TemplateEU

EU Green Claims Substantiation Template

A structured template that turns claim language into an evidence pack.

Outcome: reviewers can validate scope, methods, data quality, and disclosures fast.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Sections
6

Structured answer sets in this page tree.

Primary sources
2

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 21, 2026
Overview

The fastest way to lose a green claims challenge is a scattered substantiation file: some PDFs, a few spreadsheets, and no boundary statement. This template structures substantiation so it can be verified, repeated, and exported during audits and disputes.

Section 1

Section A - Claim card (the claim as an object)

Write the claim card first. Reviewers cannot validate evidence if they don't know what the claim means and where it appears.

Treat the claim card as versioned: each campaign variant should map to a claim version.

  • Claim text (all variants) + channels + intended audience.
  • Claim type: product vs company; absolute vs comparative; label-like claim; offset-based claim.
  • Scope: geography, timeframe, product variants/SKUs, functional unit.
Section 2

Section B - Boundary statement (life-cycle and exclusions)

Boundaries are where most greenwashing disputes happen. State what is included and excluded, and why.

If the claim is comparative, define baseline boundary and ensure comparability.

  • Life-cycle stages included (materials, production, transport, use, end-of-life).
  • Materiality: which impact categories are considered and why.
  • Exclusions: what is excluded, materiality justification, and residual risk.
Recommended next step

Keep EU Green Claims Substantiation Template in one governed evidence system

SSOT can take EU Green Claims Substantiation Template from reusing this material inside a governed evidence system to a reusable workflow inside Sorena. Teams working on EU Green Claims can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Section 3

Section C - Methodology and datasets (how results are produced)

Pick a method appropriate to the claim. For claims tied to life-cycle performance, PEF/OEF can provide a robust reference approach.

Document datasets, assumptions, and data quality requirements. 'We used industry averages' is not a method.

  • Method chosen (e.g., Environmental Footprint/PEF where relevant) + rationale.
  • Dataset inventory: primary vs secondary data; sources; representativeness; versioning.
  • Data quality: completeness, temporal/geographic relevance, uncertainty handling.
Section 4

Section D - Calculations and results (and how you avoid cherry-picking)

Provide calculation artifacts that can be replayed: spreadsheets with locked inputs, scripts, or model exports, plus a narrative summary.

Address trade-offs: improvements in one category can be offset by worsening in another.

  • Results summary with units, baselines, and comparators (if any).
  • Trade-off section: what improved, what worsened, and how you communicate that.
  • Sensitivity/uncertainty: key assumptions and their impact on outcomes.
Section 5

Section E - Disclosures (consumer-facing clarity)

A claim is not complete until you define what consumers must be told for the claim to be non-misleading.

Write disclosure text that can be reused across product pages and ads.

  • Plain-language boundary statement (one paragraph).
  • Comparative disclosures: baseline definition and comparability statement.
  • Offset disclosures (if used): reductions vs compensation and evidence references.
Section 6

Section F - Verification checklist + approval log

Verification is about repeatability and auditability. Create a checklist and log who reviewed what and when.

Store the final pack and approval record in a system with retention and access controls.

  • Verification checklist completed (methods, datasets, boundaries, trade-offs, disclosures).
  • Approval log: reviewer roles, timestamps, decision outcomes, and follow-up tasks.
  • Retention: evidence pack location, version history, and access rules.
Primary sources

References and citations

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