EU Green Claims Directive Green Claims Substantiation Template

Start the record with the exact claim that will be shown to consumers. The proposal and Council text both require the substantiation assessment to specify whether the claim concerns a whole product, part of a product, a product aspect, all trader activities, or a defined part or aspect of those activities.

Do not use this field for broad green marketing slogans. If the wording says or implies an environmental benefit, the record should name the specific environmental aspect, impact, or performance being claimed and the product, service, process, trader, activity, market, and medium where the claim will appear.

The substantiation record should separate primary information, secondary information, and the method used to turn evidence into the public claim. For product and trader claims, the proposal requires accurate information, widely recognised scientific evidence, relevant international standards, and consideration of relevant life-cycle impacts.

When a PEF, OEF, PEFCR, OEFSR, LCA, ecolabel criterion, Union product rule, or other recognised method is used, record why that method fits the claim. If the claim concerns only a specific aspect such as recycled content, reparability, durability, or a single life-cycle stage, record why a broader footprint method is or is not necessary for that claim.

Comparative claims need their own substantiation block because the proposal requires equivalent data, equivalent sourcing, equivalent value-chain coverage, equivalent environmental coverage, and equivalent assumptions for the products or traders being compared. The Council text also calls for the substantiation summary to include the data, methodology, comparability justification, and baseline year.

Climate-related claims need a separate carbon-credit block. Product claims that present a neutral, reduced, or positive greenhouse gas impact based on offsets are treated differently from trader-level climate claims. Where carbon credits are involved, the record should separate gross emissions, reductions, removals, credits, time period, scheme, registry, and whether the public wording is a contribution claim or an offset claim.

The record should distinguish current legal status from internal readiness status. The Green Claims Directive is a proposal in the ordinary legislative procedure. A 2026 Council document describes negotiations as at a standstill and says no agreement is expected in 2026, but that statement is not a formal withdrawal or final act. Do not enter final-law dates, official forms, verifier appointments, or certificate routes that do not exist.

For public communication, keep a publication record that mirrors the information expected to be made available with the claim: covered environmental aspects or impacts, relevant standards, underlying studies or calculations, assumptions and limitations, certificate and verifier information where applicable, offset information where applicable, and a consumer-readable summary.

A complete template still fails if nobody owns the fields or the release decision. Assign each claim to a marketing owner for public wording, a product or operations owner for the claimed boundary, a technical or sustainability owner for source data and calculations, a legal or compliance owner for the governing-rule path, and a publication owner who can stop or withdraw every variant.

Use controlled states instead of a free-text approval note. A practical sequence is draft, evidence pending, technical review, legal and consumer-law review, verifier review where an applicable route requires it, approved with stated conditions, published, suspended, withdrawn, or superseded. Record the reason, decision-maker, date, affected channels, and successor version each time the state changes.