What this is
What is an environmental claim substantiation record?
What is an environmental claim substantiation record?
A record capturing the evidence behind a specific environmental claim before it is used on packaging, a website, marketing material or a tender response. It names the claim, records the evidence, checks the wording, and sets a point at which the claim is looked at again.
What counts as an environmental claim?
Any statement, symbol or graphic implying the product, packaging or company has a reduced environmental impact. Recyclable, carbon neutral, sustainably sourced, reduced impact, compostable and certified-scheme claims are the common categories, each read differently by a regulator than by whoever wrote it.
Who has to sign off an environmental claim?
Technical and legal both, for different reasons. Technical confirms the evidence supports what is claimed. Legal confirms the wording says no more than the evidence supports, a separate and more common failure in enforcement.
Scope
When is an environmental claim substantiation record required?
This record gates one claim before it is published, not environmental performance generally. Used more broadly, it produces a record nobody can locate when a specific claim is challenged.
Use this template when
- A new environmental or sustainability claim is being drafted for a pack, website, marketing material or tender response
- An existing, previously substantiated claim is being reused on a new SKU, market or pack format
- A customer or certification scheme questionnaire asks you to state and evidence a specific claim
- Technical or legal flags a claim already in the market that was never formally substantiated
- The evidence behind a live claim needs re-checking because the product, process or supplier has changed
Do not use it for
- Reporting environmental performance over a period, which is the Environmental Performance Report, not a claim-scoped record
- Answering a customer's or scheme's own sustainability questionnaire, which is the Customer Sustainability Questionnaire Record
- Collecting value chain emissions data a carbon claim is built on, which feeds the Greenhouse Gas Inventory via Scope 3 Data Collection
- Calculating the greenhouse gas figures behind a carbon neutral claim; the inventory produces the figures, this record only confirms the claim is fit to publish
- A claim already withdrawn or superseded, which belongs in the register as a closed entry, not a fresh record
Compliance mapping
Which ISO 14021 requirements does this satisfy?
ISO 14021 sets the general test for a self-declared claim: accurate, verifiable, relevant, not misleading. It prescribes no format, which is why national regulators build enforcement on top of the same principle.
| Clause | Requirement | Where it lands |
|---|---|---|
| ISO 14021 cl.5 | Self-declared claims must be accurate, verifiable, relevant to the product, and not misleading | Substantiation |
| ISO 14021 cl.5 | Substantiation obtained before the claim is made, available for as long as it is used | Substantiation |
| ISO 14021 cl.5 | Claims specific to the product or packaging; vague or unqualified terms not permitted alone | Wording |
| ISO 14021 cl.6 | Specific requirements for defined terms including recyclable, compostable and recycled content | Wording |
| CMA Green Claims Code, principle 4 | Comparisons fair and meaningful, against a stated and current basis | Wording |
| ISO 14021 cl.5 | A claim is reviewed, and withdrawn if necessary, when the product, process or material it describes changes | Maintenance |
| CMA Green Claims Code, principle 6 | Claims substantiated with robust, credible, current evidence, held while live | Outcome |
| Internal governance | A claim is not used until both technical and legal approval are recorded against it | Header |
What it does not cover
- Third-party ecolabel certification (ISO 14024, Type I), awarded by an independent scheme against its own criteria, not an internal record.
- An Environmental Product Declaration (ISO 14025, Type III), which needs a full life cycle assessment against a product category rule, not a yes-or-no check.
- The greenhouse gas calculation behind a carbon claim, which belongs in the Greenhouse Gas Inventory; this record only confirms the claim is fit to publish.
- A formal legal defence, should the claim be challenged, for which this is the evidence trail a defence is built from, not the defence itself.
- Ongoing monitoring of a live claim past its review date, which needs the trigger actually acted on, not just recorded and left.
Global
Environmental Claim Substantiation Record requirements by country
The duty to have evidence behind a claim is close to universal. What differs is who enforces it, how directly, and how prescriptive the definition of a term like recyclable is allowed to be.
CMA Green Claims Code, under the Digital Markets, Competition and Consumers Act 2024
Six principles including truthfulness, comparison and substantiation, backed by direct CMA enforcement.
The CMA can investigate and fine directly, turning a green claim into a competition-law risk with a fast route.
Unfair Commercial Practices Directive 2005/29/EC as amended by Directive (EU) 2024/825
Generic unqualified claims such as environmentally friendly are banned outright from 2026; a separate Green Claims Directive on pre-use verification was paused amid legislator disagreement.
The ban on unqualified generic claims stands regardless, so wording not tied to a specific evidenced claim is at risk.
FTC Green Guides, 16 CFR Part 260, enforced through Section 5 of the FTC Act
Guidance on how the FTC interprets deceptive claims, with recyclable, degradable and offset claims singled out for specific conditions.
