Claim scope

Can greener packaging make the whole product “more sustainable”?

Many misleading environmental messages start with a fact that is true. The problem comes when a fact about one component, package or activity is allowed to create a much broader impression.

Updated 8 August 2026

Short answer

No. A benefit limited to packaging does not, by itself, support a claim that the whole product is environmentally better. From 27 September 2026, making an environmental claim about an entire product or an entire business when it concerns only one aspect or one specific activity is prohibited in all circumstances.

The Directive expressly targets overstated scope

Directive 2024/825 gives a simple example: marketing a product as made from recycled material in a way that suggests the whole product is recycled when only the packaging is.

It also addresses business-level claims, for example creating the impression that a company uses only renewable energy when that is true only for some activities or sites.

French guidance already follows the same principle

French environmental-claims guidance asks businesses to make environmental information clear, proportionate and unambiguous. A packaging attribute should not be allowed to describe the product as a whole.

For company-level statements, businesses should distinguish between all activities, particular sites, a specific production process or one stage of the value chain.

Five levels of scope to separate

Component: one material, fibre or part.
Packaging: primary, secondary or another packaging element.
Product: the good or service as a whole.
Range: several products carrying the same message.
Company or brand: the trader’s broader activities or commitments.

The broader the claim, the broader the evidence needs to be.

B2C context matters

The amended Unfair Commercial Practices Directive governs business-to-consumer commercial practices. A statement in an investor-focused report is not automatically assessed in the same way.

Once the same statement is deliberately reused on a product page, advertisement, package or consumer campaign, it enters a consumer-facing commercial context and should be reviewed accordingly.

Four-question scope test

What does a reasonable consumer think the statement applies to?
What does the evidence actually apply to?
Is any difference in scope immediately visible?
Is the highlighted benefit material to the overall product or business being presented?