EU Green Claims Directive · FAQ index

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Author: Sorena AI
Published: May 9, 2026
Updated: Oct 15, 2026

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Claims Evidence under the EU Green Claims Directive

What evidence should exist before an explicit environmental claim is communicated?

Before a voluntary is communicated to consumers, the evidence file should substantiate the exact claim being made. That means the record 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 record should not only contain a corporate ESG report or supplier certificate unrelated to that impact.

Claim text: the exact wording, imagery, label, channel, market, language, and date range for the claim.
Claim scope: whether the statement covers a product, packaging, service, business activity, trader, or a specific life-cycle stage.
Substantiation method: the scientific method, standard, assessment, study, dataset, or category rule used to support the claim.
Data trail: primary company-specific information for significant aspects within the trader's influence and where available, plus accurate and representative secondary information where primary information is unavailable.
Verification trail: verifier review, where applicable, unresolved assumptions, and any limits on what the claim can say.

Read answer in guide Open FAQ module

Claims Evidence under the EU Green Claims Directive

How scientific and life-cycle evidence should be scoped

A claim file should identify the environmental aspects and impacts relevant to the product or trader and should not omit significant impacts. Considering the life cycle does not always require a full : a narrower method may fit a single-attribute claim, but the file should explain the boundary and show that omitted stages or impacts do not make the claim misleading.

and can be useful where they fit the product category or organisation context because Commission Recommendation (EU) 2021/2279 recommends them as methods for measuring environmental performance. The Recommendation is not a universal legal mandate. The record should show the functional unit or organisational boundary, life-cycle stages, impact categories, datasets, assumptions, and data quality.

Map the claim to the environmental aspect or impact it actually communicates, such as recycled content, emissions, durability, water use, biodiversity impact, or end-of-life performance.
List significant environmental aspects and impacts considered, including potential trade-offs and burden shifts across life-cycle stages.
Explain exclusions from full life-cycle coverage and why those exclusions do not make the claim misleading.
Use PEFCR, OEFSR, , , EU Ecolabel criteria, green public procurement criteria, or other Union rules only when they are relevant to the product category, organisation, or claim type.
Keep enough method detail for review: boundary, baseline, data quality, impact categories, assumptions, uncertainty, and source of each material data point.

Read answer in guide Open FAQ module

Claims Evidence under the EU Green Claims Directive

What extra evidence is needed for comparative environmental claims?

A comparative claim needs evidence for both sides of the comparison. The record 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.

Comparable object: product, service, organisation, market, geography, function, and time period being compared.
Equivalent method: same functional unit, scope, boundary, life-cycle stages, impact categories, assumptions, and calculation method where the claim depends on quantification.
Equivalent data: source, quality, representativeness, freshness, and whether primary or secondary data was used for each side.
Baseline and recency: baseline year and evidence that the comparison is still meaningful in the current market.
Trade-offs: whether the claimed improvement worsens another relevant impact or shifts impact to another life-cycle stage.

Read answer in guide Open FAQ module

Claims Evidence under the EU Green Claims Directive

What records should stay available after the claim is published?

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 supporting information to accompany the claim or be available through a web link, QR code, or equivalent channel. The exact disclosure content differs between the Commission, Parliament, and Council positions and cannot be treated as final.

The Council draft would require review when circumstances may affect accuracy and no later than five years after certificate issuance or, where applicable, the date Specific Technical Documentation is made available to authorities. Updated substantiation would require verification; for an Article 3a claim, the trader would update the Specific Technical Documentation. This proposal-stage backstop would not permit waiting when a supplier, formulation, method, comparator, claim, or other material fact changes sooner.

Claim register: live and retired claim text, channels, markets, first publication date, withdrawal date, and responsible owner.
Substantiation file: studies, datasets, assumptions, calculations, product specifications, supplier attestations, and independent verification records.
Consumer-facing explanation: the public summary, web page, QR destination, label text, or other route used to explain the basis of the claim.
Certificate and verifier details: where issued, verifier contact information, review findings, and remediation actions.
Change log: updates after product redesign, supplier changes, new scientific evidence, new comparable products, method changes, or authority feedback.

Read answer in guide Open FAQ module

Claims Evidence under the EU Green Claims Directive

Questions and answers

What evidence should exist before an environmental claim is published?

