| Scope boundary | The Green Claims Directive is still presented in the grounding material as a legislative proposal: the Commission proposed it on 22 March 2023, Parliament adopted a first-reading position on 12 March 2024, and the Council approved a general approach on 17 June 2024. | ISO 14021 is not shown in the grounding folder as EU legislation. It is cited as an International Organization for Standardization standard on environmental labels and declarations, self-declared environmental claims, and Type II environmental labelling. | Treat Green Claims as a proposed EU compliance track whose final text must be monitored, and treat ISO 14021 as supporting claim discipline only where your evidence file separately maps the ISO reference. |
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| Covered actors | The proposal applies to explicit environmental claims made by traders about products or traders in business-to-consumer commercial practices, and the Commission Q&A describes covered voluntary claims as claims about environmental impact, aspect, or performance of a product, service, or organisation. | The ISO comparator should be triggered only when the work concerns a self-declared environmental claim or Type II environmental label; the grounding folder does not support treating ISO 14021 as a substitute for the proposed EU scope test. | Start every review by naming the public claim, audience, product or trader boundary, and whether the claim is voluntary B2C communication. Then decide whether ISO 14021 evidence can supplement, not replace, the Green Claims analysis. |
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| Trigger | The proposal would require an assessment that specifies what the claim relates to, relies on widely recognised scientific evidence and accurate information, considers relevant international standards, evaluates significance from a life-cycle perspective, and separates any greenhouse-gas offsets from emissions information. | The ISO side is useful as a self-declared claim evidence check, especially where the Green Claims file needs specific, accurate, reviewed or verified environmental information; the grounding folder does not provide enough ISO text for a full clause-by-clause checklist. | For each claim, keep the study or calculation, product or trader boundary, life-cycle stages considered, primary and secondary data sources, offset treatment, assumptions, limitations, and the standard or method used. |
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| Core obligations | The proposal would require substantiation information to be made available together with the claim, using a physical form, weblink, QR code, or equivalent. It also calls for a clear consumer-facing summary and, where relevant, information on use-phase behaviour or climate-offset reliance. | For ISO 14021, this page can only support a conservative rule: self-declared claims should not be treated as mere marketing copy; they need understandable evidence that can be checked against the claim made. | Do not publish a claim unless the consumer-facing wording, substantiation link or QR code, claim boundary, and technical evidence tell the same story. |
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| Evidence record | The proposal treats environmental labels as explicit environmental claims when they communicate environmental performance. It would require labels to meet substantiation, communication, and verification rules, and would subject environmental labelling schemes to transparency, governance, complaint, and non-compliance procedures. | ISO 14021 is grounded here as Type II environmental labelling for self-declared claims. The folder does not support claiming that ISO 14021 creates the Green Claims proposal's third-party certification or labelling-scheme approval system. | Classify each logo, badge, score, or label before launch: EU-regulated label, private scheme, public scheme, or self-declared environmental claim. A self-declared label still needs evidence; it should not be described as independently certified unless that is true. |
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| Timing and deadlines | The proposal would require Member States to set up procedures for verifying substantiation and communication before the environmental claim is made public or the environmental label is displayed. The verifier would be an independent third-party conformity assessment body, and a certificate of conformity could be issued. | ISO 14021 is not grounded here as an ex-ante legal verification route. Use it as claim-content discipline unless a separate source-linked process confirms a different assurance route. | Keep the Green Claims verification record separate from any ISO-based self-declared claim review: verifier identity, accreditation basis, certificate, claim version, evidence version, and publication date should be traceable. |
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| Enforcement | For comparative environmental claims, the proposal would require equivalent information, equivalent data sourcing, equivalent value-chain coverage, equivalent impact coverage, and equivalent assumptions for the products or traders compared. | The grounding folder supports ISO 14021 only in a narrow recyclability example and as a self-declared claim standard. It does not support broad ISO comparison rules for this page. | When a claim says better, lower impact, more recyclable, carbon neutral, or similar, keep the baseline, method, stages, assumptions, and evidence for each compared product or trader in the same file. |
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| Overlap and reuse | The Commission Q&A states that microenterprises with fewer than 10 employees and less than EUR 2 million turnover are exempt from the proposal's obligations unless they wish to use the rules. The proposal also asks Member States to help SMEs apply the requirements. | The grounding folder does not support an ISO 14021 microenterprise exemption, so do not copy the Green Claims carve-out into the ISO workstream. | For Green Claims planning, record whether the trader is a microenterprise and whether it voluntarily seeks a certificate. For ISO review, keep the business-size analysis separate unless another source supports it. |
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| Practical decision rule | The Green Claims Directive is still presented in the grounding material as a legislative proposal: the Commission proposed it on 22 March 2023, Parliament adopted a first-reading position on 12 March 2024, and the Council approved a general approach on 17 June 2024. | ISO 14021 is not shown in the grounding folder as EU legislation. It is cited as an International Organization for Standardization standard on environmental labels and declarations, self-declared environmental claims, and Type II environmental labelling. | Treat Green Claims as a proposed EU compliance track whose final text must be monitored, and treat ISO 14021 as supporting claim discipline only where your evidence file separately maps the ISO reference. |
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