'We can prove that, of course.' That sounds reassuring, until someone asks: with exactly what? In practice, the evidence behind a sustainability claim is often scattered across several departments: a spreadsheet in the sustainability team, an invoice in procurement, a certificate saved as a PDF, an audit report with legal, a metric in an ESG system — and the claim itself has been sitting on the marketing site for four years. The problem is therefore not just whether evidence exists somewhere. It is the connection between the statement and the evidence behind it.
Good evidence answers five questions
First, does it actually support this exact claim? An invoice for renewable electricity does not automatically substantiate 'our company is environmentally friendly' — it can only document a clearly defined energy purchase. Second, is the scope identical? Does the evidence relate to a product, a location, a single legal entity, or the entire corporate group? The scope of the claim must never exceed the scope of the evidence; the relevant rules explicitly prohibit claims about an entire product or company where only a single aspect is actually affected.
Third, is the evidence current? A certificate from 2021 may not be a solid basis for a claim made in 2026, so every claim should carry a currency or review date. Fourth, is the methodology traceable — how was the figure calculated, which data was included, over what period, with what system boundaries, and based on which assumptions? Fifth, could a third party actually understand it? Evidence that only the person who created it can interpret is organisationally fragile and hard to defend if challenged.
The better solution: a claim-evidence system
Companies should manage environmental claims not like individual pieces of marketing copy, but like a structured register. For every claim, it is worth documenting at minimum: the claim itself, where it appears, the responsible person, its scope, the supporting evidence, the evidence date, its validity period, its approval status, and the date of the next review. This turns sustainability communication into something genuinely maintainable over time, rather than a one-off exercise.
This matters especially for websites
Websites change constantly. A piece of text gets copied. A landing page gets duplicated. A claim ends up in a brochure. A social media team picks it up again. Within a few months, the same statement can exist in ten different places, and correcting only the original page does not solve the underlying problem. That is why a sensible green-claims process always starts by mapping where every claim actually appears. A claim without a known location is hard to manage. A claim without evidence is hard to defend. Both pieces belong together.
Application and human review
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.
Sources
About the author
Marco Giraldo · Founder of VERDAI
Marco Giraldo is the founder of VERDAI. His work focuses on evidence-based sustainability communication and practical claim management.
VERDAI is an independent orientation tool. This post does not replace legal advice.
