Empowering Consumers Directive and the ProTerra Schemes
To ensure the internal European market operates efficiently and transparently-underpinned by consumer and environmental safeguards, and to advance the EU’s green transition objectives, it is key that consumers are equipped with comprehensive information. This empowers them to make purchasing decisions that support sustainable consumption, thereby reinforcing both regulatory compliance and environmental and social stewardship.
In this context, the EU will implement Directive 2024/825 which amends Directives 2005/29/EC (relating to unfair business-to-consumer commercial practices in the internal market) and 2011/83/EU (relating to consumers’ rights). The aim is to empower consumers for the green transition by providing them with better protection against unfair commercial practices and better information. The Directive will come into effect on 27 September 2026.
To uphold the fairness and credibility of environmental and social claims, Directive 2024/825 prohibits such claims unless they are substantiated by clear, objective, publicly accessible, and verifiable commitments and targets provided by the trading organisation (or trader). As sustainability labels can relate to many characteristics of a product, process or business, it is essential to ensure their transparency and credibility. Therefore, the new regulation will prohibit the display of sustainability labels that are not based on a certification scheme established by public authorities.
Before displaying a sustainability label, as per the new legal requirements, the trader should ensure that they meet the minimum conditions of transparency and credibility set out in the publicly available terms of certification scheme. This includes objective monitoring of compliance with the scheme-s requirements.
Under the new regulation, monitoring should be carried out by a third party whose competence and independence from both the scheme owner and the trader are guaranteed in accordance with international, EU or national standards and procedures. This can be demonstrated by complying with relevant international standards, such as ISO 17065 – ‘Conformity assessment – Requirements for bodies certifying products, processes and services’ or through the mechanisms set out in the regulation.
ProTerra Foundation is the owner of ProTerra Standard V5 and its interpretations, and of the ProTerra MRV V1. ProTerra-certified organisations are positioned to meet the new regulation to the extent that Directive 2024/825 applies to food and feed commodities and products.
ProTerra labels are associated with certification/verification schemes (the ProTerra Standards), which are regulated by a set of requirements and Certification/Verification Protocols. These are publicly available on the ProTerra Foundation website. The objective monitoring of compliance with the requirements of the ProTerra schemes is done on an annual basis (in form of annual certification or verification audits), and are carried out by third parties (i.e. certification or verification bodies), whose competence and independence from both the scheme owner and the trader are based on ISO 17065 (refer to the ProTerra Approval and Operational Procedures for Certification Bodies for more information). Other relevant ProTerra documents, all of which are publicly available, include: ProTerra General Terms of Use; ProTerra General Terms of Certification; ProTerra Certification Procedure; Conflict of Interest Policy; Guidelines and Requirements for the Use of the ProTerra Logos and Seals; ProTerra Grievance and Complaint Policy; ProTerra Privacy and Confidentiality Policy, and ProTerra Standards and Interpretations, among others. This framework ensures transparency and credibility as required by regulations.
The ProTerra Guidelines and Requirements for the Use of the ProTerra Logos and Seals is a key document in the context of Directive 2024/825. It regulates the types of claims and accompanying statements that can be made to ensure that no misleading information is passed down the supply chain. The correct use of logos and seals is verified during annual ProTerra audits.
Furthermore, ProTerra schemes are open to all traders willing and able to comply with the scheme’s requirements, on transparent, fair, and non-discriminatory terms. This includes the entire food and feed supply chain: from farmers, and traders, to transport and the processing industry.
Additionally, the requirements of the ProTerra scheme are developed in consultation with relevant experts and stakeholders, thereby adding to the scheme-s transparency and credibility (refer to the Terms of Reference ProTerra Standard Revision and Development, where public consultation is included under item 2.5).
Finally, the ProTerra scheme sets out procedures for dealing with non-compliance with the scheme’s requirements and provides for the withdrawal or suspension, including those associated with misuse of its sustainability label by the trader (refer to items 6.5 Non-conformities and Corrective Actions and 8. Suspension and Withdrawal of the ProTerra Certification Protocol. For PT MRV, refer to Annex B of the Verification Protocol, item 2. Suspension and Withdrawal and 3. Complaints and Appeals).
Therefore, a ProTerra certified or verified organisation meets the transparency and credibility conditions referred to in the new regulation, by using a label based on a credible and robust certification scheme where monitoring is carried out by a third party whose competence and independence from both the scheme owner and the trader. Such organisations should have no difficulty meeting the new legal requirements, as they are already providing comprehensive information on their labels and empowering consumers to make sustainable purchasing choices.