---
title: "Green Claims Directive withdrawn: what vegan brands can’t say"
description: The Green Claims Directive is withdrawn, but green claims rules still bind vegan brands. What stays banned, what counts as proof, what to fix.
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green claims vegan brands EU compliance AI search

# The Green Claims Directive is withdrawn—what vegan brands still can’t say on product pages

The proposal is dead; the bans aren’t. A claim-by-claim field guide for vegan product pages in the EU—and the FDA decision US brands are watching.

![Alexander Kirsch-Clayton](https://digitaldomination.xyz/assets/images/alexander.webp) By [Alexander Kirsch-Clayton](https://www.linkedin.com/in/alexanderkc/), Founder November 9, 2026 ·9 min read [Digital Domination on LinkedIn](https://www.linkedin.com/company/digidomination/) [Digital Domination on GitHub](https://github.com/digidomination)

On November 4, 2026, the European Commission published its 2027 Work Programme and listed the Green Claims Directive for withdrawal. Vegan brand teams are reading that as a green light. It isn’t one: generic green claims have been banned in the EU since September 27, 2026, and “vegan = better for the planet” is a regulated claim.

## The news, in one paragraph

Here’s the whole story. The Commission’s 2027 Work Programme, published on November 4, 2026, announces its intention to withdraw the proposal for a Green Claims Directive “within six months,” per Loyens & Loeff. That was the draft law meant to add an ex-ante verification regime for environmental claims—the one that would have made every explicit green claim pass a pre-check before use. It never got that far: negotiations stalled in summer 2025, and the Commission has now cut the file rather than keep pushing it.

If you sell vegan food or cosmetics in the EU, that paragraph is not your news. Your news is the second directive: the ECGT Directive—2024/825, “Empowering Consumers for the Green Transition”—which the withdrawal doesn’t touch and which has applied since September 27, 2026. Germany transposed it into the UWG months ago. The withdrawal changes the future of green-claims law. It changes nothing about the present.

The Green Claims Directive’s withdrawal changes nothing for green claims: generic environmental claims have been banned in the EU since September 27, 2026, and under the Commission’s own Q&A a “vegan” label that implies planetary benefit counts as a regulated environmental claim.

## What the withdrawal kills—and what stays

One proposal, one directive, one law each. The withdrawal touches only the first.

- Killed: the Green Claims Directive proposal—the planned ex-ante regime for substantiating environmental claims before they’re used. The Commission intends to withdraw it within six months of November 4, 2026.
- Stays: the ECGT Directive (2024/825), which Loyens & Loeff confirms the planned withdrawal “does not affect”—in effect since September 27, 2026.
- Stays and bites: the ECGT’s core bans—generic environmental claims like “eco-friendly” and “green” are prohibited without proof of excellent environmental performance, and climate-neutrality claims based on carbon offsetting are prohibited, per Latham & Watkins.
- Stays in Germany: the UWG transposition of the same directive, in force since September 27, 2026.

Germany moved early. The Third Act Amending the UWG (Drittes Gesetz zur Änderung des UWG) of February 12, 2026 transposed the ECGT Directive and took effect on September 27, 2026. It adds three entries to the blacklist in section 3 of the UWG, per Kopp-Assenmacher: 4a for generic environmental claims, 4b for claims about a whole product that actually cover only one aspect, and 4c for claims based on greenhouse-gas compensation—the „klimaneutral“ label being the canonical example. The Umweltbundesamt adds the label rule: sustainability seals that come neither from public authorities nor from third-party certification schemes are prohibited.

Old stock is not exempt. On June 30, 2026, the CPC Network published a Common Understanding on old-stock situations. It is not legally binding, but it is the enforcement picture: products and packaging with green claims that were placed on the market before September 27, 2026 are not grandfathered. Traders are expected to move toward compliance without delay—through proportionate steps like stickers or overlabeling, removing labels, point-of-sale corrections, and updating online claims. Authorities may refrain from requiring destruction or recall, which is the proportionality working in your favor.

