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Prepare affected claims for the Directive (EU) 2024/825 application date of 27 September 2026. Review generic environmental language, sustainability labels, offset-based product climate claims, whole-product or whole-business wording, and future environmental performance claims against the adopted text and the relevant national implementing law.

Do not present Green Claims proposal details as settled law. As internal planning, a claim file can identify the claim, environmental characteristic, product or trader boundary, data and method, relevant trade-offs, communication text, and any verifier or labelling-scheme step that the cited negotiating text would require.

Use a two-stage decision. First apply the current UCPD and the national implementing law for Directive (EU) 2024/825 in the consumer's Member State, including the Annex I rules from 27 September 2026. Then, only for proposal planning, test whether the voluntary explicit claim or label would enter Green Claims scope, whether another Union act supplies specific rules, and which substantiation, communication, or verification route the cited negotiating text describes.

Do not state this as final law. The Commission Q&A on the original proposal used a shorthand description - fewer than 10 employees and less than EUR 2 million turnover - and said those microenterprises would be exempt unless they chose to use the rules.

The Council general approach is different. It refers to the microenterprise definition in Commission Recommendation 2003/361/EC and gives those enterprises a later application date for listed substantiation, communication, simplified-procedure, verifier, and related obligations. The Recommendation's full test uses fewer than 10 annual work units and an annual turnover or annual balance-sheet ceiling of EUR 2 million, with partner and linked-enterprise data included where required. That is not a permanent exclusion for every claim made by a small business.

For content, intake, or product-review workflows, record which legislative text you are applying, the enterprise-size basis used, and whether the statement is about a Green Claims proposal obligation or a separate unfair-commercial-practices risk.

The Council text frames scope around voluntary explicit environmental claims by traders about products or about traders, plus environmental labelling schemes and corresponding environmental labels, in business-to-consumer commercial practices.

That means a scope check should start with the communication, not only with the company size. Ask whether the statement is voluntary, explicit, environmental, directed at consumers, and about a product, service, trader, activity, or environmental label. Council recitals distinguish written or oral explicit claims from implicit claims such as imagery or colour, which remain addressed through Directive 2005/29/EC rather than the Green Claims proposal's explicit-claim rules.

The Council text also narrows responsibility by role. The trader generating the explicit environmental claim should possess the substantiation information. A trader that exactly reproduces a claim already communicated to consumers is treated differently from a producer or another trader that creates the B2C claim.

The Council text excludes explicit environmental claims, environmental labels, and environmental labelling schemes when other Union legislation already lays down specific rules for their substantiation, communication, verification, assessment, accounting, or mandatory and non-mandatory consumer information.

Examples in the Council text include EU Ecolabel, organic production, energy labelling, and ecodesign-related rules. The recitals also point to financial-services sustainability information, certain sustainability reporting under accounting-law standards, and offers such as green loans or green insurance terms as outside the Green Claims proposal's rules.

The operational point is not to label a product category as wholly outside Green Claims. A single product can carry different messages: an organic certification statement may be governed by organic rules, while a separate voluntary B2C claim on detergent packaging, a website, or advertising may still need a Green Claims or unfair-commercial-practices analysis.

Use a narrow answer: "This is a proposal-stage Green Claims scope issue. Check whether the communication is a voluntary explicit environmental claim or environmental label in B2C trade, whether another EU rule specifically regulates that claim or label, and whether the trader is a microenterprise under the text being applied."

Then state the result by text version. Under the Commission proposal materials, microenterprises were described as exempt unless they wished to use the rules. Under the Council general approach, microenterprises receive later application of specified obligations. Neither source supports presenting a settled, already-applicable Green Claims deadline or a blanket exclusion for every environmental statement by a small trader.

Separate the claim by its object. A product or service claim says something about the environmental impact, aspect, characteristic, or performance of a product, a product group, a service, a component, packaging, production method, use phase, or end-of-life stage. A company claim says something about the trader itself, the organisation, a business activity, a site, operations, a value chain, or future company performance.

For the proposal-stage scope test, an explicit environmental claim is the written or oral environmental statement presented to consumers about the product or trader. Record that exact statement before deciding which evidence boundary applies.

Do not let one evidence file silently cover both. Under the Council's June 2024 negotiating position, the proposed substantiation assessment would specify whether the claim relates to the whole product, part of a product, certain aspects of a product, all activities of a trader, or only part of those activities. If the public wording crosses that boundary, narrow the wording or expand the evidence before publication.

Directive (EU) 2024/825 gives concrete boundary examples. "Made with recycled material" can mislead when only the packaging is recycled but the presentation covers the entire product. A trader can also mislead by implying that its whole business uses renewable energy when several facilities still use fossil fuels. A narrower, accurate statement about the packaging or a measured business-wide reduction can remain possible.

For a product or service claim, evidence must fit the product boundary being advertised. The Council general approach would require recognised scientific evidence, accurate information, and relevant methods or international standards, with the claimed environmental characteristics shown to be relevant and significant from a life-cycle perspective.

A narrow favourable attribute does not support wording that implies broader product performance. Under the Council negotiating text, if consumer use is among the most relevant life-cycle stages, the claim would also include instructions on how to achieve the stated environmental performance. These are proposal-stage requirements, not current Green Claims law.

