Good Earth Cotton Highlights Evidence-Based Fibre Claims Ahead of New EU Rules

EU measures taking effect from 27 September raise the evidentiary threshold for environmental claims

New measures implementing the European Union’s Empowering Consumers for the Green Transition Directive (EmpCo) will begin to apply across EU Member States from 27 September, raising the evidentiary threshold for environmental claims. Good Earth Cotton® (GEC) said its evidence-led model is based on primary farm-level data, independent verification and physical fibre verification at source.

European Commission analysis has 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 offer weak or non-existent verification.

EU Rules Increase Focus on Substantiation

The new measures restrict generic environmental claims that cannot demonstrate recognised environmental performance. The regulatory change reflects a broader move towards substantiation, with greater emphasis on the evidence supporting environmental claims before they are made.

For fibre producers and the wider textile industry, this distinction is relevant as cotton continues to account for a significant share of global fibre production.

Cotton represented approximately 19% of global fibre production in 2024, equivalent to around 24.5 million tonnes. Recycled cotton accounted for approximately 1% of global cotton production, at around 300,000 tonnes.

Good Earth Cotton® defines its Next Generation Farming approach through measured environmental outcomes. The company measures performance against established baselines using primary farm-level data, with independent verification and a connection to fibre physically verified at source.

The model currently represents approximately 60,000 metric tonnes of physically verified GEC fibre, enough to produce around 300 million T-shirts for the global market.

From Farming Practices to Measured Outcomes

GEC's approach distinguishes between farming practices and measurable outcomes. While practices describe the actions undertaken, outcomes provide evidence of changes achieved. The company notes that farms operate within different soil, climate, water and production conditions, meaning the same intervention cannot automatically be expected to produce the same result in every location.

“For years, we used the language of regenerative agriculture because it helped describe the direction farming needed to take. But a practice is an intervention; an outcome is the evidence,” said Danielle Statham, Founder and Owner of Good Earth Cotton® and FibreTrace®.

“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.”

Three-Part Evidence Framework

GEC's evidence architecture comprises 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 internationally recognised ISO 14064 framework for quantification, monitoring and reporting.

Downforce Technologies measures and quantifies farm-level data, while SGS independently verifies the greenhouse gas assessment under ISO 14064-3, providing independent assurance over the reported GHG outcomes.

The physical fibre component is supported by FibreTrace®, which establishes a physical GEC identity at source. Defined verification events throughout manufacturing can then be used to confirm the detected presence of marked GEC fibre.

“Primary data provides the evidence. Independent verification provides the confidence. Physical fibre verification preserves the connection.” Statham added.

GEC said it does not present EmpCo as an endorsement of its model. Instead, the company described the directive as reflecting a broader shift from environmental claims towards information that can be measured, independently verified and connected to the physical material, with greater emphasis on specificity, substantiation and evidence.