## Why “vegan” itself became a regulated claim

Here’s the part most vegan brands miss. The Commission’s FAQ on the ECGT Directive deals with your exact label. Question 15: the terms “vegan” and “vegetarian” depend on the context. If their use suggests an ecological or social advantage, they can qualify as environmental claims or sustainability labels—and then they need what every other environmental claim needs, certification or establishment by a public authority. Heuking’s summary of the FAQ says the same thing plainly: “vegan” or “vegetarian” may qualify as environmental claims where they imply environmental benefit.

So a bare “vegan” label—no animal ingredients, full stop—is not a regulated environmental claim. “Vegan = better for the planet” is. The moment the word does ecological work on your product page, the page needs proof the label can’t provide on its own.

The German blacklist squeezes further. Entry 4b catches claims about the whole product that really cover one aspect: “sustainable” because the cap is recycled, “eco” because the carton is. If your green sentence is really about packaging, say packaging.

## The claims that are out

On a product page, these are the archetypes I cut first:

- Generic environmental adjectives: “eco-friendly,” “green,” “planet-positive,” “climate-friendly”—prohibited without proof of excellent environmental performance.
- Offset-based neutrality: “climate-neutral,” “carbon-neutral,” “climate-positive”—prohibited when based on carbon offsetting, which is how those labels typically worked.
- Vague sustainability labels: “sustainable,” „nachhaltig“, with no named scheme behind them.
- Whole-product claims from one aspect: “sustainable product” when only the packaging is recycled.

### A vegan food example, before and after

- Before: “Our oat drink is climate-neutral and eco-friendly—better for you and the planet.”
- After: “Oat drink, certified by The Vegan Trademark. Oats from \[named mill, region\]. Carton from \[X\]% recycled fiber (verification linked).”

What changed: the after names a certifier, scopes the packaging sentence to packaging, and every claim answers “says who?” in one click.

### A vegan cosmetics example, before and after

- Before: “Sustainably sourced vegan shampoo. Kind to you, kind to the planet.”
- After: “Vegan shampoo, The Vegan Trademark certified. Bottle from \[X\]% recycled PET (verification linked). Refill pouch uses \[X\]% less plastic than a new bottle (calculation linked).”

Same move, different category: the planetary framing is gone, the specifics are on the page, and nothing in the sentence is generic.

## What still works: certified, specific, substantiated

The rule I audit against: every environmental-flavored phrase needs a certifier, a number, or a named source—ideally all three, and all three crawlable.

- The Vegan Trademark for vegan status: The Vegan Society has been certifying products and ingredients since 1990, with over 70,000 certified products worldwide. Link the certificate or the trademark’s product listing, not just a logo image.
- EU Ecolabel for environmental performance: the EU’s official voluntary label for environmental excellence—an ISO 14024 Type 1 ecolabel, which means multi-criteria and third-party verified, run by the Commission and Member States.
- Third-party schemes like Ecocert or B Corp, where they fit the claim.
- Named suppliers and origins: “oats from \[named mill\]” beats “sustainably sourced” every time.
- Numbers with sources: footprints calculated to a recognized standard, verified by an independent body, with the verification linked.

## Why ChatGPT discounts the same phrases the UWG bans

Here’s why this matters twice. When ChatGPT or Perplexity decides whether to recommend your product, it faces the same question a consumer authority does: is this verifiable? An assistant that repeats “eco-friendly” is vouching for an adjective. An assistant that cites a Vegan Trademark listing is citing something it can check. Models reward the same specificity the law demands.

There’s now a number on it. Provenance ran the experiment with the brand Faith in Nature: verified Proof Points added to 37 of 73 shampoo product pages, with the other 36 as a control, tracked in ChatGPT-4 and Google AI Overviews against 25 realistic shopping queries. Pages with verified Proof Points were cited 323% more often as trusted sources in AI responses, and the brand gained 20 percentage points of AI brand visibility.

The same rewrite that keeps a product page clean under the UWG is the rewrite that gets it recommended. If you want to watch that in your own category, we built a tracker for it—[Cited](https://joincited.ai) follows how ChatGPT, Claude, Perplexity and Gemini describe your brand and your competitors in real time and turns the gaps into a to-do list. The tool isn’t the point. Verification is now a distribution strategy, not just a compliance one.

