With the new EmpCo Directive (“Empowering Consumers for the Green Transition”), the EU is introducing stricter requirements for the communication of environmental and sustainability aspects to consumers. The aim is to better protect consumers from misleading claims and to provide more reliable information for purchasing decisions.
In connection with these new requirements, we are currently receiving an increasing number of questions about the future use of IBU EPDs and the IBU logo in product communication.
Our current assessment is: An IBU EPD itself does not constitute a green claim. An IBU EPD is a Type III environmental declaration in accordance with DIN EN ISO 14025 and EN 15804. It makes the environmental impacts of a product transparent on the basis of clearly defined rules and life cycle assessment data, without evaluating them. An EPD is therefore not an environmental label with an evaluative statement, but a standardized information instrument.
Particularly relevant in the current context is the use of signs and logos in B2C communication, meaning wherever markings appear directly on products, packaging or product-related labels and are perceived by consumers. The key issue here is above all to avoid misunderstandings or misleading use.
The IBU already has a statute on the use of Trademarks. which clearly regulates the use of the signs: The general IBU association sign is intended for communicating membership, not for product-related communication. Product-related marking is reserved exclusively for the designated declaration signs in the regulated context of a valid EPD. We would therefore also like to refer once again to the statute on the use of signs and recommend observing the usage requirements set out therein.
As of today, this reflects the current status of our professional assessment. In parallel, in light of the EmpCo Directive, we are examining whether the existing statute on the use of trademarks should be further specified in certain areas. This review is also taking place at the level of the ECO Platform, the European association of EPD programme operators. As soon as further reliable findings are available, we will of course inform you through our channels.