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Green ClaimsTemplateEU

EU Green Claims Directive Green Claims Substantiation Template

A substantiation record template for explicit environmental claims: wording, boundary, environmental aspect, evidence, method, comparison, carbon-credit treatment, verification, and publication history.

Use it before a claim is generated in EU business-to-consumer marketing, packaging, web copy, labels, or equivalent public communications.

Back to main artifactReview sources
Author
Sorena AI
Published
May 9, 2026
Updated
Jul 25, 2026
5 sections6 primary sources
Overview

Use this internal template to keep a voluntary explicit environmental claim tied to its product or trader boundary, environmental aspect or impact, , other evidence, method, and consumer explanation. It is not an official EU form. The Green Claims file remains a proposal: a 2026 Council document says negotiations are at a standstill and no agreement is expected in 2026, and no final verifier route, certificate form, or application date is established.

Section 1

Claim record fields

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.

  • Claim text: quote the exact words, symbols, label text, score, comparison, future-performance wording, or climate-related statement that consumers will see.
  • Claim generator: name the trader that first introduces the explicit environmental claim in EU business-to-consumer commercial practice, not only the retailer that repeats it unchanged.
  • Subject boundary: choose one and describe it precisely: whole product, component, packaging, process, use phase, end-of-life, whole trader, business unit, site, value chain activity, or environmental label criterion.
  • Environmental characteristic: identify the claimed environmental aspect, environmental impact, or environmental performance, and state whether the claim is product-level, trader-level, label-related, comparative, climate-related, or future-performance related.
  • Legal-baseline check: state why the claim goes beyond requirements already imposed by law for the product group or sector.
Section 2

Evidence and method fields

The substantiation record should separate , 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 Product Environmental Footprint (PEF), Organisation Environmental Footprint (OEF), life-cycle assessment (LCA), ecolabel criterion, Union product rule, or other recognised method is used, record why that method fits the claim. Product Environmental Footprint Category Rules (PEFCRs) and Organisation Environmental Footprint Sector Rules (OEFSRs) specify the method for a product category or organisation sector. 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.

  • Evidence source: list each study, calculation, test report, supplier declaration, bill of materials, metering record, dataset, ecolabel certificate, PEF/OEF study, or legal method used.
  • : identify company-specific measured or collected data available to the trader for the environmental characteristic claimed.
  • Secondary information: identify representative literature, engineering studies, patents, databases, or other sources used where is not available.
  • Method: name the assessment method, standard, PEFCR, OEFSR, LCA boundary, lab test protocol, calculation rule, or sector/product rule used, and capture assumptions, limitations, cut-offs, allocation rules, and data quality checks.
  • Significance and trade-offs: state why the claimed aspect or impact is significant from a life-cycle perspective and whether the claimed improvement creates significant harm or transfers negative impacts elsewhere.
  • PEF/OEF relevance: for product footprint claims, record whether PEF or an applicable PEFCR was used; for trader or organisation footprint claims, record whether OEF or an applicable OEFSR was used; if not used, explain why the method is not suited to the claim.
Recommended next step

Turn green-claim wording into a substantiation record

This template helps connect each explicit environmental claim to its boundary, evidence, method, comparison, carbon-credit treatment, verification status, and publication record before it appears in consumer-facing materials.

Research workflow
Open Research Copilot

Check claim wording, evidence gaps, and Green Claims source support with cited source material.

Explore next step
Talk to Sorena
Discuss claim substantiation

Review claim boundaries, evidence records, PEF/OEF fit, comparison files, and publication summaries with Sorena.

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Section 3

Comparative and climate-claim fields

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.

  • Comparative basis: name the comparator product or trader, explain why it is comparable, identify the relevant market, and state whether the comparator is still sold or active.
  • Equivalent comparison file: keep matched data sources, generation method, value-chain stages, environmental impacts/aspects/performance covered, assumptions, and any baseline year.
  • Improvement claim: if the comparison is against an earlier product from the same trader or a product no longer sold, record why the improvement is significant and recent, and what other relevant environmental effects changed.
  • Climate-claim type: classify as actual life-cycle impact claim, future-performance claim, contribution claim, offset claim, or other trader-level greenhouse gas claim.
  • Carbon-credit treatment: record gross emissions separately from reductions, removals, and credits; identify quantity in tCO2e, time period, credit scheme, registry, certification or verification route, permanence where relevant, and the percentage of emissions balanced out if the claim is an offset claim.
  • Product-offset stop point: do not use this template to approve product-level carbon neutral or reduced-impact wording when the claimed product impact depends on greenhouse gas offsets outside the product life cycle.
Section 4

Verification, status, and publication record

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.

  • Legislative status field: proposal, Parliament position, Council general approach, national transposition rule, delegated act, implementing act, or other cited status; do not fill with guessed final-law dates.
  • Verifier field: verifier name, accreditation or environmental-verifier basis, conflict-of-interest statement, scope reviewed, date of verification, limitations, and certificate of conformity only if a certificate exists or is required by the applicable text.
  • Certificate field: certificate identifier, issuing verifier, issue date, maximum validity or review deadline where supported by cited sources, Internal Market Information System (IMI) or public-interface status where applicable, withdrawal or update record, and whether national authorities or courts may still assess the claim under UCPD rules.
  • Publication channel: packaging, label, web page, QR code, advertisement, point-of-sale material, marketplace listing, or other consumer-facing medium.
  • Consumer summary: plain-language scope, method, main result, limitations, use-phase instructions where relevant, and link or QR target for the detailed substantiation record.
  • Review trigger: new evidence, product or supplier change, method update, verifier finding, authority challenge, changed comparator, changed carbon-credit status, or the maximum review period stated by the applicable Green Claims text.
Section 5

Record ownership, decisions, and change control

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.

