What the EU Green Transition Directive Means for FMCG Packaging

For years, sustainability claims on packaging operated in a grey zone. Brands made commitments that were broadly true, directionally sincere, and largely unchallenged. Regulators asked questions occasionally. Consumers mostly took the claims at face value. The risk of getting it wrong was reputational, not legal — and reputational risk, for most organisations, is something that gets managed rather than eliminated.

That grey zone has closed.

The EU's Green Transition Directive — formally the Directive on Empowering Consumers for the Green Transition, adopted in early 2024 and transposing into national law across member states through 2026 — fundamentally changes the compliance calculus for any brand selling into European markets. It is not a tightening of existing guidance. It is a structural shift in what is permissible, what must be substantiated, and what happens when it is not.

For packaging managers and brand teams, the implications are immediate and practical. This article sets out what the Directive actually requires, where most packaging portfolios are currently exposed, and what a credible response looks like.

What the Directive Actually Says

The Green Transition Directive targets a category of commercial behaviour that regulators have labelled "greenwashing" — but the legal definition is more precise than the cultural one, and precision matters when you are assessing your own portfolio.

The Directive prohibits four categories of practice:

Generic environmental claims without substantiation. Terms like "eco-friendly," "green," "sustainable," "natural," "environmentally responsible," and similar expressions are no longer permissible unless accompanied by substantiation that specifically supports the claim as applied to the product. The claim cannot be true of the brand in general and then applied to a specific product. It must be true of that product, and provably so.

Claims based on carbon offsetting presented as product-level environmental achievements. A product cannot be described as "carbon neutral" or "climate positive" on the basis of offset purchases alone, without transparent disclosure of the methodology. This catches a significant number of packaging claims that were introduced during the period when carbon offset programmes were widely treated as equivalent to actual emissions reduction.

Claims about the recyclability of packaging that are not accurate for the end markets. "Recyclable" as a unqualified claim is only valid if the packaging is recyclable in the markets where it is sold — not in principle, not under ideal conditions, but in the actual recycling infrastructure available to the consumer who buys it. This distinction matters significantly in markets where collection and sorting infrastructure varies by region or municipality.

Unverified third-party certification claims. Displaying a certification mark without holding a current, valid licence for that specific product — or presenting a certification in a way that misrepresents its scope — is non-compliant. This includes certification marks that may have been accurate at one point but have not been renewed, and marks that apply to a manufacturing process but are being used on a product that is not itself certified.

Penalties for non-compliance are set at up to 4% of annual global turnover in the relevant member state — a number calibrated to ensure that compliance failures are financially material, not just administratively inconvenient.

The Part That Catches Most Teams Off Guard

Reading the Directive in isolation, many packaging and brand teams conclude that their exposure is limited. Their claims are broadly accurate. They have certifications. They are not making things up.

The gap is usually not deliberate misrepresentation. It is precision.

The Directive does not require that claims be false to be non-compliant. It requires that they be substantiated — specifically, verifiably, and in a way that is accurate for the specific product in the specific market where it is sold. A claim that is true at the category level but applied to a product where it is only partially true is non-compliant. A claim that is accurate in Germany but misleading in a market with different recycling infrastructure is non-compliant. A certification mark displayed correctly on nine formats and incorrectly on the tenth is non-compliant on that tenth format.

This is why portfolio-level exposure is almost always larger than it first appears. Claims do not live in one place. They propagate — through brand guidelines, through template artworks, through regional adaptations, through line extensions. A claim that was introduced on one SKU and felt right gets copied to twenty more. By the time anyone looks systematically, it has replicated itself across formats, substrates, and markets in ways that the original decision-maker never intended.

This is the structural problem the Directive is designed to address. And it is why the response has to be equally systematic.

Where the Exposure Typically Sits

Based on the work we do across large FMCG portfolios, the risk tends to concentrate in a few predictable places:

Generic sustainability language introduced at brand level. Claims like "we care about the planet" or "made with the future in mind" that appear across a range without product-specific substantiation. These were common during the period when brands were building sustainability narratives and the regulatory environment was permissive. Most of them are now directly in scope.

Recyclability claims that have not kept pace with market reality. Claims introduced when recycling commitments were made about future infrastructure that has not fully materialised, or claims that are accurate for primary packaging but technically incorrect for a multipack or shipping carton that uses a different material.

Carbon claims inherited from offset programmes. "Carbon neutral" or "net zero" claims that were introduced when the brand purchased offsets, but which do not meet the Directive's requirement for disclosed, audited, offset-plus-reduction methodology.

Certification marks on formats where the licence does not extend. A certification mark that is valid on a standard retail unit but has been carried across to a promotional format, a travel-retail variant, or a private-label adaptation where the certification was never independently verified.