## What a claims audit actually looks like

In the claims audits I run, the pattern repeats almost every time. The product is genuinely good—clean ingredients, a real supplier, a founder who can talk sourcing for an hour. Then the product page repeats “eco-friendly” and “sustainable” like mantras, and none of that substance is on it.

The audit itself is unglamorous. Claim by claim, every product page gets read, and each phrase gets one of three tags: keep (specific and provable), cut (a banned archetype), or substantiate (true, but the proof isn’t published). Then the cuts get rewritten into the after versions above. Most catalogs are an afternoon of reading and a day of rewriting.

## The keep/cut/substantiate checklist

1. Read before you write. Export every product page—title, description, ingredients, FAQ, image alt text—into one sheet. Change nothing yet.
2. Tag every environmental-flavored phrase, and tag “vegan” wherever it’s paired with planetary framing.
3. For each tag: can you name the certifier, the number and its source, all on a crawlable page? Keep. Anything missing? Cut or substantiate.
4. Scope the survivors. If the claim covers one aspect—packaging, one ingredient—write the sentence about that aspect, not the whole product.
5. Handle old stock proportionately: stickers or overlabeling, removing labels, point-of-sale corrections—and update the online copy the same day, because it’s the cheapest of the four.
6. Re-read as a skeptic. For every surviving claim: would a consumer authority, or a chatbot, find the proof in one click?

## US sidebar: the oat milk decision expected this month

If you sell plant-based in the US, a second naming question is landing about now. The FDA’s Unified Agenda entry RIN 0910-AJ11, “Revocation of Standards of Identity for Dairy Products,” shows a proposed rule of July 17, 2025 (90 FR 33334) and a final rule projected for November 2026. Projected, not scheduled—the Unified Agenda is a plan, not a promise.

The current posture is permissive. Under the FDA’s February 22, 2023 draft guidance on plant-based milk alternatives, the agency does not prohibit “milk” on oat, soy or almond drinks, because common and usual names like “soy milk” and “almond milk” are established by common usage; it recommends voluntary nutrient statements instead. If the revocation lands, the federal standards-of-identity objection to “oat milk” disappears—but the name every shopper, menu and model already uses doesn’t change. Legal naming and LLM categorization converged years ago. Watch the decision; don’t rewrite packaging for it yet.

## What it costs and how long it takes

Honest scope: a claim-by-claim audit is an afternoon to a day of reading plus a day of rewriting for a small catalog, and it scales roughly linearly from there. 200 product pages are not an afternoon, and anyone who quotes you a retainer for this is selling theater. It’s a fixed-scope project with a deliverable: a sheet of claims, each tagged, each with a replacement.

Our [AI Visibility Audit](https://digitaldomination.xyz/en/services/ai-visibility-audit) is a flat $390—it maps how ChatGPT, Claude, Perplexity and Google AI Overviews currently describe your brand and your category. For vegan brands we run it with the claims pass as one engagement, because the banned phrases and the ignored phrases turn out to be the same list. It sits alongside our work on the [vegan services page](https://digitaldomination.xyz/en/vegan), and you can book it through [contact](https://digitaldomination.xyz/en/contact).

## Q&A quick answers

### Is the Green Claims Directive still happening?

No. The Commission’s 2027 Work Programme of November 4, 2026 announces its intention to withdraw the Green Claims Directive proposal within six months—and the withdrawal applies only to that draft, not to the anti-greenwashing rules already in force.

### Are green claims banned in the EU?

Generic ones are: since September 27, 2026, the ECGT Directive (2024/825) prohibits generic environmental claims like “eco-friendly” without proof of excellent environmental performance, and prohibits climate-neutrality claims based on carbon offsetting.

### Is vegan an environmental claim?

Not on its own. Per the Commission’s ECGT FAQ (Question 15), “vegan” and “vegetarian” depend on context and qualify as environmental claims or sustainability labels only when their use suggests an ecological or social advantage.

### Can I say my vegan product is better for the planet?

No—not without certification by a third-party scheme or establishment by a public authority, because “vegan = better for the planet” is an implied environmental benefit, regulated since September 27, 2026.

