GRI 417 Marketing & Labelling
GRI 417 requires companies to disclose the percentage of significant product and service categories covered by labelling procedures, and incidents of non-compliance with marketing and labelling regulations. As greenwashing enforcement intensifies, accurate product environmental labelling is increasingly a material compliance and reputational risk.
GRI 417 requires companies to disclose the percentage of significant product and service categories covered by labelling procedures, and incidents of non-compliance with marketing and labelling regulations. 417-1 Requirements for product and service information and labelling: The percentage of significant product and service categories covered by and assessed for compliance with procedures for product and service information and labelling.
The three GRI 417 disclosures
417-1 Requirements for product and service information and labelling: The percentage of significant product and service categories covered by and assessed for compliance with procedures for product and service information and labelling. The types of information required by the organisation's procedures — sourcing of components; content (especially hazardous substances); safe use instructions; disposal information; and whether labelling is required by regulation or voluntary.
417-2 Incidents of non-compliance concerning product and service information and labelling: Total number of incidents of non-compliance with regulations and/or voluntary codes concerning product and service information and labelling during the reporting period, broken down by: fines or penalties; warnings; incidents of non-compliance with voluntary codes.
417-3 Incidents of non-compliance concerning marketing communications: Total number of incidents of non-compliance with regulations and/or voluntary codes concerning marketing communications — advertising, promotion, and sponsorship. This covers: misleading advertising; prohibited marketing to children; false environmental claims; and violations of responsible marketing codes.
Environmental labelling and the Green Claims Directive
The most commercially significant aspect of GRI 417 in 2026 is environmental product labelling — as the EU Green Claims Directive intensifies scrutiny of environmental claims on products and in marketing.
EU Green Claims Directive (adopted 2024): Requires that explicit environmental claims — 'carbon neutral', 'eco-friendly', 'climate positive', 'made from recycled materials' — are substantiated by scientific evidence and verified by an independent third party before being used in marketing. Claims that cannot be substantiated are prohibited.
GRI 417 and greenwashing: GRI 417-3 incidents of non-compliance with marketing communications codes covers greenwashing incidents — cases where environmental claims in marketing were found to be misleading or unsubstantiated. As Green Claims Directive enforcement ramps up from 2026, companies with unsubstantiated environmental claims face regulatory sanctions that will be disclosed under 417-3.
For CSRD companies: the same ESRS E1 and E5 data that underpins CSRD climate and circular economy disclosure should also be the evidence base for marketing environmental claims. Inconsistency between ESRS disclosed environmental performance and marketing claims creates dual regulatory exposure — CSRD greenwashing enforcement and Green Claims Directive enforcement simultaneously.
Responsible marketing — the financial services dimension
For financial services companies, GRI 417 marketing and labelling is particularly relevant for investment product disclosure — where greenwashing in fund marketing has attracted significant regulatory attention.
SFDR fund labelling: Article 8 and 9 fund labels under SFDR are regulatory designations — not marketing claims. However, the way these labels are used in marketing materials — describing Article 8 funds as 'sustainable' or 'ESG' when they may not meet these standards — creates GRI 417-3 exposure.
ESMA fund naming guidelines: The 2024 ESMA guidelines on fund names using ESG or sustainability-related terms effectively restrict which funds can use terms like 'sustainable', 'ESG', 'impact', or 'transition' in their names and marketing. Non-compliance with these guidelines would be a GRI 417-3 incident.
For non-financial companies: responsible marketing codes across sectors — food and beverage (restrictions on marketing to children, health claim regulations), pharmaceutical (prescription drug advertising restrictions), financial services (fair, clear, and not misleading standard) — all create GRI 417-3 incident exposure that must be tracked and disclosed.
Frequently asked questions
Does GRI 417 cover social media marketing?
Yes — GRI 417-3 marketing communications covers all marketing channels including social media, influencer marketing, and digital advertising. Greenwashing on social media — unsubstantiated environmental claims in Instagram posts or YouTube videos — constitutes a potential 417-3 incident where it breaches advertising standards or voluntary codes.
How does GRI 417 interact with ESRS G1 anti-corruption disclosures?
GRI 417-3 marketing communications incidents overlap with ESRS G1-1 business conduct — specifically where marketing non-compliance relates to deceptive practices or anti-competitive behaviour. For most companies, GRI 417 and ESRS G1 cover different aspects — 417 focuses on consumer-facing communications, G1 focuses on anti-corruption and governance.
We operate in multiple countries with different labelling requirements — how do we manage GRI 417?
GRI 417-1 should reflect your global labelling procedures — the company-wide standard for product information requirements, whether driven by the most demanding regulatory regime you operate in or by voluntary company policy. 417-2 incidents should cover all jurisdictions globally. Where non-compliance in one jurisdiction reflects a specific local regulatory nuance rather than a systemic failure, contextualise accordingly.