How to Substantiate Environmental Claims Under ECGT

To substantiate an environmental claim under the EU Green Claims Directive (ECGT), you must demonstrate with verifiable evidence that the claim is accurate, scoped correctly, based on recognised scientific methodology, and — for most claim types — verified by an accredited third party before publication. This guide walks through exactly what that means in practice, with examples and a documentation framework you can implement immediately.

If you are not sure which of your current claims need substantiation, scan your website free to identify all environmental claims and their risk levels before reading further.

What "Substantiation" Means Under ECGT

The ECGT uses the term "substantiation" to mean more than just having data. Article 3 of the directive requires that environmental claims be based on:

1. Recognised scientific evidence — not internal estimates or marketing approximations
2. Comprehensive and up-to-date information — reflecting the current state of the product or company, not a historical snapshot
3. Consideration of the full lifecycle where relevant — meaning you cannot claim a product is "low carbon" based only on manufacturing if transport or disposal have significant impacts
4. Pre-existing documentation — evidence must exist before the claim is published, not compiled after a regulator asks

This is a significantly higher bar than most brands applied before 2024. See our guide on the EU Green Claims Directive for the full legislative context.

The 4 Pillars of Valid Substantiation

Pillar 1: Accurate Scope

The most common substantiation failure is scope mismatch — a claim implying a broader environmental benefit than the evidence actually supports.

Example of scope mismatch:
"Our products are carbon neutral" — when only the manufacturing process has been offset, not transport, retail, or end-of-life disposal.

Compliant version:
"Manufacturing of our products is carbon neutral — Scope 1 and 2 emissions offset through verified Gold Standard credits. Scope 3 emissions reduction plan in progress."

Scope must be explicitly stated on or directly linked from the claim. Hidden scope limitations — where the full scoping is buried in a sustainability report that most consumers will never read — do not satisfy ECGT requirements.

Pillar 2: Recognised Methodology

ECGT requires that claims be based on recognised scientific methodology. For the most common claim types, the relevant standards are:

Claim Type	Required / Recommended Standard
Carbon footprint / lifecycle emissions	ISO 14040 / ISO 14044 (Life Cycle Assessment); GHG Protocol Product Standard
Carbon / climate neutrality	PAS 2060 (if retained) + SBTi-aligned reduction plan; note that pure offset claims are now banned
Recyclability	ISO 14021; EN 13430; Plastics Europe recyclability assessment
Biodegradability / compostability	EN 13432 (packaging), EN 14995 (plastics), ISO 14855
Recycled content percentage	ISO 14021; verified supply chain documentation
Energy efficiency	EU Energy Label regulation; ISO 50001
Water use	ISO 14046 (water footprint)
Chemical / hazardous substance absence	REACH regulation test reports; third-party lab analysis

Pillar 3: Third-Party Verification

For most environmental claims, ECGT requires pre-publication verification by a conformity assessment body accredited under Regulation (EC) No 765/2008. This is not just any external consultant — it must be a formally accredited body.

Third-party verification is most critical for:

• Comparative claims ("30% lower emissions than the industry average")
• Claims about offset-based neutrality
• Claims on sustainability labels or icons displayed to consumers
• Claims made in B2C advertising with broad reach

For smaller brands and specific claim types, self-declaration with robust documentary evidence may be acceptable — particularly for precise, verifiable facts like "contains 40% post-consumer recycled aluminium". See our sustainability certification comparison for a list of recognised third-party bodies.

Pillar 4: Documentation Package

Every substantiated claim should have an associated documentation package. This is not a document you publish — it is your internal file that you produce to regulators on request. ECGT requires it to be maintained and kept current.

A complete documentation package contains:

1. The claim text as it appears in marketing (screenshot or copy)
2. The publication locations (URLs, ad IDs, packaging version)
3. The methodology used to generate the underlying data
4. The raw data or study supporting the claim (LCA report, test certificate, supplier declaration)
5. The scope statement — what the claim covers and what it does not
6. Third-party verification report (where applicable)
7. Date of evidence and expiry/review date
8. Name and accreditation number of the verifier (where applicable)

Worked Examples

Example 1: Textile Brand — "Made from Recycled Materials"

Original claim: "Our hoodies are made from recycled materials."

Issues: No percentage stated; "recycled" type not specified (pre- or post-consumer?); no certification referenced.

Substantiation path:

1. Obtain supplier declaration stating exact percentage of recycled content by weight
2. Specify whether pre- or post-consumer recycled material
3. Certify through GRS (Global Recycled Standard) — requires supply chain traceability audit
4. Update claim to: "Made from 85% post-consumer recycled polyester — GRS certified [certification number]"

Example 2: Food Brand — "Sustainably Sourced Ingredients"

Original claim: "We use sustainably sourced ingredients."

Issues: "Sustainably sourced" is undefined; which ingredients? By what standard? Verified by whom?

Substantiation path:

1. Identify which specific ingredients are being claimed (palm oil, cocoa, coffee, etc.)
2. Obtain Rainforest Alliance, Fairtrade, or Organic certification for those ingredients
3. Update claim to: "Our cocoa is Rainforest Alliance certified — sourced from [country/cooperative]. Our palm oil is RSPO-certified (Mass Balance)."

Example 3: SaaS Company — "Carbon Neutral Operations"

Original claim: "Carbon neutral operations."

Issues: No scope stated; offset methodology unknown; no third-party verification; "carbon neutral" as standalone claim is now banned.

Substantiation path:

1. Commission GHG Protocol Corporate Standard inventory for Scope 1 + 2 emissions
2. Reduce where possible (server efficiency, renewable energy purchasing)
3. Offset remaining Scope 1+2 via Gold Standard or VCS credits — obtain retirement certificates
4. Have the calculation verified by an accredited body
5. Update claim to: "Our Scope 1 and 2 emissions are offset in full through Gold Standard credits [project name, registry ID]. Scope 3 reduction roadmap published at [link]." Remove "carbon neutral" language entirely.

What Happens If a Claim Cannot Be Substantiated?

Remove it. A claim that cannot be substantiated with the evidence required under ECGT is not just legally risky — it is legally non-compliant from the moment enforcement starts. The cost of removing a claim today is zero. The cost of defending it before a national consumer authority — with fines of up to 4% of turnover and mandatory corrective communication — is significant.

See our greenwashing penalties by country for current fine levels across EU member states.

Automate Claim Detection Before You Substantiate

Before you can substantiate claims, you need to know what claims you are making. GreenClaims Scanner crawls your entire website, identifies every environmental claim, and assigns a risk level based on ECGT criteria. Start there — free tier available — then use this guide for the substantiation process on your flagged claims.