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.