EU Green Claims: Product vs Company Claims EU Green Claims: Product vs Company Claims

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.

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 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.

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.

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.

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.

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