Marketing New Materials Under the EU Greenwashing Rules

Marketing a new material is a slightly unusual exercise.

You are not simply selling a finished product. You may also be introducing customers to a new material, a new production process, a new raw material or even a completely different idea of what a product can be made from.

That is exciting.

It is also becoming more regulated.

For brands working with bio-based, circular or next-generation materials, the question is no longer simply how to tell a compelling sustainability story.

It is:

How do you tell that story accurately, clearly and in a way that can be substantiated?

This matters even more now because new EU rules targeting misleading environmental marketing are about to become applicable.

The EU's new greenwashing rules

The legislation most commonly referred to as the EU's Greenwashing Directive is Directive (EU) 2024/825, formally the Directive on Empowering Consumers for the Green Transition.

It amends existing EU consumer-protection legislation, particularly the Unfair Commercial Practices Directive and the Consumer Rights Directive, with the aim of giving consumers better information and stronger protection against misleading environmental and sustainability claims.

The Directive entered into force in March 2024. Member States were required to transpose it into national law by 27 March 2026, and the new rules will apply from 27 September 2026.

So this isn't some distant piece of legislation that brands can file under “we'll deal with that later.”

It is arriving.

And for brands working with innovative materials, it is particularly relevant because many of the claims used to explain these materials are environmental claims.

What is the legislation actually trying to prevent?

The new rules are not a ban on talking about sustainability.

They are a move away from vague, unsupported or potentially misleading environmental marketing.

For example, the Directive specifically addresses generic environmental claims such as “environmentally friendly,” “eco-friendly,” “green,” “biodegradable” and “biobased” when the required level of recognised environmental performance cannot be demonstrated.

It also prohibits certain practices outright, including displaying sustainability labels that are not based on an appropriate certification scheme or established by public authorities, making environmental claims about an entire product or business when they only apply to a limited aspect, and certain claims of climate neutrality or reduced environmental impact based on external carbon offsetting.

In other words:

“It's green” is becoming a much less useful sentence.

And, frankly, it was never a particularly good technical specification.

What does this mean for new materials?

This is where things get interesting.

A material may genuinely be bio-based.

It may contain agricultural waste.

It may be plastic-free.

It may be biodegradable under particular conditions.

It may contain a certain percentage of recycled or bio-based content.

All of these can be meaningful characteristics.

But the marketing claim needs to accurately describe what has actually been demonstrated.

For example, saying:

“Made from agricultural waste”

is quite different from saying:

“100% sustainable.”

The first describes a specific characteristic.

The second makes a much broader environmental statement that is difficult to interpret and substantiate.

The more precise the material information, the easier it becomes to communicate what is actually special about it.

Don't throw away the sustainability story

There is sometimes a temptation to react to greenwashing concerns by removing sustainability from the marketing entirely.

I don't think that is particularly useful.

If the environmental characteristics of a material are genuinely important, customers should be able to understand them.

The answer is not to stop talking about sustainability.

It is to talk about it better.

Instead of making sustainability the entire personality of the product, explain what the material actually is.

  • Where does it come from?

  • What is it made from?

  • What proportion is bio-based?

  • Does it contain petroleum-derived components?

  • Is there a certification?

  • What exactly has been tested?

  • Under what conditions?

  • What makes the material different from conventional alternatives?

Those details can be much more interesting than simply calling something “sustainable.”

Let the material be interesting

This is where the original marketing idea still holds up.

New materials have stories.

Sometimes very good ones.

Mushrooms, agricultural by-products, algae, bacterial cellulose, plant proteins and other emerging feedstocks can give a product a story that conventional materials simply don't have.

But the story doesn't have to begin with:

“This product is sustainable.”

It can begin with:

“This is what the material is.”

The science can be interesting.

The production process can be interesting.

The origin of the raw material can be interesting.

The way the material behaves can be interesting.

The fact that a material was developed from something previously considered waste can be interesting.

Sustainability can be part of the story without becoming the entire story.

And, importantly, a compelling material story does not give you permission to make a bigger environmental claim than the evidence supports.

Specific claims are your friend

For brands working with innovative materials, specificity is increasingly valuable.

Compare:

“An eco-friendly leather alternative.”

with:

“A bio-based leather alternative containing 95% bio-based plant content and 5% mineral content.”

The second statement tells the customer something.

It gives them something concrete to understand.

And it gives the brand a much clearer connection between the claim and the supporting material documentation.

This is particularly important when working with emerging materials because the terminology can become confusing very quickly.

“Bio-based” does not automatically mean biodegradable.

“Biodegradable” does not mean biodegradable everywhere.

“Recycled” does not tell you the percentage.

“Plastic-free” needs to be considered across the relevant material composition.

And “sustainable” doesn't tell the customer much at all unless you explain what you mean.

Certifications can help — but they don't do all the talking

Third-party certification can be extremely useful when communicating material characteristics.

The new Directive places particular emphasis on recognised environmental performance and on sustainability labels being backed by appropriate certification schemes or public authorities.

For a brand, this makes good documentation increasingly valuable.

If a material is certified bio-based, keep the certification.

If a claim is based on a test report, keep the test report.

If a biodegradability claim applies only under particular laboratory conditions, keep the test conditions and communicate them accurately.

A beautiful marketing sentence is considerably more useful when there is a piece of evidence sitting behind it.

