1
Register the claim
Record exact wording, visuals, product scope, channel and intended publication date.
Output: registered claim and versionBUVNK · GREEN CLAIMS · COMPLIANCE
BuVNK › Green Claims › Review & Compliance
Green Claims Compliance 2026: Review and Approval
How businesses can review environmental claims before publication, document supporting evidence and assign clear responsibilities – with a practical eight-step workflow.
8-step approval workflowEmpCo applies since 27 Sep 2026Green Claims Directive: proposal
Important distinction: National measures implementing the EmpCo Directive (EU) 2024/825 have applied since 27 September 2026. The separate Green Claims Directive remains a legislative proposal. It does not currently impose a general new pre-certification obligation for every environmental claim.
PRACTICAL GUIDANCE
An approval workflow helps prevent unsupported green claims
A statement may have supporting data yet still mislead through visuals, missing qualifications or an unsuitable comparison. Effective review therefore covers the entire communication – from initial draft and evidence to subsequent updates. The steps below are a suggested internal method, not a legally mandated uniform workflow.
PRACTICAL WORKFLOW
Eight steps to a reviewable environmental claim
A practical workflow for marketing, sustainability, product and legal teams. Roles may be combined in smaller businesses, but critical decisions should remain traceable.
2
Define the scope
Does the statement concern the full product, a packaging component, one site or a defined activity?
Output: documented scope3
Identify applicable law
Check EmpCo, national consumer protection rules and sector-specific requirements. Do not treat proposals as law.
Output: list of applicable rules4
Collect evidence
Gather measurements, supplier documents, calculations and methodology; check quality, recency and relevance.
Output: traceable evidence record5
Verify the substance
Check baseline, boundaries, comparison, qualifications, uncertainties and calculation integrity.
Output: technical review note6
Review the overall impression
Consider headline, design, images, labels, footnotes and audience as a whole; escalate sensitive claims.
Output: revised or approved draft7
Record the decision
Name the technical and legal reviewers; retain approval, conditions or rejection with dates.
Output: documented decision8
Monitor and update
Track changes in data, suppliers, legislation and product details; correct communications when needed.
Output: review date and version historyRECORD KEEPING
What belongs in a claims register?
A central record allows teams to retrieve wording, evidence and approvals. Specialised software is not necessary for every business.
| Field | Record to keep |
|---|---|
| Claim ID & version | Unique identifier, exact wording, language and visual version |
| Claim scope | Product, packaging component, site, market and channel |
| Evidence & method | Measurements, supplier files, calculations, baseline and boundaries |
| Review & decision | Technical checks, legal assessment, approver and date |
| Follow-up | Review date, change triggers, corrective actions and revision history |
ACCOUNTABILITY
Who should do what?
Illustrative division of responsibilities; these exact organisational roles are not a general statutory requirement.
Marketing & communications
Draft the statement and visuals; specify channel and intended audience.
Technical & sustainability
Verify scope, methods and supporting product or impact data.
Legal & compliance
Review the applicable rules, potential deception and high-risk claims.
Approval owner
Record whether the specific version may be published, must be revised or rejected.
HIGHER-RISK CLAIMS
Claims requiring particular attention
These topics deserve careful individual review. The list is not a substitute for legal advice.
Broad environmental promises
Terms such as “green” or “eco-friendly” without adequate specificity may fall under EmpCo restrictions on certain generic environmental claims.
Offset-based product climate neutrality
Certain claims that a product has a neutral, reduced or positive greenhouse-gas impact based on offsetting are expressly prohibited.
Sustainability labels
Check whether a label is based on an eligible certification scheme or established by public authorities.
One part presented as the whole
Do not imply an entire product or business improved if the evidence covers only one aspect.
Future environmental performance
Future goals require clear, verifiable commitments, a realistic implementation plan and appropriate independent monitoring.
Comparisons & percentages
Specify baseline, comparator, boundaries, data integrity and material qualifications.
APPROVAL
Three possible outcomes of internal review
A transparent decision prevents outdated or unapproved wording from being reused.
Approve
The exact wording and visuals have been reviewed and documented for their defined scope.
Revise
The evidence is incomplete or wording overreaches; return it to the relevant owner.
Do not publish
The claim is not factually or legally supportable for the intended use.
INTERACTIVE SELF-CHECK
Eight checks before publication
Internal guidance only; answers are not transmitted to BuVNK and do not constitute legal approval.
Checks completed: 0 / 8
FREQUENT QUESTIONS
Green Claims compliance: FAQ
Does every company need a dedicated compliance department?
No. Internal organisation should fit the size and risk profile of the business. A separate department is not universally mandatory.
Does every claim require external pre-certification?
No. The separate Green Claims legislative proposal does not currently create a blanket new pre-approval rule for all claims. Sustainability labels and product categories may be subject to their own specific requirements.
Can marketing review all claims alone?
Marketing can assess the intended message, but technical, environmental and legal matters should involve appropriately qualified reviewers.
Can we advertise carbon offsetting?
Investments in climate projects can be described accurately. However, EmpCo bans certain product claims of neutral, reduced or positive greenhouse-gas impact where this is based on offsetting.
How long must we retain evidence?
This page does not assert a single universal EmpCo retention period for every claim file. Other legal duties and business risks may apply; set proportionate retention periods.
What if supplier information changes?
Review the claim if material data change. If the evidence no longer supports it, the advertising should be changed or stopped.
Are company-created green badges acceptable?
Not automatically. Sustainability labels are subject to specific EmpCo requirements; an in-house marketing badge does not necessarily qualify.
Is a BuVNK checklist a certificate?
No. It is an editorial guidance tool and does not replace individual legal review or any applicable certification.
OFFICIAL SOURCES
EU legal sources and guidance
- Directive (EU) 2024/825 – EmpCo – Binding directive text, prohibitions and application date
- European Commission – sustainable consumption – September 2026 application and official questions and answers
- European Commission – Green Claims – Information on the separate legislative proposal
Last reviewed: 14 October 2026 · General information, not legal advice.
Support trustworthy environmental marketing with clear processes
Start with the checklist, collect evidence and record the internal approval decision.