EvidenceEU

EU Green Claims Substantiation and Evidence Pack

Design evidence so it is provable, exportable, and repeatable.

Focus: evidence architecture, data quality, verification logs, and disclosures.

Author
Sorena AI
Published
Feb 21, 2026
Updated
Feb 21, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
2

Cited legal and guidance references.

Publication metadata
Sorena AI
Published Feb 21, 2026
Updated Feb 21, 2026
Overview

A green claims program fails when evidence is scattered and reviewers can't reconstruct what the claim means and how it was calculated. Build an evidence pack system that answers: what is the claim, what is the boundary, what method was used, what data supports it, what trade-offs exist, who verified it, and what did consumers see.

Section 1

Start with an evidence architecture (don't start with PDFs)

Define the evidence pack structure that you will export during disputes or regulator inquiries. Then map each section to an owner and a system-of-record.

Measure time-to-evidence: how quickly can you export a complete pack for a high-impact claim?

  • Evidence index: artifact -> owner -> system-of-record -> refresh cadence -> export format.
  • Claim cards as the front door: claim text, channels, classification, boundary, and links.
  • Version control: every claim and dataset must have a version and a date.
Recommended next step

Keep EU Green Claims Substantiation and Evidence Pack in one governed evidence system

SSOT can take EU Green Claims Substantiation and Evidence Pack from reusing this material inside a governed evidence system to a reusable workflow inside Sorena. Teams working on EU Green Claims can keep owners, evidence, and next steps aligned without copying this guide into separate documents.

Section 2

Boundary + methodology (make assumptions explicit)

Boundaries and assumptions are the main attack surface. If they are not explicit, consumers will assume the broadest interpretation.

For claims tied to lifecycle performance, reference methods like PEF/OEF can improve consistency (where appropriate).

  • Boundary statement: lifecycle stages, geographic scope, timeframe, variants/SKUs.
  • Method rationale: why this method fits the claim type and audience.
  • Trade-off handling: which impact categories were considered and why.
Section 3

Datasets and data quality (make reviewers confident)

'We used supplier data' is not a data quality story. Maintain a dataset inventory and quality criteria.

If you rely on secondary datasets or industry averages, document representativeness and uncertainty.

  • Dataset inventory: primary vs secondary, sources, versions, representativeness.
  • Quality gates: completeness, temporal/geographic relevance, uncertainty and sensitivity.
  • Reproducibility: calculations and models can be replayed.
Section 4

Verification records and approval logs (audit readiness)

Verification is an operational control: checklists, reviewer roles, and logged decisions.

Approval logs reduce chaos: you can explain who approved the claim and based on what evidence.

  • Verification checklist completed and stored with the pack.
  • Approval log: reviewers, timestamps, decisions, and required follow-ups.
  • Retention policy: how long evidence is stored and who can access it.
Section 5

Consumer-facing disclosures (what users must understand)

A claim without disclosure is often misleading even if calculations are correct.

Write disclosures as reusable components (one paragraph + a 'learn more' link) that match the evidence pack.

  • Plain-language boundary statement.
  • Comparative baseline and comparability statement (if comparative claim).
  • Offsets disclosure (if used): reductions vs compensation and evidence references.
Primary sources

References and citations

Related guides

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