--- title: "Product vs company claims under the EU Green Claims Directive" canonical_url: "https://www.sorena.io/artifacts/eu/green-claims-directive/faq/product-vs-company-claims" source_url: "https://www.sorena.io/artifacts/eu/green-claims-directive/faq/product-vs-company-claims" author: "Sorena AI" description: "FAQ guidance on separating product, service, and company environmental claims under the EU Green Claims proposal, with substantiation and communication boundaries." published_at: "2026-05-09" updated_at: "2026-05-09" keywords: - "EU Green Claims Directive" - "product environmental claims" - "company environmental claims" - "trader claims" - "substantiation" - "explicit environmental claims" - "Green Claims" - "communication" --- **[SORENA](https://www.sorena.io/)** - AI-Powered GRC Platform [Home](https://www.sorena.io/) | [Solutions](https://www.sorena.io/solutions) | [Artifacts](https://www.sorena.io/artifacts) | [About Us](https://www.sorena.io/about-us) | [Contact](https://www.sorena.io/contact) | [Portal](https://app.sorena.io) --- # Product vs company claims under the EU Green Claims Directive FAQ guidance on separating product, service, and company environmental claims under the EU Green Claims proposal, with substantiation and communication boundaries. *FAQ* *Green Claims* *EU* ## EU Green Claims Directive Product vs company claims A focused FAQ for separating environmental claims about a product or service from claims about the trader, company, organisation, or its activities. Use it to set the claim boundary, evidence scope, significant-impact review, and consumer-facing wording before a voluntary explicit environmental claim is published. Under the Green Claims proposal, the first question is not whether a statement sounds sustainable. It is what the explicit environmental claim is about: the whole product or service, part of it, a specific environmental characteristic, all activities of a trader, or only part of those activities. That boundary controls the substantiation file and the consumer-facing explanation. ## Product vs company claims under the EU Green Claims Directive Compare the boundary, evidence scope, significant-impact review, and communication limits for product or service environmental claims versus company or trader claims. - **Product or service claim**: A claim about a product, service, product group, component, life-cycle stage, or product environmental characteristic must be substantiated within that product or service boundary. - **Company or trader claim**: A claim about the trader, organisation, business activity, site, value chain, or future company performance must be substantiated within that trader-activity boundary. | Dimension | Product or service claim | Company or trader claim | Operational implication | Sources | | --- | --- | --- | --- | --- | | 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. | [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
[European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. | | 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. | [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. | | 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. | [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
[Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers.
[Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Directive (EU) 2024/825 complements the Green Claims proposal by prohibiting certain misleading environmental marketing practices, including unsupported generic environmental claims. | | 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. | [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
[Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. | | 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. | [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. | | 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. | [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
[Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Directive (EU) 2024/825 complements the Green Claims proposal by prohibiting certain misleading environmental marketing practices, including unsupported generic environmental claims. | | 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. | [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. | | 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. | [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
[European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. | | 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. | [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits.
[Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. | Sources for Scope boundary - Product or service claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. - Quote: "environmental impact, aspect, or performance of a product or the trader itself" Sources for Scope boundary - Company or trader claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. - Quote: "environmental impact, aspect, or performance of a product or the trader itself" Sources for Scope boundary - operational implication: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Covered actors - Product or service claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Covered actors - Company or trader claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Covered actors - operational implication: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Trigger - Product or service claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. - Quote: "reliable, comparable and verifiable information" Sources for Trigger - Company or trader claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. - Quote: "reliable, comparable and verifiable information" Sources for Trigger - operational implication: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Directive (EU) 2024/825 complements the Green Claims proposal by