Keep the exact claim and consumer presentation, the product, service, or trader boundary, the claimed impact or aspect, the method, calculations and data, significant life-cycle stages, assumptions, limitations, trade-offs, approval owner, and any verifier record. The evidence must support the wording consumers see, not a broader sustainability narrative.

Does every claim need a full ?

No. A narrower method may support a specific single-attribute claim, but the file should identify the assessment boundary and show that omitted life-cycle stages or environmental impacts do not make the claim misleading. Use , , category rules, ecolabel criteria, or another method only where it fits the product, organisation, and claim.

When should claim evidence be reviewed?

Review evidence whenever a product, supplier, dataset, method, comparator, market, wording, scientific finding, or legal rule could affect accuracy. The Council draft also proposes review no later than five years after certificate issuance or, where applicable, the date Specific Technical Documentation is made available to authorities. Updated substantiation would go through verification, while an Article 3a claim would instead require updated Specific Technical Documentation. These are proposal-stage routes.

Read answer in guide Open FAQ module

Environmental labels and certification schemes under EU Green Claims rules

Can teams use an environmental label as evidence for a green claim?

Yes, but only within the label's certified scope. The Commission Green Claims proposal treats environmental labels as explicit environmental claims and defines an as a that certifies a product, process, or trader against the requirements for an . A valid award does not substantiate broader wording about impacts or activities outside the scheme criteria.

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.

Map the label to the exact product, process, trader, and environmental characteristic that the public claim mentions.
Confirm that the label is based on a or was established by a public authority.
Check that scheme ownership, decision-making bodies, objectives, requirements, and monitoring procedures are public and understandable.
Keep the award decision, scope of certification, criteria version, monitoring records, and any withdrawal or suspension conditions with the claim file.

Read answer in guide Open FAQ module

Environmental labels and certification schemes under EU Green Claims rules

What transparency checks belong in a certification-scheme review?

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.

Ownership and decision-making: identify the scheme owner, decision body, conflicts process, and funding model where available.
Criteria and methodology: store the criteria version, product group or trader scope, scientific basis, stakeholder consultation record, and update history.
Access terms: check whether SMEs and other applicants can join on proportionate, transparent, and non-discriminatory terms.
Monitoring and enforcement: retain audit, surveillance, complaint, dispute, withdrawal, and suspension procedures.
Verification: document the third-party body or public-body process used to assess compliance, including competence and independence.

Read answer in guide Open FAQ module

Environmental labels and certification schemes under EU Green Claims rules

Does third-party verification apply to labels?

Third-party verification is central where the label is not established by a public authority. Directive (EU) 2024/825 defines a as a third-party verification scheme with publicly available terms and objective compliance monitoring by an independent, competent third party. National measures apply these new rules from 27 September 2026.

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.

For the scheme owner: keep the verifier appointment, independence basis, verification scope, certificate of conformity, and any re-verification trigger.
For the trader using the label: keep proof that the product, process, or trader was actually awarded the label and that use stays within the certified scope.
For marketing teams: do not convert a narrow label award into a broader claim about the whole product, company, or future performance.
For retailers and distributors: keep supplier documentation showing whether the displayed label is public-authority based or certification-scheme based.

Read answer in guide Open FAQ module

Environmental labels and certification schemes under EU Green Claims rules

How should teams treat the EU Ecolabel?

The 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 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.

Confirm the product or service is covered by the relevant product group and criteria.
Keep the licence or catalogue evidence with the exact product or service identifier.
Use claim wording that matches the certified scope and does not imply unverified benefits outside the criteria.
Refresh the evidence when criteria, licence status, product composition, supplier data, or claim wording changes.

Read answer in guide Open FAQ module

Environmental labels and certification schemes under EU Green Claims rules

Can new public or private environmental labelling schemes still be created?

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.

Prefer existing Union-level schemes and officially recognised type I ecolabels before creating a new label.
For a proposed private scheme, prepare evidence of added value, environmental ambition, coverage, criteria, methodology, market impact, ownership, and decision-making.
For a proposed public scheme, check whether the latest legislative text requires Commission approval and publication on an allowed-label list.
Before a new label launch, check the current UCPD and national rules, certification-scheme or public-authority basis, award status, and permitted scope. Track the Green Claims draft approval proposals separately; their stalled status does not itself prohibit a label launch.

