A pre-publication checklist for explicit environmental claims, labels, comparisons, and climate claims in EU consumer-facing communications.
Use it to decide what must be inventoried, substantiated, narrowed, verified, or removed before a claim reaches packaging, ads, ecommerce pages, or sales collateral.
Use this checklist for voluntary business-to-consumer environmental claims and labels that are not already governed by more specific EU product, sector, or label rules. The Green Claims Directive has not been adopted; the Commission said in June 2026 that negotiations were at a standstill and no agreement was expected in 2026. The proposal's substantiation and verification model is therefore a planning control. Run a separate consumer-law check under the and the national measures implementing Directive (EU) 2024/825, which apply from 27 September 2026.
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Section 1
1. Build the claim inventory before reviewing wording
Start with every explicit environmental statement a consumer can see or hear: packaging claims, ecommerce copy, ads, point-of-sale material, label text, QR-code summaries, comparison tables, company-level sustainability statements, and climate or carbon wording. Separate claims about a product from claims about the trader, a product part, a packaging component, a process, or a specific activity.
Flag claims that are mandatory under another EU rule or governed by a specific scheme, because the Green Claims proposal is framed for voluntary explicit claims and labels not already covered by more specific EU rules. Keep these items in the inventory, but route them to the sector rule owner instead of treating Green Claims as the only source.
Record the institutional version used for every proposal-stage control. The Commission proposal would exempt microenterprises from substantiation and linked communication duties unless they requested a certificate; the Council general approach would instead delay specified duties for microenterprises until 50 months after entry into force. Financial-services sustainability information and claims governed by specific Union acts follow other routes. Do not turn any of these draft branches into a current exemption or deadline.
Record the exact public wording, channel, country, language, product or trader boundary, and owner generating the claim.
Classify whether the claim is product-level, trader-level, package-only, process-only, future-performance, comparative, climate-related, offset-based, or label-based.
Mark generic claims such as green, eco-friendly, environmentally friendly, climate friendly, sustainable, conscious, or responsible for review before spending time on substantiation.
Identify claims that present legal compliance as a distinctive benefit, because Directive (EU) 2024/825 adds that practice to the greenwashing controls.
Keep retailer repetitions of supplier claims visible in the register, but record who generated the claim and who merely replicated it.
Assign a legal or compliance owner to choose the current-law route, a sustainability or technical owner to maintain the evidence, a marketing owner to control every public variant, and a withdrawal owner who can remove the claim across channels.
2. Substantiate only the environmental characteristic actually claimed
For each remaining claim, require an assessment that matches the claim's scope. A recycled-content claim needs composition evidence for the claimed component; a lower-pollution claim needs emissions or impact evidence for the claimed life-cycle stage; a company-level claim needs evidence for the trader activity, facilities, or value chain included in the public wording.
Do not allow the public wording to become broader than the evidence. If the dossier supports only packaging recycled content, the claim should not imply that the whole product is recycled, circular, or environmentally preferable.
Specify whether the claim covers the whole product, part of the product, a product aspect, all trader activities, or only a defined activity.
Attach widely recognised scientific evidence, accurate information, and any relevant Union or international standards used for the method.
Use primary company-specific information where it is available for the claimed environmental characteristic.
Use representative secondary information only where primary information is unavailable, and document why it is representative of the value chain.
Confirm that the claimed benefit is not merely equivalent to a legal requirement imposed on the relevant product group or sector.
A Green Claims review should not stop at the environmental attribute named in the headline. The proposal requires the substantiation assessment to consider significant environmental impacts from a life-cycle perspective and to identify whether a claimed improvement creates significant harm elsewhere.
Use Product Environmental Footprint or Organisation Environmental Footprint work where it fits the claim, but do not force every claim into a single method. The proposal itself recognises that environmental footprint methods do not cover every relevant impact category or claim type.
Identify the relevant life-cycle stages: raw material acquisition, pre-processing, manufacturing, storage, distribution, installation, use, maintenance, repair, upgrading, refurbishment, re-use, and end-of-life where relevant.
For environmental performance claims, assess all significant environmental aspects and impacts, not only the metric that makes the claim look strongest.
Document hotspot analysis, omitted stages, assumptions, data quality limits, and uncertainty where the chosen method produces them.
Reject or narrow claims where a benefit in one impact area creates an unjustified transfer of harm to climate, resources, water, pollution, biodiversity, animal welfare, ecosystems, or another life-cycle stage.
