Dear Member,

The possibility that the Responsible Care logo might be regarded as a "sustainability label" by national implementing authorities under (EU) Directive 2024/825 on raising consumer awareness of greenwashing and empowering them regarding the green transition has been brought to Cefic’s attention by several national chemical industry associations.

This concern stems in particular from the risk that, in communications aimed at consumers, the Responsible Care logo could be perceived as a mark that distinguishes or promotes companies, products, services or processes on the basis of their environmental or social characteristics. The use of a green colour variation for the logo and the inclusion of the slogan “Driving Safety & Sustainability” have been identified as factors that could exacerbate this risk.

The matter was addressed jointly by Cefic’s HSSE, Responsible Care & Supply Chain Department and its Legal Department, and an independent external legal opinion was sought from the law firm Covington to assess the potential legal implications.

In the assessment carried out by Covington, it was noted that the current Responsible Care programme does not require independent third-party auditing or verification for all participating companies, nor does it provide for a mechanism to revoke the right to use the logo in the event of non-compliance with the programme’s requirements. It was therefore concluded that, whilst the programme does not meet the minimum requirements of the certification system model defined in the Directive, there is a risk that the logo may be perceived as a sustainability label, particularly in communications aimed at consumers.

Following the legal assessment, Cefic reviewed the existing rules governing the use of the Responsible Care logo in Europe and prepared a draft guideline. The main changes envisaged in the draft include:

• discontinuing the use of variations of the Responsible Care logo that include the colour green,
• removing the slogan "Driving Safety & Sustainability",
• and restricting the use of the logo on consumer-facing websites, product packaging, advertising and marketing materials, and other communications accessible to the public.

It is strongly emphasised that the provisions set out in the draft guidance are still subject to consultation and final approval, and therefore the current text should not be regarded as definitive rules.

You can access the TKSD Information Note containing detailed information on this subject here.

You can view Cefic’s draft guidance on the use of the RC logo here.