prohibiting certain misleading environmental marketing practices, including unsupported generic environmental claims. - Quote: "better protection against unfair practices" Sources for Core obligations - Product or service claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. - Quote: "reliable, comparable and verifiable information" Sources for Core obligations - Company or trader claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. - Quote: "reliable, comparable and verifiable information" Sources for Core obligations - operational implication: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Evidence record - Product or service claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Evidence record - Company or trader claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Evidence record - operational implication: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Timing and deadlines - Product or service claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Timing and deadlines - Company or trader claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Directive (EU) 2024/825 complements the Green Claims proposal by prohibiting certain misleading environmental marketing practices, including unsupported generic environmental claims. - Quote: "better protection against unfair practices" Sources for Timing and deadlines - operational implication: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Enforcement - Product or service claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Enforcement - Company or trader claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Enforcement - operational implication: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Overlap and reuse - Product or service claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. - Quote: "environmental impact, aspect, or performance of a product or the trader itself" Sources for Overlap and reuse - Company or trader claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. - Quote: "environmental impact, aspect, or performance of a product or the trader itself" Sources for Overlap and reuse - operational implication: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" Sources for Practical decision rule - Product or service claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. - Quote: "reliable, comparable and verifiable information" Sources for Practical decision rule - Company or trader claim: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. - Quote: "reliable, comparable and verifiable information" Sources for Practical decision rule - operational implication: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. - Quote: "reliable, comparable and verifiable information" ### How should teams decide between product and company claims? - Start with the claim object: product, service, product part, product characteristic, trader, trader activity, or future company performance. - Use the product evidence file only for the matching product or service boundary, and use the company evidence file only for the matching trader-activity boundary. - Split mixed wording into separate claims when the same substantiation does not cover both objects, all significant impacts, trade-offs, and consumer-facing explanations. Sources for the practical decision rule: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. - Quote: "environmental impact, aspect, or performance of a product or the trader itself" ## How should teams separate product claims from company claims? 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. Do not let one evidence file silently cover both. The Council text requires the substantiation assessment to 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 a certain part or aspect of those activities. If the public wording crosses that boundary, narrow the wording or expand the assessment before publication. - Product or service boundary: identify the exact product, service, component, product group, life-cycle stage, or environmental characteristic covered by the claim. - Company boundary: identify whether the claim covers the whole trader, one business line, one site, one activity, one value-chain segment, or a future company target. - Mixed wording: split statements such as "our products are sustainable because our company is carbon neutral" into separate product and trader claims, each with its own substantiation and communication summary. - Proposal-stage limit: describe this as Green Claims proposal and Council compromise text guidance unless the final adopted directive text has been checked. Sources for this answer: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. - [European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. ## What substantiation changes when the claim is about a product or service? For a product or service claim, evidence must fit the product boundary being advertised. The assessment should rely on recognised scientific evidence, accurate information, and relevant standards or methods, and it must show that the environmental characteristics claimed are relevant and significant, particularly from a life-cycle perspective. A product claim cannot cherry-pick one favourable attribute if that wording suggests broader environmental performance. If the use phase is one of the most relevant life-cycle stages, the Council text also expects consumer communication to explain how the product should be used to achieve the expected environmental performance. - Keep primary information where available for the product characteristics being claimed, such as composition, recycled content, emissions, energy use, repairability, durability, or packaging data. - Use representative secondary information only where primary information is unavailable, and document why it fits the specific value chain of the product or service. - Check trade-offs: improvements in one impact category