Green ClaimsSide-by-sideEU

Product and company environmental claims Match each claim to its evidence

Separate claims about a product or service from claims about the trader, organisation, activity, or value chain behind it.

Apply the national consumer rules implementing Directive (EU) 2024/825 from 27 September 2026. Use the Green Claims proposal as a voluntary model for evidence scope and verification records.

Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
Overview

Classify each by the consumer takeaway. A product claim says something about a product, service, package, component, use phase, or disposal route; a company claim says something about the trader, brand, operations, activity, portfolio, target, or value chain. Directive (EU) 2024/825 prohibits presenting a whole product or business as environmentally better when the claimed benefit concerns only one aspect or activity. The Green Claims proposal offers a useful evidence-boundary model, but it was not adopted and does not create a current verifier or certificate duty.

Comparison matrix

Product vs company environmental claims

Use the rows below to keep product/service claims separate from broad trader or organisation claims before publication, substantiation, verification, or evidence reuse.

Review all sources
First framework
Product or service claim

Covers an environmental impact, aspect, or performance statement about a named product or service, such as packaging, recycled content, use-phase performance, repairability, or lifecycle emissions.

Second framework
Company or trader claim

Covers an environmental statement about the trader, organisation, activity, operations, value chain, brand, company name, or portfolio-level environmental performance.

Claim boundary

Product or service claim

Name the exact product or service, variant, market, lifecycle stage, component, packaging element, or environmental aspect covered by the claim. A product claim should not imply whole-company performance unless that broader statement is separately substantiated.

Company or trader claim

Name the trader, organisation, activity, operations, value chain, facility set, portfolio, or company-name statement covered by the claim. A company claim should not imply that every product has the same environmental performance unless product-level evidence supports that message.

Operational implication

Draft the wording so a consumer can tell whether the claim concerns one product or service, the whole organisation, or a narrower activity. From 27 September 2026, national measures implementing Directive (EU) 2024/825 must prohibit whole-product or whole-business claims when the benefit covers only a particular aspect or activity.

Who generates and holds the claim

Product or service claim

The product owner, packaging owner, service owner, marketing approver, and legal reviewer need evidence for the product facts they control or communicate. Retailers repeating a producer claim should preserve the producer substantiation and avoid changing the meaning.

Company or trader claim

The sustainability, operations, finance, procurement, and corporate communications owners need evidence for the organisational boundary, own operations, value-chain data, and any company-level target or performance statement.

Operational implication

Assign accountability to the team that can change the product data or company data behind the claim, not only to the team publishing the wording.

What triggers substantiation

Product or service claim

A trigger exists when voluntary consumer-facing wording states or implies a product or service has a positive impact, lower negative impact, no impact, improved impact, or a specific environmental characteristic.

Company or trader claim

A trigger exists when voluntary consumer-facing wording states or implies the trader, organisation, activity, or company name has a positive impact, lower negative impact, no impact, improved impact, or recognised environmental performance.

Operational implication

Treat labels, names, packaging text, websites, advertising, and oral or written commercial communications as claim surfaces when they create an environmental impression. The exact wording is not decisive if the overall presentation implies a broader product or company benefit.

Substantiation focus

Product or service claim

Substantiate the specific product or service characteristic being claimed with recognised scientific evidence, relevant lifecycle stages, primary data where available, representative secondary data where needed, and any trade-offs created by the claimed improvement.

Company or trader claim

Substantiate the organisational or activity-level characteristic being claimed with evidence that matches the trader boundary, overall activities, value-chain coverage, primary data availability, representative secondary data, and trade-offs across relevant operations.

Operational implication

Do not use a single environmental footprint, ecolabel, or supplier certificate as proof for a broader claim unless it covers the same subject, boundary, impact categories, assumptions, and communication wording.

Evidence scope

Product or service claim

Keep product bills of material, packaging composition, lifecycle or PEF studies where relevant, supplier data, test reports, calculation files, assumptions, data-quality notes, and verifier certificates tied to the exact product or service claim.

Company or trader claim

Keep organisation-boundary records, OEF or other lifecycle studies where relevant, emissions and activity data, procurement or value-chain inputs, target evidence, assumptions, data-quality notes, and verifier certificates tied to the exact company claim.

Operational implication

The evidence pack should expose scope, limitations, underlying studies or calculations, standards used, verifier details where applicable, and the environmental aspects or impacts covered by the claim.

When evidence must be ready and refreshed

Product or service claim

For a product or service claim, prepare substantiation before the claim is communicated and refresh it when formulation, supplier data, lifecycle assumptions, use instructions, or product performance facts change.

Company or trader claim

For a company claim, prepare substantiation before the claim is communicated and refresh it when organisational boundaries, operations, value-chain data, targets, offsets, or reporting assumptions change.

