Future targets
“Net zero by 2030”, “100% recyclable by 2028”: what makes a future environmental claim defensible?
Future ambition is not prohibited. What becomes much harder to defend is a public promise with no credible system connecting today’s position to the stated destination.
Updated 8 August 2026
Short answer
From 27 September 2026, a future environmental performance claim can be misleading if it is not backed by clear, objective, public and verifiable commitments set out in a detailed and realistic implementation plan, with measurable targets, timelines, resources and regular verification by an independent third-party expert.
Future targets are not banned as a category
The amended consumer-law rule is assessed case by case. Businesses can still communicate future targets and transition pathways, but the statement needs to reflect a real implementation framework rather than an unsupported aspiration.
The practical question is not “do we have a target?” but “is there enough evidence of delivery behind the target to put it in front of consumers?”
What the implementation plan should be able to show
- Clear and publicly accessible commitments.
- A defined baseline and measurable indicators.
- Deadlines and interim milestones.
- A detailed and realistic implementation plan.
- Allocated resources and responsibilities.
- Regular verification by an independent third-party expert.
- Verification findings made available to consumers.
Do not confuse this with the separate Green Claims Directive proposal
Directive 2024/825 does require regular independent verification for certain future environmental performance claims. It does not create an across-the-board requirement for ex ante certification of every environmental claim.
The separate proposal COM(2023) 166, commonly called the Green Claims Directive, contemplated a broader verification regime. Its legislative process remains blocked as of this update.
Accurate message: some future environmental claims need a credible, independently reviewed implementation plan. Inaccurate message: every green claim must be certified from September.
Example: “100% recyclable by 2028”
A defensible target would normally be tied to a defined product scope, a baseline, identified technical changes, interim milestones, resources, measurement criteria and an independent review process.
A broad ambition copied from a sustainability report onto a product page does not automatically carry the evidence needed for a consumer-facing commercial claim.
Pre-publication checklist
- Is the scope of the target explicit?
- Is there a deadline and a baseline year?
- Are the indicators and milestones measurable?
- Have resources and responsibilities been assigned?
- Is the implementation plan public and sufficiently detailed?
- Is progress reviewed regularly by an independent expert?
- Are the review findings accessible to consumers?