should not hide significant harm or a transfer of negative impacts to another life-cycle stage. - If a sector-specific EU rule already governs the environmental claim, use that rule first rather than treating the Green Claims proposal as the only source. Sources for this answer: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. ## What substantiation changes when the claim is about the company? For a company or trader claim, the evidence scope follows the trader activity being presented to consumers. A claim about the whole organisation needs substantiation for the relevant overall activities; a claim about one division, site, fleet, store format, procurement programme, or future target should say so clearly and keep evidence limited to that boundary. The Council text treats trader claims as explicit environmental claims too. That means the company cannot reuse a product footprint or product label as proof of a broad organisation claim unless the product evidence actually covers the trader activity, environmental characteristics, and significant impacts being communicated. - Map the trader activity covered by the claim, including sites, operations, suppliers, services, value-chain stages, and time period. - For climate-related trader claims, keep emissions reductions and any carbon credits or offset/contribution elements separate in the substantiation summary. - Avoid turning legal minimum compliance or common sector practice into a distinctive company environmental benefit. - For future-performance claims, include the plan details required by the consumer-law framework instead of using vague net-zero or greener-company language. Sources for this answer: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Directive (EU) 2024/825 complements the Green Claims proposal by prohibiting certain misleading environmental marketing practices, including unsupported generic environmental claims. - [European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. ## What is the practical rule before publishing either type of claim? Publish only the claim that the evidence can support. The consumer-facing wording should be clear and comprehensible, identify the environmental characteristics covered, and avoid implying a broader product or company benefit than the substantiation assessment covers. The most common failure is boundary drift: product evidence is used to imply a company-wide benefit, or company-level initiatives are used to imply that every product or service is environmentally better. Treat those as separate claims unless the same evidence genuinely covers both objects, all significant impacts, and the same comparison baseline. - Before approval, ask: is this about a product, a service, a product part, the trader, or a specific trader activity? - Then ask: does the evidence cover the same boundary, life-cycle stages, significant impacts, trade-offs, baseline, and time period as the wording? - For comparisons, compare like with like: product group to product group, trader sector to trader sector, equivalent data, equivalent method, and equivalent value-chain coverage. - If the answer depends on future final-law text, say that the point is based on proposal or Council text and avoid unsupported compliance deadlines. Sources for this answer: - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. - [European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. - [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Directive (EU) 2024/825 complements the Green Claims proposal by prohibiting certain misleading environmental marketing practices, including unsupported generic environmental claims. ## Primary sources - [Council general approach on the Green Claims Directive](https://data.consilium.europa.eu/doc/document/ST-11312-2024-INIT/en/pdf?ref=sorena.io) - Council compromise text supports the distinction between explicit environmental claims about products and claims about traders, including scope, substantiation, communication, verification, and proposal-stage drafting limits. - Quote: "whole product, part of a product or certain aspects of a product, or to all activities of a trader" - [Commission proposal COM(2023) 166 for the Green Claims Directive](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A52023PC0166&ref=sorena.io) - Commission proposal explains why voluntary environmental claims need reliable, comparable, and verifiable substantiation before they are communicated to consumers. - Quote: "reliable, comparable and verifiable information" - [European Commission Q&A on European Green Claims](https://ec.europa.eu/commission/presscorner/detail/en/qanda_23_1693?ref=sorena.io) - Commission Q&A confirms the proposal covers voluntary explicit claims for consumers about a product or the trader itself and uses a life-cycle approach from raw materials to end-of-life. - Quote: "environmental impact, aspect, or performance of a product or the trader itself" - [Directive (EU) 2024/825 on empowering consumers for the green transition](https://eur-lex.europa.eu/eli/dir/2024/825/oj/eng?ref=sorena.io) - Directive (EU) 2024/825 complements the Green Claims proposal by prohibiting certain misleading environmental marketing practices, including unsupported generic environmental claims. - Quote: "better protection against unfair practices" ## Topic Guides - [Carbon offsets and carbon-neutral claims: EU Green Claims Directive requirements](/artifacts/eu/green-claims-directive/offsets-and-carbon-neutral-claims.md): How to handle carbon-neutral, climate-neutral, compensated, and offset-backed claims under Directive (EU) 2024/825 and the Green Claims proposal. - [Claims Evidence under the EU Green Claims Directive](/artifacts/eu/green-claims-directive/faq/claims-evidence.md): FAQ on the evidence expected before EU Green Claims are communicated, including scientific substantiation, life-cycle coverage, comparisons, and