Read answer in guide Open FAQ module

Environmental labels and certification schemes under EU Green Claims rules

How does Directive (EU) 2024/825 overlap with the Green Claims proposal?

Directive (EU) 2024/825 amends the UCPD framework for consumer-facing marketing. From 27 September 2026, national measures must prohibit displaying a that is not based on a or established by public authorities. They also prohibit generic environmental claims unless the trader demonstrates recognised excellent environmental performance relevant to the claim. Existing UCPD misleading-practice rules continue to apply before that date.

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.

For products or packaging created before 27 September 2026, do not assume a blanket old-stock exemption. The CPC authorities' June 2026 common understanding expects timely, good-faith compliance work and says authorities may phase enforcement where genuine and specific transitional difficulties arise. The treatment remains fact- and authority-specific.

Run the existing UCPD screen now, and prepare for the national Directive (EU) 2024/825 rules that apply from 27 September 2026 on sustainability-label basis, generic claims, whole-product overclaims, and future-performance claims.
Run the Green Claims screen for explicit environmental claim substantiation, communication, environmental-label scheme governance, and verification.
Do not rely on a certificate, label award, or verifier note to justify misleading claim wording outside the certified scope.
Keep separate evidence for the label's certification basis and for each consumer-facing claim that uses the label.
For old stock, record when labelled products or packaging were manufactured, ordered, distributed, or placed on shelves, the remaining quantities, relabelling or withdrawal options, good-faith mitigation steps, and any national authority direction.

Read answer in guide Open FAQ module

Environmental labels and certification schemes under EU Green Claims rules

Questions and answers

Can an substantiate a green claim?

Yes, but only within the certified scope. Keep the scheme criteria, award decision, covered product, process or trader, criteria version, validity status, monitoring record, and public claim wording. A narrow label award does not substantiate a broader claim about the whole product, business, or future performance.

Which sustainability labels can be displayed from 27 September 2026?

Under national measures implementing Directive (EU) 2024/825, a must be based on a or established by a public authority. A trader-created badge without independent scheme monitoring does not satisfy that basis, even if the underlying product has a documented environmental attribute.

Does old packaging get a blanket exemption?

No blanket exemption appears in Directive (EU) 2024/825. The CPC authorities' June 2026 common understanding expects timely, good-faith compliance steps and allows authorities to take a phased approach where genuine and specific old-stock difficulties arise. Record manufacture, order, distribution and shelf dates, quantities, mitigation steps, and the national authority position.

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EU Green Claims claim categories

What counts as an explicit environmental claim?

An 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.

Classify as explicit when the environmental message is written or spoken, including packaging copy, website copy, advertising text, sales scripts, and environmental wording in a product or company name.
State the claim boundary before review: whole product, product part, product aspect, whole trader, or defined trader activity.
Keep substantiation showing significance from a life-cycle perspective, relevant standards or methods, primary and secondary data sources, assumptions, limitations, and trade-off checks.
Make the consumer-facing support available with the claim through physical information, a web link, QR code, or equivalent route where the proposal requires it.

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EU Green Claims claim categories

How should teams handle generic environmental claims?

Directive (EU) 2024/825 defines a as written or oral environmental wording whose specification is not provided in clear and prominent terms on the same medium. From 27 September 2026, national implementing measures prohibit such a claim unless the trader can demonstrate recognised excellent environmental performance relevant to it. Existing UCPD rules can still catch vague or misleading wording before then.

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.

Rewrite broad wording into the specific benefit being claimed, such as recycled content, lower emissions in a defined life-cycle stage, reduced water use, reparability, or waste reduction.
If the generic wording remains, document the recognised excellent environmental performance relied on and why it is relevant to the exact claim.
Check that the claim does not present a legal requirement or common market practice as a special environmental advantage.
Use prominent qualifying language on the same medium so the consumer sees the limitation without hunting for a footnote.

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EU Green Claims claim categories

What extra evidence is needed for comparative claims?

A 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 record should state the baseline year and show the improvement is significant and recent.

Identify the comparator by product, trader, market, and function served.
For Council-text planning, use the same assessment method and equivalent data quality, value-chain stages, impact coverage, allocation rules, and assumptions on each side.
Record the baseline year where the claim is an improvement claim against an earlier product or trader.
Do not publish a comparison if material impact categories, life-cycle stages, or assumptions differ in a way that makes the comparison unfair or misleading.

Read answer in guide Open FAQ module