

Reducing supplier risk and strengthening supply chain resilience

A supplier unable to document their environmental claims represents a growing operational risk: product withdrawal from the market, loss of labelling, exposure to regulatory sanctions. A supplier portfolio that complies with Green Claims requirements is a more resilient portfolio. Environmental transparency becomes an indicator of maturity and reliability: suppliers who master their environmental data also master their production chain and their overall regulatory compliance

Highlighting environmental commitments with stakeholders and in CSRD reporting

Documented procurement that complies with Green Claims requirements directly feeds into CSRD reporting, responses to tenders incorporating CSR criteria, and institutional communication towards investors, clients and employees. Environmental transparency in procurement becomes an intangible asset of the company: it strengthens the credibility of CSR commitments, facilitates external audits and improves the extra-financial rating. This traceability requirement aligns with the principles of green finance, where investors are increasingly conditioning their decisions on the robustness of the environmental data declared by businesses.

Senior management teams find in this a concrete management driver, directly articulated to regulatory reporting requirements.

Turning compliance into a competitive advantage and commercial argument

Businesses that anticipate Green Claims compliance are positioning themselves ahead of their competitors. They reduce their exposure to regulatory risks and strengthen their credibility with their stakeholders. Environmental transparency ceases to be a constraint and becomes a visible differentiating argument: in tenders, in client evaluations, in relationships with investors and institutional partners. Organisations that act now are building an advantage that will be difficult to close.