Be careful with the whole-product story

One of the changes particularly relevant to fashion brands is the distinction between a claim about a component and a claim about the whole product.

If the main outer material is bio-based but the product also contains conventional lining, thread, adhesives, reinforcement and hardware, saying that the entire product is “100% bio-based” would create a very different impression.

The Directive specifically addresses environmental claims about an entire product or business when the environmental characteristic actually applies only to a specific aspect.

This is why material knowledge matters in marketing.

You need to know what the claim actually refers to.

Sometimes the most accurate statement is also the most interesting one.

“The outer material is made with 95% bio-based plant content.”

That is much more useful than simply saying:

“Our bag is sustainable.”

And then there are future claims

New-material brands often talk about what they are going to achieve.

A company may say that it is moving towards a fully circular product system, becoming carbon neutral, eliminating virgin materials or reaching a particular environmental target in the future.

The new rules also address environmental claims about future performance. Such claims need to be supported by clear, objective, publicly available and verifiable commitments, a detailed and realistic implementation plan, measurable and time-bound targets, appropriate resources and independent verification.

So:

“We are working towards…”

isn't automatically a free pass.

If you make a future environmental promise, you need to be able to explain what the promise actually means and how you intend to achieve it.

What about “carbon neutral”?

This is an area where brands should be particularly careful.

The Directive introduces specific restrictions around claims that a product has a neutral, reduced or positive environmental impact in terms of greenhouse-gas emissions when those claims are based on offsetting.

The legislation specifically addresses claims such as “carbon neutral,” “climate neutral,” “carbon positive” and similar statements.

The important distinction is between the actual environmental impact of the product and claims based on compensating for emissions elsewhere.

They are not the same thing.

Marketing doesn't have to become boring

There is a slightly unfortunate fear that stricter greenwashing rules will result in brands saying nothing interesting at all.

It doesn't have to.

In fact, I think the opposite can happen.

When brands can no longer rely on vague phrases such as “eco-friendly” or “sustainable,” they have to become better at explaining what makes their product interesting.

That means better material stories.

Better photography.

Better education.

Better product descriptions.

Better conversations between the material producer, designer, marketing team and sales team.

And, ultimately, better products.

The most compelling story may not be:

“This is a sustainable bag.”

It might be:

“This bag uses a material made from agricultural by-products that contains 95% bio-based plant content, and here is exactly what that means.”

That is a much more interesting story.

New materials need a different kind of marketing

Some of the practical marketing strategies for innovative materials still make sense.

You may want to work closely with the material producer, particularly if they are actively building awareness of the material.

You may want to use exhibitions, physical retail and samples because customers often need to touch an unfamiliar material before they understand it.

You may want to work with designers, stylists, journalists or influencers who are genuinely interested in material innovation rather than simply sending products out for one-off promotion.

You may want to use limited releases or pre-orders when material availability is limited.

And you should certainly invest in good branding and visual communication.

But the environmental claims running through all of this need to be grounded in the actual material and product data.

Marketing and material development are becoming increasingly connected.

The material file is becoming part of the marketing file

This is perhaps the biggest shift for brands working with new materials.

The information collected during material development is no longer useful only for the designer or product developer.

It can support:

  • Product descriptions

  • Sustainability claims

  • Certification statements

  • E-commerce content

  • Press materials

  • Sales training

  • Customer education

  • Digital Product Passport data

  • Regulatory compliance

This means that material documentation should be treated as something valuable.

  • Know what the material is.

  • Know what it contains.

  • Know what has been tested.

  • Know what has been certified.

  • Know what the producer actually claims.

  • And know which claims you are making yourself.

  • That foundation makes marketing considerably easier.

One important naming point

You may see the new rules described online as the EU Greenwashing Directive, Greenwashing Directive or Empowering Consumers for the Green Transition Directive.

The formal legislation is Directive (EU) 2024/825.

There is also a separate proposal called the Green Claims Directive, which would establish more detailed rules for substantiating and communicating explicit environmental claims. That is a different legislative file. It has not become binding EU law; the proposal has been stalled, and the European Commission announced its intention to withdraw it in 2025.

For brands preparing for 27 September 2026, the immediate focus should therefore be on the rules that are actually coming into application under Directive (EU) 2024/825 and their national implementation.

Marketing with evidence, not fear

The new rules don't mean brands should stop talking about innovative materials.

They mean that the material story needs to be more precise.

And perhaps that's not such a bad thing.

The best marketing for a new material should not need to hide behind a cloud of green words.

It should be able to say:

  • This is what it is.

  • This is what it contains.

  • This is what has been tested.

  • This is what has been certified.

  • This is what makes it different.

And, importantly:

  • This is what we can actually substantiate.

This is where Substanz can help

Substanz Marketing, PR & B2B Placement Services helps innovative material and fashion brands turn material innovation into clear industry communication and market visibility.

We work with brands and material producers to communicate innovative materials to relevant fashion and industry audiences through targeted marketing, PR, product placement and B2B introductions.

For brands working with new materials, good communication starts with understanding the material itself — what it is, what makes it interesting and which claims can be supported.

Because the future of sustainable material marketing probably isn't going to be about saying more.

It is going to be about saying something that can be backed up.

Explore our Consultancy Offer

#Greenwashing #EUGreenwashing #EnvironmentalClaims #MaterialInnovation #BioBasedMaterials #SustainableMaterials #FashionInnovation

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