EU Green Claims Directive Verifier workflow

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.