Search every question across sub-FAQs

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.

Yes, but only if the label itself is credible for the claim being made. The Green Claims proposal treats environmental labels as explicit environmental claims and defines an environmental labelling scheme as a certification scheme that certifies a product, process, or trader against the requirements for an environmental label.

Before using a label in packaging, advertising, procurement material, or a product page, teams should check the scheme behind it. The useful evidence is not the badge artwork; it is the scheme file showing ownership, objectives, criteria, monitoring, complaint handling, non-compliance procedures, and verification.

The review should start with public transparency, because both the Green Claims proposal and Directive (EU) 2024/825 focus on whether consumers can trust the label's governance. A scheme should not be accepted if its rules, owner, decision-makers, criteria, monitoring, or non-compliance process cannot be found or understood.

For private schemes, the review should also test whether the scheme is open on fair and non-discriminatory terms, whether the requirements were developed with relevant experts and stakeholders, and whether compliance monitoring is objective and independent.

Third-party verification is central where the label is not simply a public-authority label. Directive (EU) 2024/825 defines a certification scheme as a third-party verification scheme and requires objective monitoring by a third party whose competence and independence are based on international, Union, or national standards and procedures.

The Green Claims proposal adds a separate verification layer for explicit environmental claims and environmental labelling schemes. The Council general approach keeps that structure but makes the scheme owner the party that submits the scheme and corresponding label for verification; traders awarded a compliant label may display that label without repeating the scheme-level verification.

The EU Ecolabel is different from a private sustainability badge. It is the official EU voluntary label for environmental excellence, and Commission materials describe it as promoting goods and services with reduced environmental impact across the life cycle.

Teams can use EU Ecolabel evidence when the public claim stays inside the certified product group and criteria. They should still preserve the product group criteria, licence or catalogue record, and claim wording, because a label for one criterion or product group does not automatically support a broad claim such as sustainable, responsible, or green for the whole business.

The Green Claims proposal is designed to slow proliferation of environmental labels, not to invite new badges for every product line. The Commission proposal would have stopped new national or regional public schemes after transposition while allowing new schemes under Union law; it would also have required new private schemes to be approved only where they add environmental value compared with existing schemes.

The Council general approach changes the detail: new national or regional public schemes and public schemes from third countries would be subject to Commission approval before entering the Union market, while new private schemes would need Member State approval and added value. Existing schemes may continue only if they meet the directive's requirements. Because the proposal is not final, teams should avoid publishing fixed approval deadlines or final-law statements unless they are citing the adopted text when it exists.

Directive (EU) 2024/825 already amends the UCPD framework for consumer-facing environmental marketing. It prohibits displaying a sustainability label that is not based on a certification scheme or established by public authorities, and it also targets generic environmental claims unless the trader can demonstrate recognised excellent environmental performance relevant to the claim.

The Green Claims proposal is more specific for explicit environmental claims and environmental labels: it adds substantiation, communication, scheme governance, and verification requirements. Passing a Green Claims verification check would not automatically make a marketing practice fair under the UCPD, and the Council text expressly preserves national authority and court assessment under Directive 2005/29/EC where applicable.

An explicit environmental claim is an environmental claim made in written form or orally. The Council text distinguishes it from implicit claims such as colours or imagery, which remain handled under the wider unfair-commercial-practices framework.

For an explicit claim, the evidence file should first state exactly what the claim covers: the whole product, part of a product, a product aspect, all trader activities, or a specific activity. The assessment then needs scientific evidence, accurate information, relevant standards, significant life-cycle impacts or aspects, primary information where available, representative secondary information where primary data is not available, and a check that the claim is not merely a legal minimum.

Generic claims such as broad 'green', 'eco-friendly', or similar environmental-benefit wording are high-risk unless the specification is clear and prominent or the trader can demonstrate recognised excellent environmental performance relevant to the claim.

Do not approve a generic claim because a product has one positive attribute. The evidence should show the claimed environmental excellence is relevant to the claim, significant for the product or trader, not just common practice, and not offset by unmentioned trade-offs.

A comparative environmental claim says or implies that one product or trader has lower environmental impact or better environmental performance than another. It needs the normal explicit-claim evidence plus equivalence across the comparison.

The comparison file should prove that the compared products or traders use equivalent data, equivalent sourcing or generation methods, equivalent value-chain coverage, equivalent impact or aspect coverage, and equivalent assumptions. If the comparison is against an older product, a discontinued product, or a trader that no longer sells to consumers, the file should state the baseline year and show the improvement is significant and recent.

Product claims need evidence for the specific good or service and the life-cycle stages that matter to that claim. If the use phase is one of the most relevant life-cycle stages, the claim should tell consumers how to use the product to achieve the stated environmental performance.

Trader or company claims need evidence for the activities covered by the wording. A company-level claim cannot borrow a narrow product improvement unless the claim clearly limits itself to that product, activity, site, business line, or environmental aspect. Product Environmental Footprint and Organisation Environmental Footprint methods are relevant because they are life-cycle methods for products and organisations, respectively.

An environmental label is not just a short claim in a logo. The proposal treats labels as claims awarded under environmental labelling schemes, with scheme-level evidence and governance requirements in addition to claim substantiation.

The scheme owner should be able to show transparent ownership, decision-making bodies, objectives, monitoring procedures, proportionate joining conditions, expert and stakeholder input for criteria, complaint and dispute handling, and non-compliance procedures. The label should also be verified against the relevant substantiation, communication, and scheme requirements unless an applicable exemption or simplified route applies.

Climate claims need the normal explicit-claim file and a separate climate evidence file. Product-level claims that a product has a neutral, reduced, or positive greenhouse-gas impact based on offsetting are a specific red flag: the Council text describes those product claims as prohibited under Directive 2024/825 when they rely on offsets outside the product value chain.

For trader climate claims using carbon credits, the evidence should separate the trader's greenhouse-gas emissions and reductions from any credits. It should identify the quantity of credits in tCO2e, the period, whether credits are reductions or removals, the scheme, registry, verification and certification route, and, for offset claims, the percentage of total greenhouse-gas emissions balanced out by credits.

Every category needs a claim register entry before publication. The entry should identify the exact wording, medium, market, product or trader boundary, category, owner, evidence method, source data, consumer-facing support, verification route, and review trigger.

The evidence file should be strong enough for a reviewer to tell whether the claim is specific, accurate, significant, current, not misleading by omission, and not broader than the data. It should also preserve the public explanation consumers will see, because Green Claims communication rules focus on both substantiation and how the substantiated claim is communicated.

The Green Claims Directive is grounded as Commission proposal COM(2023) 166 for a directive on substantiation and communication of explicit environmental claims. The proposal was published on 22 March 2023 and is tracked under ordinary legislative procedure 2023/0085(COD).

Do not describe this file as an adopted final Green Claims Directive or attach final transposition and application deadlines unless a later final act is added to the grounding sources. The grounded procedure records show legislative progress, not completion.

The European Parliament adopted its first-reading position on the Green Claims Directive proposal on 12 March 2024. That is a legislative milestone, not the adoption of the final directive.

For public copy, say that Parliament adopted a first-reading position, or that the text was adopted by Parliament at first reading. Avoid wording that makes the Parliament vote sound like the completed EU act.

The Council approved a general approach for the Green Claims Directive at the Environment Council meeting on 17 June 2024. The Council document is a negotiating position showing changes against the Commission proposal.

A Council general approach is not the same thing as the adopted final directive. It is useful for monitoring likely negotiation direction, but it should not be used to publish final legal deadlines.