Speeki GreenDesk™

The EmpCo green claims checklist

Which of your green claims would still stand on 27 September 2026?

Directive (EU) 2024/825, known as EmpCo, applies across the EU from 27 September 2026. It changes what an organisation is allowed to say about its products, and it is enforced through existing consumer and unfair competition law. Penalties are set by each member state and, for large-scale cross-border infringements, can reach at least 4% of the trader's annual turnover in the member states concerned. This checklist is for the EU market.

How to use it
Read part one. List your claims in the table in part two, one claim to a row, and answer each of the eight questions with a Yes, a No, N/A where the question does not apply, or a blank where you do not know. For every question, a yes means the claim is fine on that point and a no means it needs attention. Answer for the claim as it is published today and for the product as it is made and sold today, not as either is intended to be.

There is no score. What you are left with is a clear split: the claims that are not permitted as written, and the claims you cannot yet prove.
Part one

The eight questions

Questions 5 to 7 are not prohibitions under EmpCo. They are what determines whether you can produce the proof on the day someone asks for it. Questions 1 to 4 and 8 trace to specific EmpCo prohibitions.

1
Is the claim specific (about one identified, proven aspect) rather than a general term like "green" or "eco-friendly"?
EmpCo prohibits generic environmental claims where the organisation cannot demonstrate recognised excellent environmental performance relevant to the claim. Green, eco-friendly and environmentally friendly are the terms most often used this way. A claim about one identified aspect, proven, remains permitted. Broad terms such as conscious, sustainable or responsible are treated separately by the directive and are not made compliant simply by qualifying them.
EmpCo prohibition
2
Does the substantiation appear in the same place as the claim?
Evidence held in a file, or on a separate page a consumer would have to go looking for, does not do the work. The substantiation has to be available where the claim is made, in a clear and prominent form.
EmpCo prohibition
3
Is the claim free of any offsetting basis?
Claims that a product has a neutral, reduced or positive environmental impact by reason of offsetting are prohibited. This applies whether the wording is climate neutral, carbon neutral, net zero or CO₂ neutral, and it applies to the product, not only to the organisation.
EmpCo prohibition
4
If the claim uses a label or logo, is it backed by an independent certification scheme (rather than one you created yourself)?
Sustainability labels not based on a certification scheme, and not established by public authorities, are prohibited. A logo, badge or rating an organisation created for its own products falls here. The scheme behind a permitted label has to be open, transparent and monitored by an independent third party. If the claim uses no label, answer N/A.
EmpCo prohibition
5
Does the claim have a named owner?
Someone has to be able to answer for the claim, and it is rarely the person who wrote the copy. Where nobody owns a claim, nobody is renewing the evidence behind it.
Substantiation readiness
6
Has the evidence been checked recently enough to still support the claim today?
Evidence ages. A certificate, a supplier declaration or a life cycle assessment supports a claim as at its date, not indefinitely, and a supplier declaring its own product compliant is not substantiation.
Substantiation readiness
7
Does the claim describe the product as it is made and sold today?
Formulations, packaging, suppliers and markets change, and the claim on the pack usually does not change with them. This is the question that catches claims that were accurate when they were signed off.
Substantiation readiness
8
If the claim is about the future (a target or pledge), is it backed by a clear implementation plan and independent verification?
Forward-looking claims such as "climate neutral by 2030" are only permitted where they rest on clear, objective and publicly available commitments set out in a detailed and realistic implementation plan, including measurable targets, and are regularly verified by an independent third party. A pledge without a plan and independent verification is not permitted. If the claim makes no future commitment, answer N/A.
EmpCo prohibition
Part two

Your claims

One claim to a row. Answer each question Yes, No, N/A or leave blank. The column numbers match the eight questions above. Your entries are saved in this browser.

Claim as published Where it appears 1234 5678
1 Specific  |  2 Substantiation alongside the claim  |  3 Free of offsetting  |  4 Certified label  |  5 Named owner  |  6 Evidence current  |  7 Current version  |  8 Verified future target
Part three

Your result

Read the completed table both ways. Along each row, a single no tells you that claim needs attention. Down each column, a run of blanks or nos points to a system problem that will repeat with every new claim.

  • A no in questions 1, 3, 4 or 8 — a prohibition. The claim as written is not permitted in the EU from 27 September 2026, whatever evidence sits behind it.
  • A no in question 2 — depends on the claim. For a generic claim, substantiation that is not clear and prominent on the same medium is itself a prohibition. For a specific claim, the claim may be permitted but not as presented: the substantiation has to appear alongside the claim, not elsewhere.
  • A no in question 5 — a broken chain. No one is accountable for the claim, so nothing keeps its evidence current.
  • A no in questions 6 or 7 — an exposure. The claim may well be true, but you cannot currently show that it is.
  • A blank — a no until somebody has looked. Most organisations find more blanks than they expected.
  • An N/A means the question does not apply to that claim and does not count against it.
  • A column of blanks is a system problem rather than a claim problem, and it will reappear with every claim you make next.

Where each claim goes next

A claim you have assessed yourself is still a claim you have assessed yourself — and it carries only as much weight as your own sign-off. This is where Speeki helps.

Independent review

Speeki GreenDesk™

Assesses an individual claim before it is published, against the standards and regulations that apply. Every determination is signed off by a named Speeki expert.

Get a claim reviewed → Free standard

SPK GCMS3000:2026

Speeki's green claims management standard, covering ownership, evidence, review and renewal. Free to read and free to implement.

Read the standard →

Bring your completed table to the conversation.

Our team can talk you through GreenDesk™ or the SPK GCMS3000:2026 standard — whichever you need first.

Let's talk green claims