publication records. - [Comparative Environmental Claims Under EU Green Claims Rules](/artifacts/eu/green-claims-directive/comparative-claims.md): How to substantiate EU comparative environmental claims using equivalent products, methods, data, value-chain coverage, significant impacts, and consumer-law comparison disclosures. - [Environmental labels and certification schemes under EU Green Claims rules](/artifacts/eu/green-claims-directive/faq/labels-and-certification-schemes.md): FAQ on environmental labels, certification schemes, EU Ecolabel, third-party verification, and Directive (EU) 2024/825 overlap for green claims. - [EU Green Claims Applicability Test](/artifacts/eu/green-claims-directive/applicability-test.md): Check whether the EU Green Claims Directive proposal could apply to an explicit environmental claim, environmental label, product claim, trader claim, or B2C communication. - [EU Green Claims Checklist](/artifacts/eu/green-claims-directive/checklist.md): A concrete checklist for EU environmental claims covering claim inventory, substantiation, life-cycle impacts, comparisons, offsets, labels, verification, and UCPD overlap. - [EU Green Claims claim categories and evidence map](/artifacts/eu/green-claims-directive/claim-categories.md): Classify EU environmental claims by category: explicit, comparative, product, trader, carbon, labels, generic wording, and evidence needs. - [EU Green Claims claim categories FAQ](/artifacts/eu/green-claims-directive/faq/claim-categories.md): FAQ guidance on explicit, generic, comparative, product, company, label, and carbon claim categories under the EU Green Claims proposal. - [EU Green Claims compliance controls for proposal-stage planning](/artifacts/eu/green-claims-directive/compliance.md): Proposal-stage Green Claims compliance controls for claim inventory, substantiation, communication, labels, comparative claims, offset claims, verification planning, and evidence records. - [EU Green Claims Directive FAQ: scope, evidence, labels, offsets, and status](/artifacts/eu/green-claims-directive/faq.md): Direct answers on the EU Green Claims Directive proposal, explicit environmental claims, substantiation, labels, offsets, PEF/OEF evidence, UCPD overlap, and penalties. - [EU Green Claims Directive Procedure Calendar](/artifacts/eu/green-claims-directive/deadlines-and-compliance-calendar.md): Track grounded EU Green Claims Directive proposal milestones: Commission proposal, Parliament first reading, Council general approach, and current procedure status. - [EU Green Claims Directive proposal requirements](/artifacts/eu/green-claims-directive/requirements.md): source-linked summary of proposed EU Green Claims requirements for explicit environmental claims, substantiation, communication, verification, labels, comparisons, and Directive (EU) 2024/825 overlap. - [EU Green Claims Directive Proposal Status and Legislative Tracker](/artifacts/eu/green-claims-directive/proposal-status-and-legislative-tracker.md): Track COM(2023) 166 and procedure 2023/0085(COD) through public EUR-Lex, OEIL, Parliament, and Council files without treating the proposal as adopted law. - [EU Green Claims Directive proposal status FAQ](/artifacts/eu/green-claims-directive/faq/proposal-status.md): Current source-linked status of the EU Green Claims Directive proposal: Commission proposal, Parliament first reading, Council general approach, and procedure records. - [EU Green Claims Directive Substantiation Template](/artifacts/eu/green-claims-directive/green-claims-substantiation-template.md): A field-by-field template for substantiating EU explicit environmental claims with claim scope, evidence, method, PEF/OEF, comparison, carbon-credit, verification, and publication records. - [EU Green Claims Directive vs FTC Green Guides](/artifacts/eu/green-claims-directive/green-claims-directive-vs-ftc-green-guides.md): A source-limited comparison focused on the EU Green Claims proposal: scope, substantiation, verification, labels, offsets, and reusable evidence. - [EU Green Claims penalties and enforcement FAQ](/artifacts/eu/green-claims-directive/faq/penalties.md): FAQ on EU Green Claims penalty risk, Council and proposal enforcement principles, UCPD overlap, and evidence that reduces greenwashing risk. - [EU Green Claims Templates for Claim Evidence and Verification](/artifacts/eu/green-claims-directive/templates.md): Reusable templates for EU green-claim substantiation, verifier handoff, evidence inventory, sustainability labels, comparative claims, and Directive (EU) 2024/825 status checks. - [EU Green Claims Verification and Audit Readiness](/artifacts/eu/green-claims-directive/verification-and-audit-readiness.md): Prepare explicit environmental claims for substantiation review, verifier handoff, source traceability, communication checks, and proposal-stage caveats. - [EU Green Claims: Product vs Company Claims](/artifacts/eu/green-claims-directive/product-vs-company-claims.md): Compare product, service, and company environmental claims under the EU Green Claims proposal: scope, evidence, significant impacts, communication, and reuse limits. - [FAQ: carbon offsets and carbon-neutral claims under EU Green Claims rules](/artifacts/eu/green-claims-directive/faq/offsets-and-carbon-neutral-claims.md): FAQ guidance on carbon neutral, climate neutral, offset, carbon credit, and future climate claims under the Green Claims proposal and Directive (EU) 2024/825. - [FAQ: comparative environmental claims under EU Green Claims Directive](/artifacts/eu/green-claims-directive/faq/comparative-claims.md): FAQ guidance on EU comparative environmental claims: equivalent data, method boundaries, product comparisons, substantiation, presentation, and UCPD overlap. - [FAQ: PEF and OEF evidence requirements for EU Green Claims](/artifacts/eu/green-claims-directive/faq/pef-and-oef-evidence.md): FAQ on when