Green Claims substantiation Evidence Pack

Start the file with the consumer-facing claim exactly as it appears and the medium where it will appear. The Council general approach says explicit environmental claims should be substantiated by the trader generating them, while environmental labels should be substantiated by the scheme owner. That distinction matters when a retailer repeats a producer claim, a marketplace adapts a claim, or a brand relies on a label.

Record whether the claim is product-level, trader-level, generic, specific, comparative, climate-related, future-performance, or label-based. Also record whether another Union act already sets specific rules for the claim, because the Green Claims proposal is framed for voluntary business-to-consumer explicit environmental claims and environmental labels not already covered by more specific Union rules. Mandatory disclosures, business-to-business material that never reaches consumers, and a regulated claim within the scope of a more specific Union rule need a different legal route.

Record enterprise size without assuming one draft's exemption will survive. The Commission proposal exempts microenterprises from specified substantiation, communication, and verification duties unless they request verification for an EU-recognised certificate. The Council general approach instead delays listed requirements for microenterprises until 50 months after entry into force. Neither position is final law.

The evidence file should show why the claim is scientifically supportable for the specific product, service, activity, or trader. The Council text says substantiation should be based on widely recognised scientific evidence, use recognised scientific approaches where relevant, consider the life-cycle, and not omit relevant environmental aspects or impacts.

When the claim concerns environmental performance across a product or organisation, add a life-cycle assessment record. If Product Environmental Footprint or Organisation Environmental Footprint methods fit the claim, include the PEF or OEF study reference, category or sector rules if used, data quality notes, and the list of relevant impact categories, life-cycle stages, processes, and limitations.

Comparative claims need a separate comparison file. The Council text warns that comparisons can mislead when indicators, formulas, direct and indirect impacts, or life-cycle stages differ. The pack should therefore preserve the baseline product or trader, the time period, the calculation formula, the same environmental aspects, and why the compared systems are comparable.

Labels and climate-related claims need their own dependency records. For a label, keep the scheme owner, criteria, certification evidence, governance, licence or approval, and the exact label use. For climate claims involving carbon credits, keep the product or trader emissions inventory separate from the credit record, and capture the share of emissions addressed, whether credits are reductions or removals, the verification and certification scheme, and the registry.

The pack should be usable before publication and after publication. The Commission proposal and Council text both include verification and certification concepts for claims and environmental labels before public use, while the Council text also discusses a Specific Technical Documentation route for certain less complex claims. Do not describe either route as a final operational deadline unless the enacted national rule and implementing act are confirmed.

Keep a traceability table that links every public sentence to evidence. A reviewer should be able to move from public claim, to source, to data, to method, to verifier or self-documentation record, to publication location, without asking who approved the wording or where the current evidence lives.

Before a claim goes live, reject the pack if it only says the product is sustainable without proving the precise environmental benefit. Reject it if the evidence supports a narrower claim than the public wording, if life-cycle exclusions are not justified, if a comparison uses different boundaries, or if a climate claim hides offsets inside the product footprint.

A complete pack is narrow, traceable, and current. It identifies the claim generator or label scheme owner, shows scientific evidence for the exact claim, covers relevant impacts and trade-offs, preserves PEF or OEF material where used, isolates comparison and offset dependencies, and stores verifier or documentation records with the live publication record.