Does a green leaf on the packaging count as an environmental claim?

Yes, possibly. The legal definition of an environmental claim expressly covers representations through images, graphic elements and symbols as well as labels, brand names, company names and product names. A graphic element suggesting a positive environmental effect can therefore fall under the same rules as a written claim.

What counts is the overall impression the pack creates, not the single element. Green colouring combined with nature imagery can create the same impression as a written claim and is then subject to the same requirements. Anyone pointing to an environmental benefit visually needs the same evidence as for the sentence beside it.