| Scope boundary | Product or service claim: specify whether the wording covers the whole product, part of a product, a service, a product group, or selected environmental characteristics such as recycled content, durability, emissions, packaging, or use-phase performance. | Company or trader claim: specify whether the wording covers all trader activities or only a business unit, site, activity, value-chain segment, target, label scheme, or environmental characteristic of the trader. | The public wording and the substantiation assessment must use the same boundary. Split mixed product-company messages into separate claims when evidence does not cover both. |
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| Covered actors | Product or service claim: the trader generating the explicit environmental claim, often the producer but sometimes another trader that first introduces a B2C claim, should possess substantiation for the product wording. | Company or trader claim: the trader generating the organisation-level or activity-level claim should possess the substantiation for the claimed trader activity; environmental label scheme owners substantiate label criteria. | Retailers exactly repeating an already communicated claim are different from traders that introduce or adapt the claim toward consumers. Check who generated the B2C wording before assigning evidence ownership. |
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| Trigger | Product or service claim: review before packaging, web, advertising, product-page, label, marketplace, or point-of-sale wording states or implies an environmental benefit for that product or service. | Company or trader claim: review before corporate, brand, sustainability, site, service-provider, value-chain, or future-performance wording states or implies an environmental benefit for the trader or its activities. | The trigger is the voluntary explicit environmental claim in B2C communication, not only a formal legal approval event. Implicit colour and image cues remain governed through the wider consumer-law framework. |
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| Core obligations | Product or service claim: use recognised scientific evidence, accurate information, relevant methods or standards, and a life-cycle view that identifies significant product impacts and aspects. | Company or trader claim: apply the same substantiation discipline to the trader activity, including significant environmental aspects or impacts of the activities covered by the claim. | Do not use a narrow product study to prove a broad company claim, or a corporate programme to prove every product claim, unless the evidence covers the same object and significant impacts. |
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| Evidence record | Product or service claim: keep product-specific primary information where available, representative secondary information where primary data is unavailable, assumptions, methods, calculations, value-chain scope, and limitations. | Company or trader claim: keep trader-activity data, site or value-chain scope, emissions or resource data where relevant, target assumptions, carbon credit details for climate claims, methods, calculations, and limitations. | Evidence should be readable against the consumer wording: source, claim object, environmental characteristics, data type, method, significant impacts, trade-offs, reviewer, and version. |
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| Timing and deadlines | Product or service claim: communicate the claim clearly and comprehensibly, and include use-phase instructions when consumer use is among the most relevant life-cycle stages for achieving the stated performance. | Company or trader claim: communicate the exact trader activity or organisation boundary, the environmental characteristics covered, and any climate-credit or future-performance basis without implying broader coverage. | The summary given with the claim should match the substantiation boundary and should not hide trade-offs, exclusions, or limits behind generic green wording. |
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| Enforcement | Product or service claim: compare only products that serve similar purposes or have similar use or functional properties, using equivalent data, the same assessment method, and equivalent value-chain coverage. | Company or trader claim: compare only traders in the same sector or comparable activity boundary, with equivalent data, method, environmental-characteristic coverage, assumptions, and baseline where needed. | A product comparison cannot become a company superiority claim, and a company comparison cannot imply product superiority, unless the comparison evidence separately supports that message. |
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| Overlap and reuse | Product or service claim: product data can support company reporting only for the matching product, activity, or value-chain segment, and only with the same limitations and assumptions. | Company or trader claim: company data can support product wording only when it is specific enough to the product or service and covers the relevant product impacts and life-cycle stages. | Reuse evidence with a bridge note that names what carries over, what does not, and which consumer wording must stay narrow. |
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| Practical decision rule | Product or service claim: treat Green Claims obligations as proposal and Council-text guidance until the final adopted directive and national implementation are checked for the specific claim. | Company or trader claim: do the same for trader claims, especially climate, future-performance, carbon-credit, verification, and documentation details that may change in the final text. | Avoid unsupported final-law deadlines. Use current text to improve claim quality now, but verify final legal duties before setting compliance dates or launch gates. |
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