EU Green Claims Directive Proposal Claim substantiation evidence workflow

First record the legal status you are working from. After the Commission proposal and the co-legislators' 2024 positions, two trilogues took place in 2025. The Commission announced an intention to withdraw the proposal on 20 June 2025, and the planned third trilogue was cancelled. A 2026 Council budget document says negotiations are at a standstill and no agreement is expected in 2026. OEIL still shows no final Green Claims Directive or formal withdrawal, so do not convert proposal milestones or the budget statement into binding duties, deadlines, or formal closure.

Then capture the consumer-facing wording exactly as it will appear on a package, page, label, ad, sales deck, marketplace listing, QR-code landing page, or in-store material. Record who generated the claim, where it will be used, whether it concerns a product, part of a product, the trader, or a specific activity, and whether another EU rule already sets the substantiation, communication, labelling, or verification method for that claim.

For each claim, create a substantiation file that ties the wording to recognised scientific evidence, accurate information, relevant methods or international standards, and the specific environmental characteristics being claimed. The record should explain why those characteristics are significant for the product or trader from a life-cycle perspective, not just convenient because the data is easy to collect.

Use primary company-specific information where available for the characteristics subject to the claim. Where primary information is not available, record the secondary information used, why it is representative of the value chain, and the quality checks applied. If evidence is uncertain, contested, stale, or unavailable for a significant impact, narrow the claim, switch to factual performance reporting, or hold it.

A claim about one environmental benefit can mislead if it hides significant impacts elsewhere. The workflow should therefore check the life-cycle stages and impact categories that are relevant to the claim, then document why the claim does or does not need a full life-cycle assessment.

For claims based on Product Environmental Footprint, Organisation Environmental Footprint, PEFCRs, OEFSRs, or another accepted method, keep the functional unit, reference flow or product portfolio, system boundary, data sources, impact categories, hotspot interpretation, assumptions, and limitations with the claim file. For narrower claims, keep the rationale for using a narrower assessment and the checks performed to avoid burden shifting.

Comparative claims need their own evidence gate because the comparison can fail even when the trader's own data is strong. The compared products or traders should serve a similar purpose or be in the same product group or sector, the method and data should be equivalent, the relevant value-chain stages should be equivalent, and assumptions should be set consistently.

Climate and carbon-credit claims also need a separate gate. From 27 September 2026, national measures implementing Directive (EU) 2024/825 must prohibit product claims that, based on offsetting greenhouse gas emissions, state that a product has a neutral, reduced, or positive greenhouse-gas impact. The Council Green Claims text separately addresses climate-related trader claims, carbon credits, contribution claims, and offset claims, and calls for separate information on greenhouse gas emissions, reductions, future performance, and carbon credits where applicable.

Approval should be a release gate, not a loose legal sign-off. The record should show who approved the final wording, what evidence was approved, whether the Council-text route would require third-party verification or Specific Technical Documentation, what consumer-facing substantiation summary is available, and when the claim must be reviewed.

The Council text provides review triggers that are useful operational controls: review the information when circumstances may affect claim accuracy and no later than five years from the certificate of conformity or relevant Specific Technical Documentation date. Reopen earlier when the product, supplier, method, data source, legal rule, claim wording, packaging, comparison set, carbon-credit position, verifier certificate, or consumer-facing summary changes.

Assign the handoff before release. Marketing owns the exact public variants; the product or operations owner confirms the subject boundary; the sustainability or technical owner maintains calculations and source data; legal or compliance selects the rule path and records conditions; an independent verifier acts only where an applicable route requires one; and a named publication owner can hold, correct, or withdraw every live use.