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 readiness status. The Green Claims Directive is a proposal in the ordinary legislative procedure, so the template should not state final law dates or final forms that are not in force. Use status fields to say whether the public claim is draft, substantiation in progress, verifier review requested, certificate issued, withdrawn, expired, or not yet published.

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.