Green Claims Compliance Checklist: Audit Your Environmental Marketing for the EU
If your marketing for the EU market says 'sustainable', 'eco-friendly', 'recyclable' or 'climate neutral', each of those words is now a legal statement that must be provable. The EU's green-claims framework bans generic environmental claims without recognized substantiation and outlaws unverified sustainability labels, while German unfair-competition law already lets competitors and associations attack misleading green advertising today.
International companies are especially exposed because claims are often written by a global marketing team with no view of EU specifics, then translated for the German shop. The fix is a systematic audit: know every claim you make, decide for each whether you can prove it to EU standards, and rewrite or remove the rest. The checklist below walks through that audit.
Your checklist
- 1Inventory every environmental claim: crawl websites, packaging, ads, social media and sales decks for terms like 'green', 'eco', 'sustainable', 'climate neutral', 'recyclable' and 'biodegradable' in all EU languages you use.
- 2Classify each claim: separate generic claims (highest risk), specific product claims, comparative claims and future commitments such as net-zero targets.
- 3Check substantiation: for each claim, confirm you hold current, recognized scientific or certification-based evidence covering the whole claim as the consumer understands it.
- 4Remove or rewrite unprovable claims: replace generic slogans with specific, verifiable statements ('packaging made from 80% recycled PET') and delete the rest.
- 5Review offset-based 'climate neutral' claims: treat neutrality claims relying on carbon offsetting as high risk and phase them out or clearly restructure them.
- 6Audit labels and logos: drop self-created sustainability seals and keep only certification labels from recognized, third-party-verified schemes.
- 7Make evidence accessible: link claims to their substantiation (e.g., via product pages or QR codes) so verification is straightforward.
- 8Install a claims-approval workflow: require legal or compliance sign-off before any new environmental claim goes live in EU markets.
- 9Re-audit regularly: recheck claims when products, supply chains or certifications change — substantiation must stay current.
Matching tool
Make your environmental claims litigation-proof.
Green Claims Scanner → Check now for freeFrequently asked questions
Which environmental claims are considered 'generic' and banned?
Claims like 'environmentally friendly', 'eco', 'green', 'natural' or 'climate friendly' used without recognized substantiation directly connected to the claim. The stricter the claim sounds, the more complete the proof must be — and if the evidence covers only part of the product or lifecycle, the claim must say so.
Can we still use our own sustainability logo on packaging?
Self-created sustainability labels that are not based on a certification scheme verified by an independent third party are being prohibited for the EU market. Only recognized, verified labeling schemes remain permissible, so proprietary green seals should be retired or converted to certified schemes.
How should we handle claims written by our global marketing team?
Treat the EU as its own compliance zone. Establish that no environmental claim reaches EU-facing channels without a substantiation check against EU and German standards, even if the claim is lawful in your home market. Claims that survive US puffery standards routinely fail German misleading-advertising tests.