### Which certifications count as proof?

Labels from public authorities or third-party certification schemes: The Vegan Trademark for vegan status (certifying since 1990, over 70,000 certified products) and the EU Ecolabel for environmental performance (an ISO 14024 Type 1 ecolabel—multi-criteria, third-party verified).

## What to do this week

1. Inventory, read-only. One sheet, every product page, every claim tagged. No edits yet—read first, write second.
2. Cut the banned three: generic eco adjectives, offset-based neutrality, whole-product claims from one aspect. Cut before you rewrite; a page with no green claims is compliant, a half-rewritten one isn’t.
3. Substantiate the survivors—certifier, number, source, linked and crawlable—then watch what the machines say about them.

And keep watching monthly, not once. We re-track claim language in German and English AI answers every month because the sources assistants cite churn: a page that was the canonical answer in October can lose the spot by December, and a competitor’s new claim can appear overnight. Withdrawal or not, your product pages are now a legal surface and a machine-readable one at the same time. Specific copy wins both.

## Sources

1. [Loyens & Loeff — ESG Update: Green Claims Directive set to be withdrawn, but anti-greenwashing rules remain](https://www.loyensloeff.com/insights/news--events/news/esg-update-green-claims-directive-set-to-be-withdrawn-but-anti-greenwashing-rules-remain/) (accessed 2026-11-09)
2. [Linklaters Sustainable Futures — EU: Commission's Work Programme sets out key sustainability initiatives for 2027](https://sustainablefutures.linklaters.com/post/102o7ir/eu-commissions-work-programme-sets-out-key-sustainability-initiatives-for-2027) (accessed 2026-11-09)
3. [Latham & Watkins — EU Empowering Consumers Directive: New Rules on Green Claims Apply from 27 September 2026](https://www.lw.com/en/insights/eu-empowering-consumers-directive-new-rules-on-green-claims-apply-from-27-september-2026) (accessed 2026-11-09)
4. [Kopp-Assenmacher — Umsetzung der EU-Richtlinie 2024/825 im UWG – Stärkung des Verbraucherschutzes gegen Greenwashing](https://www.kopp-assenmacher.de/de/news/umsetzung-der-eu-richtlinie-2024-825-im-uwg-staerkung-des-verbraucherschutzes-gegen-greenwashing/) (accessed 2026-11-09)
5. [Umweltbundesamt — Neue Regeln: Schutz vor Greenwashing](https://www.umweltbundesamt.de/themen/neue-regeln-schutz-vor-greenwashing) (accessed 2026-11-09)
6. [Heuking — EU Commission publishes FAQ on the EmpCo Directive](https://www.heuking.de/en/news-events/newsletter-articles/detail/eu-commission-publishes-faq-on-the-empco-directive.html) (accessed 2026-11-09)
7. [Linklaters Sustainable Futures — EU: CPC Network publishes Common Understanding on Enforcement of Old Stock situations](https://sustainablefutures.linklaters.com/post/102nbb3/eu-cpc-network-publishes-common-understanding-on-enforcement-of-old-stock-situa) (accessed 2026-11-09)
8. [Provenance — How Faith in Nature are getting more AI product recommendations](https://www.provenance.org/case-studies/faith-in-nature) (accessed 2026-11-09)
9. [The Vegan Society — The Vegan Trademark](https://www.vegansociety.com/the-vegan-trademark) (accessed 2026-11-09)
10. [European Commission Green Forum — About the EU Ecolabel](https://green-forum.ec.europa.eu/green-business/eu-ecolabel/about-eu-ecolabel_en) (accessed 2026-11-09)
11. [Reginfo.gov — Unified Agenda entry RIN 0910-AJ11](https://www.reginfo.gov/public/do/eAgendaViewRule?RIN=0910-AJ11&pubId=202510) (accessed 2026-11-09)
12. [Epstein Becker Green — FDA Issues Draft Guidance on Labeling of Plant-Based Milk Alternatives](https://www.ebglaw.com/health-law-advisor/fda-issues-draft-guidance-on-labeling-of-plant-based-milk-alternatives) (accessed 2026-11-09)