If the use phase is a relevant life-cycle stage, include the consumer-use condition needed to achieve the claimed environmental performance.
4. Apply stricter checks to comparisons, offsets, and carbon-neutral wording
Comparative claims need a separate file because the claim is about both the advertised product and the comparator. The comparison should use equivalent data, equivalent sourcing, the same assessment method, equivalent value-chain coverage, equivalent environmental-characteristic coverage, and equivalent assumptions.
Climate and carbon claims need a separate review. From 27 September 2026, national measures implementing Directive (EU) 2024/825 must prohibit product claims that rely on greenhouse-gas offsetting to say that a product has a neutral, reduced, or positive greenhouse-gas impact. Until then, existing rules and national law still require a case-specific misleading-practice review. The stalled Green Claims proposal would add transparency where climate-related claims rely on offsets or carbon credits, including whether the claim concerns emission reductions, removals, contribution claims, or offset claims.
For comparisons, confirm that the compared products serve a similar purpose or have similar use or functional properties.
State the baseline year when the claim compares improvement against the trader's older product or a no-longer-sold comparator.
Do not compare against a no-longer-active trader or no-longer-sold product unless the evidence shows a significant improvement achieved in the last five years.
Keep greenhouse-gas emissions reductions separate from offsets, and record whether offsets relate to reductions or removals.
Remove product-level claims such as climate neutral, CO2 neutral certified, carbon positive, climate net zero, climate compensated, reduced climate impact, or limited CO2 footprint when they are based on offsetting outside the product value chain.
5. Review labels, schemes, verification, and consumer disclosure
Treat environmental labels as claims, not decoration. The checklist should confirm whether the label is based on a compliant environmental labelling scheme, whether the scheme owner has the required verification route, and whether scheme ownership, decision bodies, objectives, requirements, monitoring procedures, complaints handling, and dispute handling are transparent.
Where the Green Claims proposal's verification route applies, the claim or label should not move to publication until the relevant verification file, certificate information, and consumer-facing substantiation summary are ready. Keep the control tied to the proposal text unless a cited source has enacted wording.
Check whether the label is established under Union law, by a public authority, by an officially recognised EN ISO 14024 type I ecolabel scheme, or by a private scheme.
For private and non-Union schemes, keep the scheme rationale, scope, added-value evidence, draft criteria, methodology, ownership, and decision-body documentation.
Do not use aggregated ratings or scores for a product or trader unless the source of the rating is allowed under the relevant EU rules.
Prepare a consumer-facing substantiation summary that identifies the covered environmental characteristics, relevant certificate information where applicable, and verifier contact details excluding personal data.
Put the disclosure next to the claim through a physical statement, QR code, data carrier, link, or digital product passport field where the applicable EU product rules support that route.
The final review should stop weak claims rather than only adding disclaimers. If the claim cannot survive the inventory, substantiation, life-cycle, comparison, offset, label, and checks, narrow the wording or remove it from the release.
Keep the approval record short but specific: public wording, claim classification, evidence file, life-cycle scope, trade-off assessment, comparison file if any, offset position if any, label scheme file if any, checks, verifier or certificate status where supported by cited sources, approver, and withdrawal trigger. The recorded outcome should be approve, approve with wording or placement conditions, hold for named evidence, route to another Union rule, or reject and withdraw.
Stop if the claim is generic and the team cannot demonstrate recognised excellent environmental performance relevant to the claim.
Stop if the claim makes the whole product or whole business look greener when the evidence covers only one aspect or activity.
Stop if the substantiation omits significant impacts, hides trade-offs, or relies on stale assumptions without a review trigger.
Stop if the consumer cannot access a clear summary of the substantiation, assumptions, limitations, and certificate information where applicable.
Stop if a verifier certificate is treated as immunity from review; the Green Claims materials state that authority and court assessment under Directive 2005/29/EC is not prejudged.
Reopen an approved claim when wording, translation, product composition, supplier, comparator, method, dataset, target, carbon credit, label criteria, certificate, legal rule, complaint evidence, or authority position changes.
Current official status source for treating Green Claims verification and substantiation duties as proposal-stage planning: negotiations were at a standstill and no agreement was expected in 2026.
"The negotiations on the Green Claims Directive proposal are at a standstill, and no agreement is expected in 2026."
Grounds the UCPD case-by-case review approach and transparency expectations for self-declared environmental claims, third-party certification, and labels.
Grounds the final UCPD stop-list for generic claims, whole-product overclaims, offset-based product climate claims, sustainability labels, and future environmental-performance claims.