Enforcement is coming. If your business makes any environmental claims in the EU market, you need a compliance plan. Not next year — now.
Here's a practical checklist. No theory, just what you need to do.
Phase 1: Audit (Weeks 1-2)
Step 1: Inventory All Environmental Claims
Go through every channel where your brand communicates:
- Website (every page, not just the sustainability section)
- Product packaging and labels
- Advertising (digital, print, TV, social media)
- Sales materials and pitch decks
- Press releases and blog posts
- Social media posts
Create a spreadsheet: claim text, where it appears, who approved it, and what evidence exists.
Shortcut: Run your website through our Greenwashing Scanner to automatically identify environmental claims on your site.
Step 2: Classify Each Claim
For each claim, determine:
- Explicit vs. implicit: Does it directly state something ("50% recycled") or imply it (green leaf logo)?
- Scope: Does it apply to the product, packaging, a process, or the whole company?
- Type: Absolute ("zero waste"), comparative ("greener than X"), or aspirational ("committed to sustainability")?
Step 3: Rate Risk Level
- High risk: Vague claims without evidence, offset-based neutrality claims, self-created eco-labels
- Medium risk: Specific claims with partial evidence, claims needing updated data
- Low risk: Certified claims from recognized bodies, specific measurable statements with documentation
Phase 2: Substantiation (Weeks 3-8)
Step 4: Gather Evidence for Each Claim
For every claim you want to keep, assemble:
- Scientific data or lifecycle assessment (LCA) results
- Third-party test results or certifications
- Supply chain documentation
- Methodology description
Step 5: Check Lifecycle Coverage
The directive requires that claims consider the full product lifecycle. Verify that your evidence covers:
- Raw material extraction
- Manufacturing and processing
- Transportation and distribution
- Use phase
- End-of-life (recycling, disposal)
If your claim only covers one stage, either narrow the claim's wording or expand the evidence.
Step 6: Eliminate Offset-Only Claims
Review any claim based on carbon offsetting. Under the directive, you must show real emission reductions first. Offsets can only supplement, not replace, actual reduction efforts.
Step 7: Replace Vague Language
Transform vague claims into specific ones:
- "Eco-friendly" → "Made with 60% post-consumer recycled content"
- "Sustainable packaging" → "Packaging certified compostable per EN 13432"
- "Green product" → "Manufactured using 100% renewable electricity"
- "Carbon neutral" → "35% emission reduction since 2020, with residual emissions addressed through verified removal credits"
Phase 3: Verification (Weeks 9-12)
Step 8: Identify Accredited Verifiers
The directive requires independent, third-party verification. Research accredited bodies in your industry and market. Budget accordingly — verification isn't free.
Step 9: Prepare Substantiation Files
For each claim, create a documentation package that a verifier can review. Include all evidence, methodology, and scope definitions.
Step 10: Submit for Verification
Engage your chosen verifier. Allow 4-8 weeks for the process, longer for complex claims or if issues are found.
Phase 4: Implementation (Weeks 13-16)
Step 11: Update All Materials
Once claims are verified, update every channel systematically. Don't forget:
- Older blog posts and press releases
- Packaging in production pipeline
- Third-party retailer listings
- Employee training materials
Step 12: Set Up Ongoing Monitoring
Compliance isn't a one-time project. Establish:
- A review process for all new environmental claims before publication
- Annual re-verification of existing claims
- Monitoring for regulatory updates
- Training for marketing and communications teams
Don't Panic, But Don't Delay
The directive is complex but manageable if you start now. Companies that prepare early will have a genuine competitive advantage — they'll be the ones consumers trust.
Start with Step 1: scan your website for free and see where you stand.