An implicit environmental claim is a message that is not directly expressed in writing or verbally, but that can be conveyed through images, colors, symbols, sounds, or other elements of the product’s or operator’s presentation. For example, the use of leaves, natural landscapes, animals, or shades of green can lead consumers to perceive an environmental benefit even in the absence of an explicit claim.
According to the European Commission, visual elements can also constitute environmental claims and must therefore be assessed on a case-by-case basis in accordance with the general rules of the Unfair Commercial Practices Directive (UCPD), as amended by the ECGT Directive. The case-by-case assessment will take into account the content of the message; its overall presentation; the commercial context; and the likely effect on the average consumer. An implied claim may be misleading if it is likely to lead the consumer to form an incorrect impression regarding environmental performance.
! Please note: The Commission also clarifies that generic environmental claims are normally expressed through words or verbal statements. Therefore, images or colors, on their own, do not automatically constitute generic environmental claims. However, when combined with text or other messages suggesting unspecified environmental benefits, they may contribute to constituting a prohibited generic environmental claim, unless supported by evidence of recognized environmental excellence (see Chapter Error. The source reference was not found. ).
Last modified on 02/10/2026