Claims on secondary packaging that receive less scrutiny than primary. Shippers, cartons, and multipacks are part of the consumer's experience of the product. They are subject to the same rules. They often receive less rigorous compliance review.

What "Substantiation" Actually Requires in Practice

The Directive's substantiation requirement is not a paperwork exercise. It is a genuine evidentiary standard, and meeting it requires documentation that many brand teams do not currently have at a product level.

For material and recycling claims, substantiation means being able to demonstrate, for each specific packaging format sold in each specific market, that the claim is accurate. For recyclability, this typically means reference to recognised national or EU-level recyclability assessment frameworks, not just general statements about material type. A "recyclable" claim on a black plastic tray in a market where black plastics are not collected is not substantiated, regardless of what the material is technically capable of.

For carbon and lifecycle claims, the bar is higher. The Directive anticipates independent verification — not necessarily a full third-party LCA for every product, but sufficient documentation to demonstrate that the claim is based on measured data rather than assumption. Carbon neutrality claims made on the basis of offsets require explicit disclosure of the offset methodology, the verification standard applied, and the ratio of emissions reduced versus offset.

For certification claims, substantiation is the certification itself — but with the caveat that the certification must be current, must cover the specific product, and must be presented in accordance with the certification body's own usage requirements. The last point catches more teams than the first two, because certification body usage guidelines are often more specific than teams realise.

The Operational Reality for Large Portfolios

Understanding what the Directive requires is the straightforward part. The harder problem is applying that understanding to a portfolio of any significant scale.

Consider what a systematic compliance review actually involves: a complete inventory of every SKU in every format and every market; extraction of every sustainability claim that appears anywhere on those artworks; substantiation assessment for each claim against each market; remediation of every artwork where a claim cannot be substantiated; and quality control at sufficient rigour to ensure that remediation is consistent across all variants.

For a brand with a few hundred SKUs across multiple European markets, this is a months-long project. For a brand with a thousand or more, it is a programme.

What makes it operationally difficult is not any single step — it is the combination of scale, time pressure, and the fact that this work typically lands alongside existing launch programmes, seasonal campaigns, and ongoing artwork updates. The compliance project does not pause everything else. It runs concurrently, competing for the same resources.

One FMCG company we worked with identified a sustainability claim that needed to be removed and rebalanced across 180 SKUs — with the majority of artworks needing to be completed within six weeks to protect production schedules. That kind of timeline, at that volume, requires a specific operational approach: batching by print deadline rather than project logic, parallel teams working from shared standards, and quality control that keeps pace with production rather than following behind it.

The broader point is that the Directive does not just create a compliance challenge. It creates an operational one. And operational challenges require operational responses, not just policy ones.

A Framework for Thinking About Your Own Exposure

For teams beginning to assess their position, a useful starting point is to think about exposure across three dimensions:

Claim type. Generic environmental language carries the highest immediate risk because the Directive addresses it most directly and there is little ambiguity about what is required. Carbon and lifecycle claims are the highest-risk substantiation challenge because the evidentiary bar is highest. Certification claims carry specific operational complexity because of the printer-licence dynamic.

Portfolio breadth. The more SKUs, formats, and market variants you have, the more likely it is that a claim has propagated into places where it is technically non-compliant. Breadth also determines how long remediation will take — which in turn determines how urgently the audit needs to begin.

Existing documentation. The gap between having a claim and being able to substantiate it is often a documentation gap rather than a factual one. Many brands have the underlying data — lifecycle assessments, recycling test reports, certification documentation — but it is not organised in a way that maps to specific products and specific markets. Getting the documentation right is often as much work as getting the claims right.

What a Credible Response Looks Like

The Directive is not going away, and enforcement timelines across member states are tightening. The brands that will be in the strongest position are those that treat compliance as an operational programme rather than a legal review.

That means starting with a systematic audit — not a sample review, not a check of the highest-visibility SKUs, but a complete claim-by-claim assessment across the full portfolio. It means resourcing the remediation as the operational project it actually is, with realistic timelines, appropriate capacity, and clear prioritisation logic. And it means building the documentation infrastructure to substantiate claims on an ongoing basis, not just for the current portfolio but for everything that comes after.

For brands with large portfolios, it also means being honest about whether this can be done with internal resources alone, or whether bringing in artwork expertise — to handle the scale, manage the quality control, and navigate the print partner relationships where certification is involved — is the more realistic path.

The deadline pressure is real. But the underlying requirement is permanent. The brands that respond structurally, rather than scrambling to fix the most visible problems, will be better positioned for every compliance challenge that follows this one.

Collabra works with leading FMCG brands on large-scale artwork management and regulatory compliance projects across complex portfolios. If you would like to understand how we approach the operational side of Green Transition Directive compliance, get in touch →