Good Earth Cotton® says the EU’s new environmental-claim rules highlight the growing importance of measured outcomes, independent verification and physical fibre traceability.
Good Earth Cotton® (GEC) has highlighted the growing importance of evidence-based environmental claims as new European Union measures under the Empowering Consumers for the Green Transition Directive (EmpCo) begin to apply across EU Member States from 27 September.
The measures raise the evidentiary threshold for environmental claims, including restrictions on generic environmental claims that cannot demonstrate recognised environmental performance.
GEC said the regulatory development reflects a broader shift in the market from practice-based environmental claims towards claims supported by measurable outcomes, primary data, independent verification and physical material traceability.
EU rules raise focus on environmental evidence
European Commission analysis cited by GEC found that 53% of green claims examined in the EU market provide vague, misleading or unfounded information, while 40% have no supporting evidence. The analysis also found that half of green labels offered weak or non-existent verification.
According to GEC, the regulatory direction places greater emphasis on substantiating environmental claims before they are made.
For the fibre sector, the company said this distinction is particularly relevant because cotton remains a significant part of global fibre production.
Cotton accounted for approximately 19% of global fibre production in 2024, representing around 24.5 million tonnes, while recycled cotton accounted for approximately 1% of global cotton production, at around 300,000 tonnes.
GEC focuses on measured farming outcomes
Good Earth Cotton® describes its approach as Next Generation Farming, using an outcomes-focused model in which environmental performance is measured against established baselines using primary farm-level data.
The company said the data is independently verified and connected to fibre that is physically verified at source.
The model currently represents approximately 60,000 metric tonnes of physically verified GEC fibre, which the company estimates is sufficient to produce around 300 million T-shirts for the global market.
GEC said its approach distinguishes between farming practices and measurable outcomes. While practices describe interventions undertaken on farms, outcomes provide data on the resulting environmental changes.
The company noted that farms operate within different soil, climate, water and production conditions, meaning the same intervention may not produce identical results in every location.
Three-part evidence architecture
GEC said its evidence model is built around three connected elements: measured outcomes, verified data and verified fibre.
Farm-specific primary data is assessed against established baselines and monitored over time. For greenhouse gas emissions and removals, GEC applies the ISO 14064 framework for quantification, monitoring and reporting.
According to the company, Downforce Technologies measures and quantifies farm-level data, while SGS independently verifies the greenhouse gas assessment under ISO 14064-3.
The company said this process provides independent assurance over reported greenhouse gas outcomes.
Physical fibre verification
The third component involves FibreTrace®, which establishes a physical GEC identity at source. The system enables defined verification events throughout manufacturing to confirm the detected presence of marked GEC fibre.
Danielle Statham, Founder and Owner of Good Earth Cotton® and FibreTrace®, said the company had previously used the terminology of regenerative agriculture to describe the direction of farming, but that practices and outcomes represent different aspects of environmental performance.
“The next generation of fibre will not be defined by the practice it claims. It will be defined by what can be measured, independently verified and connected to the physical fibre itself,” Statham said.
She added that primary data provides the evidence, independent verification provides confidence, and physical fibre verification maintains the connection with the material.
Shift towards substantiated environmental claims
GEC said it does not present EmpCo as an endorsement of its model. Instead, the company views the directive as part of a broader shift towards greater specificity and substantiation in environmental communications.
For the textile and fibre industry, this development places greater attention on the ability to demonstrate environmental performance through measurable data, independent verification and traceability to physical materials.
As environmental-claim requirements evolve, fibre producers, manufacturers and brands may increasingly need to distinguish between describing sustainability-related practices and demonstrating measurable environmental outcomes associated with those practices.