Product and Organisation Environmental Footprint methods help substantiate EU environmental claims, including scope, data quality, and method limits. - [Green Claims Directive proposal status check workflow](/artifacts/eu/green-claims-directive/proposal-status-check-workflow.md): A source-linked workflow for checking the Green Claims Directive proposal status across OEIL, EUR-Lex, Council documents, and Parliament records. - [Green Claims Directive vs Empowering Consumers Directive](/artifacts/eu/green-claims-directive/green-claims-directive-vs-empowering-consumers-directive.md): Compare the Green Claims proposal with Directive (EU) 2024/825: ex-ante substantiation and verification versus adopted UCPD amendments on generic claims, future performance, labels, and timing. - [Green Claims Directive vs ISO 14021](/artifacts/eu/green-claims-directive/green-claims-directive-vs-iso-14021.md): Compare the proposed EU Green Claims Directive with ISO 14021 for voluntary environmental claims, substantiation, self-declared labels, evidence, and verification. - [Green Claims Directive vs UK Green Claims Code](/artifacts/eu/green-claims-directive/green-claims-directive-vs-uk-green-claims-code.md): Compare the EU Green Claims Directive proposal with the UK Green Claims Code, covering substantiation, communication, labels, offsets, verification, enforcement, and evidence. - [Green Claims evidence workflow for substantiation](/artifacts/eu/green-claims-directive/claim-substantiation-evidence-workflow.md): Build a Green Claims proposal evidence file for voluntary EU environmental claims: status check, scope, scientific evidence, life-cycle impacts, comparisons, carbon credits, verification, consumer communication, and review. - [Green Claims labels and certification schemes](/artifacts/eu/green-claims-directive/labels-and-certification-schemes.md): How EU Green Claims rules and Directive (EU) 2024/825 treat environmental labels, certification schemes, EU Ecolabel use, new schemes, evidence records, and consumer-facing clarity. - [Green Claims penalties and enforcement: proposal and Council approach](/artifacts/eu/green-claims-directive/penalties-and-enforcement.md): How the EU Green Claims proposal and Council general approach handle competent authorities, corrective measures, penalties, verifiers, and UCPD overlap. - [Green Claims penalties and fines under the EU proposal](/artifacts/eu/green-claims-directive/penalties-and-fines.md): source-linked summary of proposed Green Claims enforcement, corrective measures, penalty criteria, and the Council approach to maximum-fine language. - [Green Claims substantiation evidence pack](/artifacts/eu/green-claims-directive/substantiation-and-evidence-pack.md): Build a source-linked evidence pack for EU Green Claims: claim inventory, scientific substantiation, life-cycle impacts, PEF or OEF records, comparisons, labels, offsets, verification, and traceability. - [Green Claims verifier workflow for explicit environmental claims](/artifacts/eu/green-claims-directive/verifier-workflow.md): A concrete verifier-preparation workflow for voluntary explicit environmental claims: claim boundaries, substantiation evidence, verifier package, certificate handling, and change reviews. - [Greenwashing risk checklist for EU green claims](/artifacts/eu/green-claims-directive/greenwashing-risk-checklist.md): A concrete EU greenwashing checklist for marketing, product, legal, and sustainability teams reviewing vague claims, evidence gaps, offsets, labels, comparisons, and future targets. - [How do the UCPD, Directive (EU) 2024/825, and Green Claims proposal overlap?](/artifacts/eu/green-claims-directive/faq/ucpd-and-empowering-consumers-overlap.md): FAQ on how Directive (EU) 2024/825 changes UCPD greenwashing rules and how the Green Claims proposal would add substantiation, communication, labels, and verification detail. - [Microenterprise and Scope Exclusions in the EU Green Claims Proposal](/artifacts/eu/green-claims-directive/faq/microenterprise-and-scope-exclusions.md): FAQ on proposal-stage Green Claims scope: microenterprise treatment, voluntary B2C explicit environmental claims, B2B limits, and EU-rule exclusions. - [PEF and OEF evidence for EU green claims](/artifacts/eu/green-claims-directive/pef-and-oef-evidence.md): How Product and Organisation Environmental Footprint studies can support EU green-claim substantiation without treating PEF or OEF as mandatory for every claim. - [Verifier workflow under the EU Green Claims Directive](/artifacts/eu/green-claims-directive/faq/verifier-workflow.md): FAQ on the proposed EU Green Claims verifier workflow: substantiation, ex-ante verification, verifier requirements, certificates, and proposal-stage caveats. - [What Counts as a Green Claim Under the EU Green Claims Proposal](/artifacts/eu/green-claims-directive/what-counts-as-a-green-claim.md): source-linked scope guide to explicit environmental claims under the EU Green Claims proposal and related Directive (EU) 2024/825 concepts. *Recommended next step* *Placement: after evidence section* ## Turn Green Claims guidance into an evidence workflow Use this Green Claims guide to separate product, service, and trader claims before teams approve public environmental wording or evidence summaries. - [Open Research Copilot](/solutions/research-copilot.md): Check Green Claims source text before approving environmental claim wording. - [Discuss Green Claims implementation](/contact.md): Review claim boundaries, substantiation scope, and consumer-facing communication with Sorena. --- [Privacy Policy](https://www.sorena.io/privacy) | [Terms of Use](https://www.sorena.io/terms-of-use) | [DMCA](https://www.sorena.io/dmca) | [About Us](https://www.sorena.io/about-us) (c) 2026 Sorena AB (559573-7338). All rights reserved. Source: https://www.sorena.io/artifacts/eu/green-claims-directive/faq/product-vs-company-claims