EU Green Claims Directive and Green Transition Rules Templates

Create one record for each explicit environmental claim before it appears on packaging, product pages, advertising, sales collateral, or a sustainability-label explanation. The record should prove that the public wording is no broader than the assessment behind it.

The proposed Green Claims rules require substantiation to rely on recognised scientific evidence, identify significant impacts from a life-cycle perspective, say whether the claim covers the whole product or only part of it, avoid presenting legal minimums as distinctive benefits, identify trade-offs, and use accurate primary or secondary information.

Use a separate verifier pack when the claim or label is intended for an external verification route. Keep it narrower than the internal evidence folder: the verifier should be able to see the claim, the assessment, the evidence trail, and the proposed consumer communication without hunting through unrelated sustainability files.

The Council text provides that verification takes place before the explicit environmental claim is made public or the environmental label is made available, that a certificate of conformity is issued where compliance is demonstrated, and that competent authorities recognise that certificate across the Union. Separately, it requires the trader or labelling-scheme owner to review and, where necessary, update the substantiation of the claim or label at least every five years; this is a review obligation, not a fixed maximum certificate validity period. It also states that the certificate does not prevent national authorities or courts from assessing the claim under Directive 2005/29/EC.

Keep the evidence inventory separate from the claim approval log. The inventory should show what each item proves, the data quality, and whether the evidence is primary company-specific data, representative secondary data, a recognised method, a public certification criterion, or a legal status item.

For environmental-footprint work, the JRC describes PEF and OEF as life-cycle assessment based methods for measuring and communicating potential life-cycle environmental impacts. Use those methods where they fit the claim, but do not imply that every claim requires a full life-cycle assessment.

Use this template whenever a sustainability label, certification mark, score, or ecolabel appears next to a product or trader claim. The first question is not whether the label looks credible; it is whether the label is established by a public authority or based on a certification scheme with transparent terms and third-party monitoring.

Directive (EU) 2024/825 prohibits displaying a sustainability label that is not based on a certification scheme or established by public authorities. The Green Claims proposal adds environmental-label scheme requirements on transparency, objectives, joining conditions, expert and stakeholder consultation, complaints, approval routes for new schemes, and verification.

Comparative environmental claims need their own record because the risk often sits in the comparator, not the headline. The template should force the team to name what is compared, whether the products or traders serve the same function, the method and assumptions, and how the information will stay current.

The Green Claims proposal explains that comparative claims should use equivalent information, equivalent data generation or sourcing, equivalent coverage of value-chain stages and impacts, consistent assumptions, and for improvement claims against an earlier product, evidence that the improvement is significant and tied to a baseline year.

Run this status check before releasing broad environmental language. The goal is to classify the wording as specific and supportable, generic but backed by recognised excellent environmental performance, comparative, future-performance, label-based, or offset-based.

Directive (EU) 2024/825 is already adopted and adds concrete greenwashing rules to the UCPD framework. Treat its prohibited-practice items separately from the proposed Green Claims verification mechanics so teams do not imply that proposal-stage procedures are already enacted.