Operational implication

Avoid treating the proposal as a final adopted timetable; the practical control is to keep claim evidence current before publication and whenever facts affect accuracy.

Verification and enforcement exposure

Product or service claim

A product claim is high risk when a benefit concerning only one characteristic, component, or lifecycle stage is presented as a benefit of the whole product. Directive (EU) 2024/825 adds that whole-product overstatement to the UCPD blacklist.

Company or trader claim

A company claim is high risk when a benefit concerning only one activity is presented as a benefit of the entire business. Under the adopted directive, a future environmental performance claim may be misleading if it lacks clear, objective, publicly available and verifiable commitments in a detailed and realistic implementation plan with measurable and time-bound targets, allocated resources, and regular independent third-party verification whose findings are available to consumers.

Operational implication

Screen the overall consumer impression under adopted law before using the Green Claims proposal's evidence and verification model. Strong evidence for one aspect does not make an overbroad whole-product or whole-business claim permissible.

Overlap and reuse

Product or service claim

Product evidence can support a company claim only for the product, activity, or value-chain slice it actually covers. It should not be scaled to a company-wide claim without matching organisational evidence.

Company or trader claim

Company evidence can support a product claim only when it proves the product-specific environmental aspect or impact. General corporate performance does not prove a claim printed on one product or service page.

Operational implication

Reuse data through a crosswalk that maps each public sentence to the subject of the claim, covered impacts or aspects, lifecycle or organisational boundary, and source evidence.

Plain-language rule

Product or service claim

Use product-claim controls when the consumer takeaway is about what a product or service is made of, how it performs, how it is used, how it is disposed of, or how its lifecycle impact compares.

Company or trader claim

Use company-claim controls when the consumer takeaway is about the trader, brand, organisation, operations, value chain, portfolio, corporate target, or company-wide environmental performance.

Operational implication

When the wording creates both takeaways, approve it only after both evidence files support the exact message and the communication makes the split clear.

Practical decision rule

How to classify the claim before publication

  • Use product-claim controls when the public message is about a named product, service, component, package, use phase, disposal route, or product lifecycle impact.
  • Use company-claim controls when the public message is about the trader, organisation, brand, operations, value chain, portfolio, target, or company-wide environmental performance.
  • When wording creates both impressions, keep both evidence files and qualify the communication so the product boundary and company boundary are visible.
  • Reject wording that presents one product aspect as a whole-product benefit or one company activity as a whole-business benefit, even when the narrower fact is supported.
Section 1

How to keep the two claim types separate

Start from the consumer takeaway, not the internal data source. If the takeaway is that one product, service, package, component, or lifecycle stage is greener, the evidence has to match that product boundary. If the takeaway is that the company, brand, activity, or value chain is greener, the evidence has to match that organisational boundary.

Broad claims can imply performance across products, sites, activities, or future conduct. Directive (EU) 2024/825 adds explicit UCPD prohibitions for whole-product and whole-business overstatement, while existing EU guidance calls for specific, accurate claims whose qualifications and evidence cover the impression created.

  • State whether the claim covers a product/service, the trader, or a specific company activity.
  • Identify the significant environmental aspects or impacts covered by the claim and any relevant trade-offs.
  • Keep product-level evidence and organisation-level evidence separate unless a cited crosswalk proves the same data supports both.
  • For voluntary preparation against the proposal, provide an accessible substantiation summary through a physical statement, link, QR code, or equivalent. A necessary same-medium specification for generic wording should not be hidden behind that link.
  • Classify concrete examples by their stated boundary: 'bottle made with 50% recycled plastic' concerns a component; '20% less use-phase electricity than our 2025 model' concerns a product comparison; 'our European offices use renewable electricity' concerns a defined activity; and 'we are a green company' creates a broad trader-level takeaway.
  • Reassess and, if necessary, narrow or withdraw the claim when product composition, supplier data, organisational boundaries, target assumptions, offsets, the public wording, or applicable law changes.
Recommended next step

Turn claim boundaries into an evidence pack

This comparison helps map each environmental claim to its subject, significant impacts, substantiation file, communication wording, and verifier-ready record.

Primary sources

References and citations

eur-lex.europa.eu3 citations
Referenced sections
  • Adopted source for the prohibition on presenting a benefit concerning one product aspect or business activity as a benefit of the whole product or business, and for future environmental-performance claim conditions.
  • Adopted source for the prohibition on presenting a benefit concerning one product aspect or business activity as a benefit of the whole product or business.
  • Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
commission.europa.eu
Referenced sections
  • Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
"whole product or organisation"
data.consilium.europa.eu
Referenced sections
  • Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
"product or trader concerned"
ec.europa.eu
Referenced sections
  • Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
"products, services, or organisation"
eur-lex.europa.eu
Referenced sections
  • Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
"products or traders"
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