EU Green Claims Directive and Green Transition Rules What evidence should support environmental claims before communication?

Before a voluntary explicit environmental claim is communicated to consumers, the evidence file should substantiate the exact claim being made. That means the file should identify the product, service, or trader; the claimed environmental impact, aspect, or performance; the scientific method or study relied on; the data sources; and the verifier or review status where verification is required.

The evidence should support the public wording, not a broader or different sustainability story. If the claim says a product has lower water impact in the use phase, the file should not only contain a corporate ESG report or supplier certificate unrelated to that impact.

A claim file should identify the environmental aspects and impacts that are relevant to the product or trader and should not omit significant impacts. The assessment should consider the life cycle unless the nature of the claim justifies a narrower boundary and that limitation is explained.

PEF and OEF can be useful where grounded in the product category or organisation context because they are EU-recommended life-cycle assessment methods for quantifying environmental impacts. They should not be cited as a badge by themselves; the record should show the functional unit or organisational boundary, life-cycle stages, impact categories, datasets, assumptions, and data quality.

A comparative claim needs evidence for both sides of the comparison. The file should show that products or traders are comparable, the same or equivalent methods and assumptions were used, and the comparison is based on equivalent information and data.

If the comparison is against an earlier version of the same product, a competitor product no longer on the market, or a trader that no longer sells to consumers, the substantiation should explain the improvement, the baseline year, and whether the improvement changes other relevant environmental impacts.

Keep a publication record that connects each live claim to its substantiation package. The record should allow a reviewer to see what was communicated, which evidence supported it at the time of communication, what information was made available to consumers, and whether the evidence has been reviewed after product, supplier, method, market, or legal changes.

The 2016 compliance criteria state that substantiation should be available when claims are published and retained for a reasonable period after use in commercial communication. The Green Claims proposal also expects information supporting claims to be communicated with the claim or made available through a web link, QR code, or equivalent channel, subject to the detailed rule text.