Use this before 27 September 2026, when Directive (EU) 2024/825 takes effect with no transition period. It applies to material already published, not just new campaigns.
Work through it in order. Step 1 takes longer than people expect and determines whether the rest is accurate.
Step 1: Find every claim
Claims accumulate in places the marketing team no longer edits. Check all of these.
Owned digital
- Homepage, product pages, about and sustainability pages
- Blog archive, including posts from three or more years ago
- PDFs: brochures, spec sheets, whitepapers, annual reports
- Email footers and automated sequences
- Landing pages built for campaigns that have since ended
Product and packaging
- On-pack text, symbols, and self-designed badges
- Labels, inserts, and instruction manuals
- Point-of-sale material and shelf talkers
Third-party surfaces
- Retailer and marketplace listings, where copy is often years stale
- Distributor and reseller sites carrying your text
- Trade association profiles and directory entries
Sales and social
- Pitch decks and proposal boilerplate
- Tender responses and supplier questionnaire answers
- LinkedIn company page, executive profiles, trade show stands
Record each claim with where it appears and who can change it. That last column decides your timeline: a website edit takes an hour, a packaging change takes a print run.
Step 2: Classify each claim
Sort every claim into one of three buckets.
REMOVE: prohibited outright
- Any neutrality claim resting on offsetting: "carbon neutral", "climate neutral", "net zero product", "CO2-neutral" where compensation delivers it
- Generic terms with no demonstrated performance: "eco-friendly", "green", "sustainable", "environmentally responsible", "kind to the planet"
- Self-invented badges resembling certification
- Future commitments with no costed plan or independent verification
FIX: real performance, wrong wording
- Specific but unquantified: "made with recycled materials" -> state the percentage and what it covers
- Undefined scope: "recyclable" -> name the collection system
- Unclear boundary: "lower emissions" -> against what baseline, over what period, on what method
- Intensity presented as absolute reduction
KEEP: compliant as written
- Single-aspect claims with a figure, a method, and evidence on file
- Reduction claims with a stated baseline calculated consistently
- Third-party certified labels, described accurately for what they cover
Step 3: Find the evidence for everything you keep
A kept claim needs documentation someone else could reproduce. For each one, record:
- The figure and what it covers
- The method (ISO 14067, EN 15804+A2, GHG Protocol, and which version)
- The boundary (cradle-to-gate, cradle-to-grave, which scopes, which sites)
- The date and when it will next be recalculated
- The owner who can produce the underlying calculation
If any row is blank, the claim is not defensible. Either produce the evidence or move the claim to FIX.
Step 4: Deal with the targets
Forward-looking commitments are the most commonly missed item, because they read as ambition rather than as claims. Under the Directive they are claims, and each published target needs:
- A detailed implementation plan with allocated budget and resources
- Interim milestones, not only an end-state year
- Independent third-party verification
- Regular monitoring and public progress reporting
A "net zero by 2040" line on your website with none of that behind it is now a prohibited practice. Either build the backing or take the target down.
Step 5: Rewrite, then re-check the numbers
Rewriting is the quick part. The slow part is discovering that a claim you wanted to keep has no current calculation behind it, or that the baseline was calculated on a boundary you no longer use.
Two common blockers:
No product-level data. Claims about a product need product-level evidence. A corporate footprint does not substantiate a claim about one SKU. This needs an LCA or product carbon footprint.
A broken baseline. Reduction claims need the baseline year and the current year on the same method. If the footprint has been rebuilt in different tools over the years, the series may not be comparable. Rebuilding a consistent history is the work, and it is the reason ongoing measurement beats an annual one-off exercise.
Step 6: Set the review cadence
Claims decay. New products launch, suppliers change, factors update. Put a recurring review in the calendar, with a named owner, and treat the claim inventory as a live document rather than a September project.
Quick self-assessment
Count your NO answers.
- Can you list every environmental claim you currently publish?
- Does every claim have a figure behind it?
- Can you name the standard each figure was calculated to?
- For reduction claims, is the baseline on the same boundary as today?
- Is every published target backed by a costed, verified plan?
- Have you checked retailer and distributor listings for stale copy?
- Does anyone own claims review after September?
0-1 NO: You are in good shape. Verify and document. 2-4 NO: Normal starting position. The gaps are usually evidence, not intent. 5+ NO: Start with Step 1 this week. The inventory alone will take longer than the deadline comfortably allows.
Need the underlying numbers before you can rewrite anything? That is what a claim audit and footprint covers. Or read what the Directive prohibits and which claims survive.
Sources: Directive (EU) 2024/825.
