EU Green Claims Checklist

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.

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.

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.

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 UCPD 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.

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.

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 UCPD 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, UCPD 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.