For a company or trader claim, the evidence scope follows the activity presented to consumers. A claim about the whole organisation needs evidence for that broader boundary. A claim about one division, site, fleet, store format, procurement programme, or future target should name that narrower boundary.

The Council negotiating text covers explicit environmental claims about traders as well as products. Under that text, a product footprint or label would not by itself substantiate a broad organisation claim unless the evidence also covered the trader activity and environmental characteristics communicated. Independently, the adopted Directive (EU) 2024/825 adds a UCPD prohibition, applicable from 27 September 2026, on whole-business wording based on one specific business activity.

Publish only wording that the evidence supports. Identify the product, service, trader, or activity covered and avoid implying a broader environmental benefit. Under the Council general approach, a covered explicit claim would also need a clear consumer-facing summary of its substantiation, but that Green Claims requirement remains proposal-stage.

Boundary drift occurs when product evidence implies a company-wide benefit, or company-level initiatives imply that every product or service is environmentally better. Treat those as separate claims unless the same evidence covers both objects, all significant impacts, and the same comparison baseline.

Build the workflow around the claim, not around a generic compliance calendar. The Commission proposal says explicit environmental claims would need substantiation and ex-ante verification before they are used in commercial communications. The Council general approach keeps that structure but changes some drafting, including references to claims being generated by the trader and environmental labels or schemes being made available.

The first gate is therefore scope and claim wording: identify the exact explicit environmental claim, the product or trader it concerns, whether another EU regime already sets specific rules, and whether the claim is ordinary verification or a Council-proposed simplified-procedure case handled through Specific Technical Documentation.

Record one branch before work starts. An out-of-scope B2B or implicit-only message stays with the applicable consumer, advertising, or national-law review. A claim specifically regulated by another Union act follows that act. A Council simplified-procedure claim uses the prescribed self-declaration record. An ordinary in-scope claim moves through substantiation, verifier review, certificate decision, consumer communication, publication, and later reassessment.

The Council simplified branch covers four proposed categories: claims that exceed minimum requirements in another Union act using that act's method; claims corresponding to environmental characteristics certified by an awarded label; claims directly tied to specified Common Agricultural Policy eco-schemes or interventions; and single-characteristic, low-trade-off claim types later listed by Commission implementing act. Comparative, climate-related, and future environmental-performance claims cannot use the listed implementing-act shortcut.

The verifier workflow starts with a substantiation file that can be checked against the proposed requirements. For ordinary explicit environmental claims, the Commission proposal says the assessment should rely on recognised scientific evidence and state-of-the-art technical knowledge, identify significant impacts from a life-cycle perspective, cover relevant environmental aspects, state whether the claim applies to the whole product or trader or only part of it, address legal-baseline claims, trade-offs, offsets where relevant, and use accurate primary or secondary information.

For comparative claims, the dossier should also show that compared products or traders use equivalent information, data generation or sourcing, value-chain coverage, impact coverage, and assumptions. If the Council simplified procedure applies, the record is not a full verifier package; it is the Specific Technical Documentation required before the claim is public.

Under the proposal, the verifier does not approve the trader's commercial strategy. The Commission proposal describes a third-party conformity assessment body accredited under Regulation (EC) No 765/2008. The Council general approach also refers to accredited conformity assessment bodies for verification activities or EMAS environmental verifiers, and adds EN ISO/IEC 17029 compliance.

The verifier checks the substantiation assessment and the nature and content of the claim against the applicable requirements. The Council recitals say the consumer-facing communication itself is not subject to verification, although it must still comply with the communication rules. If compliance is demonstrated, the verifier issues a certificate of conformity. The certificate supports cross-EU recognition by competent authorities, but it does not prevent national authorities or courts from assessing the commercial practice under the Unfair Commercial Practices Directive.

Keep the record set tied to the verifier decision. For ordinary verified claims, that means the claim version, substantiation assessment, verifier correspondence, certificate of conformity if issued, and consumer-facing summary or link material. The Commission proposal expects claim communication to include substantiation information such as covered aspects, underlying studies and calculations, how improvements are achieved, the certificate, and verifier contact details.

The Council text adds a certificate-management trail: certificates, review certificates, withdrawals, and updates would be communicated through a public interface connected to IMI, with the Commission publishing an up-to-date list on the Single Digital Gateway. The Council text also says certificates would be valid for no more than five years and substantiation must be reviewed earlier if circumstances affect claim accuracy. These systems and validity rules remain proposal-stage.

Do not lock implementation dates, forms, or certificate mechanics from this FAQ alone. The cited materials include the Commission proposal and the Council's 17 June 2024 general approach; neither is a final enacted Directive. As checked on 25 July 2026, the European Parliament procedure file still records the proposal as awaiting the Council's first-reading position. Any final workflow depends on adoption, publication, national transposition, and implementing acts for details such as the certificate form and technical issuing or notification procedures.

Teams can still prepare useful records now: map claims, collect substantiation evidence, identify likely verifier inputs, and keep a versioned watchlist of text changes between the Commission proposal, Parliament position, Council general approach, and the final Directive when available.