
Sustainability claims for manufacturers are increasingly treated as regulated statements, not marketing language. As scrutiny around greenwashing intensifies, even well-intentioned environmental claims can create regulatory, reputational, and commercial risk if they are vague, overstated, or poorly substantiated.
Under the Ecodesign for Sustainable Products Regulation (ESPR) and the proposed EU Green Claims Directive, manufacturers are required to clearly define what a sustainability claim refers to, support it with reliable evidence, and present it without misleading emphasis. This means manufacturer sustainability claims must be accurate, verifiable, and proportionate to actual performance.
This guide outlines how manufacturers can make clear, transparent, and substantiated sustainability claims, helping organisations communicate impact responsibly, avoid greenwashing, and build trust with regulators, customers, and supply-chain partners.
Greenwashing occurs when a company makes sustainability claims that sound good but are unclear, inaccurate, or not fully supported by facts. This often involves using vague terms like “green” or “eco-friendly,” highlighting minor improvements, or omitting crucial details about environmental impact.
Manufacturers are more likely to get caught because their operations and supply chains are complex, and sustainability information can be hard to track and explain. As regulators and customers expect greater transparency, unclear or incomplete claims are more likely to be questioned.
As scrutiny increases, market surveillance authorities are paying closer attention to how sustainability claims are presented, particularly where claims lack evidence, clarity, or consistency across products and markets.
Common manufacturing-specific pitfalls include:
These gaps expose manufacturers to greenwashing allegations even when real sustainability work is underway.
Responsible sustainability communication is grounded in accuracy, transparency, and proportionality. Key principles include:
When claims are treated as structured information rather than creative copy, greenwashing risk drops significantly. As sustainability reporting requirements expand under the Corporate Sustainability Reporting Directive (CSRD), the data companies disclose publicly, increasingly becoming the reference point for external sustainability claims. Claims that are inconsistent with reported performance, or that selectively highlight improvements, can undermine credibility and attract regulatory attention.
Before publishing any sustainability claim, manufacturers should be able to answer:
If any answer is unclear, the claim needs refinement.
Even well-meaning teams often introduce risk through:
Avoiding these pitfalls requires coordination between sustainability, compliance, and marketing teams, not just better copywriting.
The Ecodesign for Sustainable Products Regulation (ESPR) raises the standards for how sustainability information is communicated, especially at the product level.
At a high level, ESPR signals that:
This shifts sustainability claims from marketing statements to regulated product information.
The Ecodesign for Sustainable Products Regulation (ESPR) promotes Digital Product Passports (DPPs) as a mechanism for delivering clear, structured, and traceable product-level sustainability information.
Instead of relying on broad environmental claims, DPPs connect sustainability statements directly to verifiable product data, such as material composition, environmental performance indicators, durability information, and compliance attributes. This marks a shift from narrative sustainability messaging to data-driven transparency for manufacturers.
Sustainability claims are increasingly expected to reflect specific, up-to-date product information that can be shared consistently across regulatory, commercial, and supply-chain contexts. By standardising how sustainability data is recorded and accessed, DPPs help improve comparability, reduce ambiguity, and support more credible, defensible sustainability claims across a product’s lifecycle.
Instead of free-text claims, DPPs connect statements to:
This fundamentally changes how claims are created and managed.
For manufacturers, this means:
Digital Product Passports allow manufacturers to operationalise ethical claims rather than relying on static statements.
Every sustainability claim should correspond to a specific data attribute, such as recycled content percentage, energy intensity, or certification status.
Claims should reference:
This ensures claims remain defensible.
DPPs make it clear:
This prevents outdated or conflicting claims from circulating.
Ethical sustainability communication depends on governance, not complexity.
When a claim changes, it must update consistently across:
This avoids contradictions that regulators and customers quickly spot.
DigiProd Pass helps manufacturers cut through sustainability ambiguity by turning scattered claims into structured, verifiable product‑level data. Rather than relying on unclear messaging, it enables brands to link every sustainability claim directly to documented evidence and material information, providing a clear audit trail and building trust with regulators and customers alike.
The platform also supports version control and audit readiness, so teams can track updates and ensure all sustainability data remains current and defensible.
By centralising product information in a single source of truth that aligns compliance, marketing, and product teams, DigiProd Pass reduces the risk of unsubstantiated claims being perceived as greenwashing and strengthens brand credibility in an increasingly transparent regulatory landscape.
DigiProd Pass helps manufacturers:
This reduces greenwashing risk while enabling confident, credible sustainability communication.
Before releasing a sustainability claim:
Product Claim
“This product contains 35% post-consumer recycled aluminium, measured by weight, based on supplier declarations verified in 2024.”
Operations Claim
“Our [facility/location] reduced electricity-related emissions by 18% between 2022–2024, calculated using location-based emission factors.”
Target / Progress Claim
“We aim to reduce Scope 1 and 2 emissions by 30% by 2030, relative to a 2021 baseline. Current progress: 12% achieved.”
Claim - DPP Mapping
Claim: Recycled content percentage
DPP field: Material composition
Evidence: Supplier certificate
Last updated: YYYY-MM
Owner: Sustainability team
Is it safer to avoid sustainability claims altogether?
No. Silence can raise as much suspicion as overstatement. The goal is accurate, well-supported communication.
Can marketing teams write sustainability claims alone?
Not safely. Claims should be co-owned by sustainability and compliance functions.
Do Digital Product Passports replace marketing claims?
No. They support and validate them by providing structured, verifiable data behind the message.
Is greenwashing always intentional?
Most cases are not. They result from poor governance, unclear data, or misaligned teams.
Sources
EU Green Claims Directive
Ecodesign for Sustainable Products Regulation(ESPR)
Stopping greenwashing: how the EU regulates green claims

