Environmental claims audit

The audit examines every environmental claim the operator makes on the label, the packaging, the website or in advertising, including those conveyed through images, colours, labels or brand and product names, which fall within the Directive's definition. It checks each claim against the criteria that Directive (EU) 2024/825 inserts into Directive 2005/29/EC on unfair commercial practices: the prohibition of generic environmental claims where recognised excellent environmental performance relevant to the claim cannot be demonstrated; of claims that attribute to the entire product or the whole business what concerns only one aspect of the product or a specific activity; of claims, based on greenhouse gas emissions offsetting, that a product has a neutral, reduced or positive impact on the environment; of sustainability labels not based on a certification scheme or established by public authorities; and of presenting as a distinctive feature of the offer what the law requires of all products in the category. Claims about future environmental performance are checked against the requirement of clear, objective, publicly available and verifiable commitments, set out in a detailed and realistic implementation plan regularly verified by an independent third-party expert. For a food, the analysis also coordinates these prohibitions with terms reserved by sectoral legislation, such as those relating to organic production under Regulation (EU) 2018/848.

The analysis does not stop at the Directive. When it relates to the food, an environmental claim is voluntary food information: Article 36 of Regulation (EU) No 1169/2011 subjects it to the fair information practices of Article 7, which paragraph 4 extends to advertising and presentation, and requires it not to be ambiguous or confusing and to be based, where appropriate, on the relevant scientific data. These requirements already apply, whatever the state of transposition of the Directive in a given Member State, and the interplay between the two regimes is part of the analysis, since Directive 2005/29/EC gives way to sectoral Union rules in the event of conflict (Article 3(4)). The result is a report with an assessment of each claim, its basis and, where appropriate, the rewording that would make it compliant or a recommendation to withdraw it.

It does not include calculating the environmental footprint or the life-cycle assessment of the product, which require specific technical studies; the report can, however, assess whether the technical documentation provided by the operator is sufficient to substantiate the claim. Nor does it include verifying the implementation plan required for claims about future environmental performance, which falls to an independent third-party expert — a role incompatible with advising the operator itself — or obtaining certifications or sustainability labels.

Directive (EU) 2024/825 of the European Parliament and of the Council of 28 February 2024 amending Directives 2005/29/EC and 2011/83/EU as regards empowering consumers for the green transition through better protection against unfair practices and through better information, and the national transposing measures. Regulation (EU) No 1169/2011, in particular Articles 7 and 36. Regulation (EU) 2018/848 on organic production and labelling of organic products, as regards reserved terms. Directive (EU) 2024/825 should not be confused with the proposal for a Directive on substantiation and communication of explicit environmental claims (COM(2023) 166), known as the Green Claims Directive, which has not been adopted: the criteria applied in this audit are law in force.

Through the quote form, the company provides the claims in their real context (label, packaging, advertising, screenshots of the website) and the documentation on which they rely. The analysis is carried out and the report is delivered with an individual assessment of each claim within the agreed timeframe.

If the doubt concerns nutrition or health claims rather than environmental claims, the right service is the nutrition and health claims review. If it is a complete campaign, in which visuals and channel weigh as much as the text, it is the food advertising review.