Who Is Actually Responsible for Green Claims?

No single department can manage them alone. Marketing understands the audience, tone, and channels. Sustainability or ESG teams understand the data, methodologies, and measures behind the claims. Legal teams assess legal risk. Subject-matter teams understand the product, supply chain, or operational processes in question. Senior leadership makes the call on especially far-reaching positioning and target commitments. Problems arise when these functions only come together after a campaign is already finished.

An efficient workflow might look like this. Step one: capture claims systematically, by regularly scanning the website, PDFs, and relevant marketing materials for sustainability statements. Step two: prioritise by risk — a technical sentence about the size of a solar installation is a very different matter from a sweeping statement like 'we are the most sustainable company in our industry.' Step three: assign technical evidence, with the relevant subject-matter team attaching data, certificates, or other supporting documentation. Step four: refine the communication, with marketing turning the substantiated claim into clear, audience-appropriate language. Step five: escalate critical cases, sending only claims with genuinely material risk to legal or external counsel, which keeps overall effort manageable. Step six: document the decision — which wording was approved, why, on what evidence, and until when the approval remains valid.

The goal cannot be to route every social media post through three departments and a law firm. A workable process therefore needs risk tiers: low risk gets standardised approval, medium risk gets a technical review, high risk goes to legal teams, and foundational, company-wide claims go to senior leadership or external review. That structure allows speed without sacrificing control.

Artificial intelligence is likely to change green-claims management substantially — not by taking over legal responsibility, but by reducing repetitive work: finding claims, spotting duplicates, documenting where they appear, categorising statements, flagging possible evidence gaps, drafting alternative wording, and monitoring for changes over time. The human role remains where context, accountability, and judgment are actually required.

Websites change. Campaigns change. Products change. Laws change. A one-time 'green claims check' is a good starting point, but it is not a durable governance model on its own. In the long run, companies need a process that catches new claims before they turn into a problem. That is the next stage of maturity: not just checking green claims occasionally, but actively managing them on an ongoing basis.

EmpCo primarily complements the rules for commercial practices directed at consumers. Check the applicable national implementation separately; Germany’s UWG does not automatically govern claims in other countries. Precise wording alone does not replace matching evidence or a responsible person’s decision before publication. Review the overall impression, including the heading, image and immediately visible explanation. Automated findings do not approve a claim.