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.
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.
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.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
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
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
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
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
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
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
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
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
When the wording creates both takeaways, approve it only after both evidence files support the exact message and the communication makes the split clear.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
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
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
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
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
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
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
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
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Explains PEF and OEF as life-cycle methods for measuring potential environmental impacts of products and organisations respectively.
products (goods or services) and organisations, respectively
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Adopted EU source for environmental-claim definitions, whole-product and whole-business overstatement, generic claims, and future environmental-performance claims.
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
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
1
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.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
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.
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.
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.
Provides EU guidance that environmental claims should be specific, clear about whether they concern the whole product or organisation, and backed by robust evidence.
Shows Council text distinguishing product and trader claims, significant environmental characteristics, summaries for consumers, and updated substantiation duties.
Explains that covered voluntary green claims can concern products, services, or the organisation, and that substantiation should be verified before claims are used.
Defines explicit environmental claims and sets proposed substantiation, communication, comparison, and verification requirements for claims about products, services, or traders.