  • Responsible owner: the person who maintains the field and supplies updates.
  • Accountable approver: the person who accepts the boundary, evidence limits, public wording, and release outcome.
  • Decision outcome: approve, approve with wording or placement conditions, hold for named evidence, route to another Union rule, or reject.
  • Version link: connect the approved claim text to each translation, artwork file, webpage, marketplace feed, label, QR destination, and substantiation summary.
  • Reassessment record: state the earliest data-expiry date and every event trigger, including supplier, composition, method, comparator, target, credit, certificate, legal-rule, complaint, or authority change.
  • Closure record: identify who removed the claim, where it was removed, whether consumers or customers need correction, and which evidence remains retained.
Primary sources

References and citations

Council general approach on the Green Claims Directive
data.consilium.europa.eu6 citations
Referenced sections
  • Used for Council-position fields covering claim generation, environmental characteristics, climate contribution and offset claims, PEF/OEF incorporation, comparative substantiation summary, review, verification, certificate, and verifier status.
  • Supports template fields for the trader generating an explicit environmental claim, claim boundary, environmental characteristic, and verification definitions.
  • Supports the Council text recommending incorporation of EU Environmental Footprint methods, including PEFCRs and OEFSRs, where suitable for the claim.
Show 3 more
  • Supports contribution-claim and offset-claim classification, trader climate-claim assessment fields, and Council wording on product offset claims.
  • Supports verification, certificate-of-conformity, maximum certificate validity, review, verifier, and IMI/public-interface status fields in the template.
  • Supports claim-generator responsibility, review triggers, updated substantiation, certificate status, competent-authority action, and corrective outcomes.
"Green Claims Directive"
More quoted passages
"explicit environmental claim"
"EU Environmental Footprint methods"
"contribution claim"
"certificate of conformity"
"circumstances that may affect the accuracy"
Proposal for a Directive on Green Claims (COM(2023) 166 final)
eur-lex.europa.eu6 citations
Referenced sections
  • Used for Commission-proposal fields covering claim boundary, scientific evidence, primary and secondary information, comparative claims, publication information, offsets, verification, and microenterprise caveats.
  • Supports the assessment fields requiring claim boundary, scientific evidence, significance from a life-cycle perspective, legal-baseline checks, primary information, and secondary information.
  • Supports evidence fields for scientific evidence, primary information, secondary information, life-cycle significance, and trade-off checks.
Show 3 more
  • Supports comparative-claim fields for equivalent information, equivalent sourcing, value-chain coverage, environmental coverage, assumptions, and baseline year.
  • Supports publication fields for information made available with the claim, including standards, studies, calculations, certificate, verifier contact information, offsets, and consumer summary.
  • Supports maintaining claim-level substantiation, communication, verification, correction, and monitoring records.
"substantiation and communication"
More quoted passages
"Substantiation of explicit environmental claims"
"widely recognised scientific evidence"
"comparative environmental claims"
"made available together with the claim"
"reviewed and updated by traders"
Compliance Criteria on Environmental Claims
commission.europa.eu3 citations
Referenced sections
  • Used for consumer-law claim quality fields: clear scope, specific wording, scientific evidence, life-cycle relevance, objective comparisons, and avoiding vague broad claims.
  • Supports the need for specific, accurate, unambiguous claim wording and clear scope and boundaries.
  • Supports comparison fields requiring objective, relevant, verifiable comparisons using the same methods and assumptions.
"Compliance Criteria"
More quoted passages
"specific, accurate and unambiguous"
"using the same methods"
Product Environmental Footprint method
eplca.jrc.ec.europa.eu3 citations
Referenced sections
  • Used for detailed PEF report and validation-statement fields such as goal and scope, system boundary, data collection, data quality, impact results, interpretation, verifier, and limitations.
  • Supports detailed PEF report fields for goal and scope, system boundary, data sources, data quality, impact results, interpretation, and validation statement.
  • Supports PEF validation-statement fields such as study version, commissioner, verifier, objective, result, limitations, issue date, and signature.
"Product Environmental Footprint Report"
More quoted passages
"PEF report template"
"validation statement"
Council draft amending budget No 2 to the 2026 general budget
data.consilium.europa.eu2 citations
Referenced sections
  • Current status evidence that negotiations are at a standstill and no agreement is expected in 2026; not evidence of formal withdrawal or adoption.
  • Supports the status field: negotiations are at a standstill and no agreement is expected in 2026, without establishing a formal withdrawal, final form, or operative verifier process.
Understanding Product Environmental Footprint and Organisation Environmental Footprint methods
publications.jrc.ec.europa.eu2 citations
Referenced sections
  • Used for PEF/OEF template fields distinguishing product and organisation footprint methods and their life-cycle assessment basis.
  • Supports the PEF/OEF distinction: PEF for products and OEF for organisations, both based on life-cycle assessment.
"Organisation Environmental Footprint"
More quoted passages
"Product Environmental Footprint"

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