Making green claims that stand up to scrutiny: measurement and communication

The EmpCo Directive prohibits green claims that are not properly substantiated. But what does that actually mean? It starts with a rigorous measurement of your environmental impact – and only ends once that measurement has been translated into a claim that is factually accurate, legally defensible and credible. In this article, we explore how you can build that foundation.

‍

Today, companies making claims about CO₂ emissions, energy consumption, recyclability or any other environmental attribute must be able to demonstrate that those claims are based on methodologically sound measurement.

‍

A life cycle assessment (LCA) maps a product's environmental impact across its entire lifespan: from raw material extraction through to end-of-life processing. It is the most robust instrument available for substantiating a green claim under EmpCo.

May 27, 2026

Katelijne Norga

Liesbeth Voets

Green Claims Directive

What a sound LCA looks like

A robust claim is built on high-quality, transparent information. An LCA must therefore meet a number of conditions:

‍

Methodological rigour

The assessment must be conducted in line with recognised standards. ISO 14040/14044 is the international standard for LCAs. For certain product categories, sector-specific methods and the PEF methodology (Product Environmental Footprint) are often the preferred approach. An in-house analysis that fails to follow these standards offers no legal protection.

‍

Appropriate system boundaries

Which part of the life cycle does the assessment actually cover? Production only, or also raw material extraction, transport, use and end-of-life? The choice of system boundaries shapes the claims you can make – and how you must phrase them. An assessment with narrow boundaries that are not clearly communicated may result in a misleading claim.

‍

Traceable data

The underlying data must be traceable and verifiable on a per-product basis. The directive requires that evidence is available for inspection – accessible to regulators and, where relevant, to consumers. In certain cases, such as forward-looking claims, external verification by an independent third party is mandatory.

From measurement to claim: the second pillar

A solid LCA provides you with an excellent basis for substantiating claims, but that is only half the job. The measurement still has to be translated into a claim that is correct from both a legal and a communications perspective – and that involves more than it might appear. An LCA report produces data. But which figures can you actually communicate? How specific do you need to be in each medium? What context is mandatory? And is your claim really about something materially impactful – or are you communicating a marginal effect?

‍

The additional information that EmpCo requires to accompany a claim is precisely where companies most often fall short in practice. Technical results are often translated into marketing copy without the legal preconditions being carried across. A claim such as “30% less CO₂” may be accurate on the basis of the LCA and yet remain problematic if the basis for comparison is missing, the scope is not stated, or the medium leaves too little room for the mandatory qualifiers.

‍

The EmpCo Directive also requires a materiality test: does your claim relate to something that is genuinely impactful for the product in question? Labelling a glass bottle “recyclable” communicates a quality inherent to glass as a material – not a performance that sets this product apart from any other glass packaging.

What Pantarein does: from measurement to claim

Pantarein offers both pillars – technical substantiation and communications guidance – as a single, integrated process. We carry out LCAs and guide the translation into compliant, credible communication.

‍

In practice, our programme covers:

‍

Scope and boundary definition – we determine which part of the value chain the assessment covers and how that scope should be communicated.
LCA execution – we conduct the life cycle assessment in line with the relevant standards and with the methodology best suited to your product and sector.
Materiality test - we assess which environmental aspects are most significant and therefore worth communicating.
Claim formulation – we translate the assessment results into specific, accurate and EmpCo-compliant claims tailored to each communication channel.
Documentation – we make sure the substantiation behind every claim is documented and available for inspection, as the legislation requires.

‍

The outcome of this process is an LCA report together with a set of claims you can deploy immediately and correctly in your communications. For formal certification or external verification – which is legally required in certain cases, such as forward-looking claims – we partner with specialist providers and can refer you to the right one.

When should you start?

Depending on the complexity of the product and the availability of data, a full life cycle assessment can take anywhere from a few weeks to several months. Add claim translation, building the supporting documentation and any changes to packaging or campaigns – and it quickly becomes clear that the September 2026 EmpCo deadline is closer than it looks.

‍

If you are currently making green claims on packaging, in campaigns or on your website, and want to continue making them after 27 September, now is the time to start.

‍

Making green claims that stand up to scrutiny: measurement and communication

What a sound LCA looks like

From measurement to claim: the second pillar

What Pantarein does: from measurement to claim

When should you start?

Do you want to find out which of your current claims already have substantiation gaps, or what an LCA programme would look like for your products?

Most recent

Making green claims that stand up to scrutiny: measurement and communication

Water is becoming scarce. Does your company have a plan?

CBAM: from a new climate measure to a strategic advantage

Making green claims that stand up to scrutiny: measurement and communication

What a sound LCA looks like

From measurement to claim: the second pillar

What Pantarein does: from measurement to claim

When should you start?

Do you want to find out which of your current claims already have substantiation gaps, or what an LCA programme would look like for your products?

Share this article

Most recent

Making green claims that stand up to scrutiny: measurement and communication

Water is becoming scarce. Does your company have a plan?

CBAM: from a new climate measure to a strategic advantage