The Guides are not law, but the FTC Act's deception standard is, and they signal how it applies.
How to complete it
How to complete an environmental claim substantiation record, step by step
The form asks whether evidence exists and the wording is fair. The judgement that protects the business is in how those two questions connect.
Substantiation obtained after a claim is challenged is a defence built under pressure, weaker than evidence gathered first. Evidence Held For The Claim and Method Or Standard Named force the sequence: claim follows evidence, not the reverse.
Sustainable, eco-friendly and green are conclusions, not measurements, read by a regulator as claims needing their own substantiation. Wording Specific Not Vague and Qualifiers Included Where Needed exist because that gap is where enforcement lands.
A claim true at product level can be false read as company-wide, and true domestically can be false in export. Product Or Company Level, Market Where Used and Comparison Basis Fair Where Used stop a claim travelling further than its evidence.
A claim reviewed annually is wrong the moment the formulation or supplier changes, correct on paper until the calendar catches up. The two Maintenance fields raise the review directly, rather than waiting for Expiry Or Review Date.
What auditors find
Most common environmental claim substantiation record findings
The record almost always exists for a claim already on a pack; the findings concern what it actually establishes and how quickly it goes stale.
| Finding | Clause | What fixes it |
|---|---|---|
| Evidence recorded as held but never independently verified for a claim a regulator would expect checked. | CMA Green Claims Code, principle 6 | Commission verification proportionate to prominence; record the source. |
| Wording broader than the evidence, most often an unqualified recyclable or sustainable claim with no market attached. | ISO 14021 cl.5 | Qualify the claim to the market it is true for; record the qualifier rather than implying it. |
| A comparative claim made with no stated, current comparison basis. | CMA Green Claims Code, principle 4 | Record the comparator, confirm it is current, reject the claim if not statable. |
| Claim not re-checked after the formulation or supplier behind it changed. | ISO 14021 cl.5 | Link the claim to the change process so a change raises re-substantiation. |
| Offsetting used to support a claim without the offset itself being disclosed. | CMA Green Claims Code, principle 1 | Disclose the offset explicitly rather than folding it into an unqualified claim. |
| A claim live in market with an expired review date and no register entry linking to this record. | Internal governance | Maintain the register as a live list; an expired Review Date is a hard block. |
Case in point
Case in point: the claim that was correct at launch
A consumer goods brand substantiated a recyclable claim for a pack sold domestically, where the material was accepted by kerbside collection, and took the record through technical and legal review before print. Eighteen months later the same unchanged pack was approved for an export market as a routine range extension, reusing the existing record because the artwork had not changed.
A retail buyer in the export market asked for evidence the claim was true locally. It was not: that country's kerbside system did not accept the material, and the claim depended on infrastructure that only existed domestically. The record had never been re-opened for Market Where Used, because only where the pack was sold had changed.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
5 sections
- Reference
- ENV-056
- Archetype
- Record
- Record ID
- ECS-2026-000
- Scoring
- Claims substantiated
- Direction
- High is good
- Singleton
- No
- Basis
- ISO 14021
- Links
- Links Packaging review, GHG inventory
- Tags
- Environment, Claims
- Sections
- 5
- Fields
- 45
- Follow up fields
- 3
- Repeating sections
- 0
- Links out
- 3
Header
13 fieldsRecord ID*
Auto sequence. Format ECS-2026-000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Date and Time*
Completed By*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Claim Made*
Where It Appears*
Claim Type*
Requested By*
Product Or Company Level*
Market Where Used*
Unsubstantiated Claims Are A Regulated Offence
Recyclable, carbon neutral and sustainably sourced are all claims a regulator can ask you to prove. Approve them before they go on a pack, not afterwards.
Substantiation
6 fieldsEvidence Held For The Claim*
- Yes3 pts
- Partly1 pt
- No0 pts
Evidence Independent Or Verified*
- Yes2 pts
- No0 pts
- N/Aexcluded from denominator
Method Or Standard Named*
- Yes3 pts
- Partly1 pt
- No0 pts
Scope Of The Claim Clear*
- Yes3 pts
- Partly1 pt
- No0 pts
No Material Omissions*
- Yes3 pts
- Partly1 pt
- No0 pts
Comparison Basis Fair Where Used*
- Yes3 pts
- Partly1 pt
- No0 pts
Wording
6 fieldsWording Specific Not Vague*
- Yes3 pts
- Partly1 pt
- No0 pts
Qualifiers Included Where Needed*
- Yes3 pts
- Partly1 pt
- No0 pts
Life Cycle Considered*
- Yes3 pts
- Partly1 pt
- No0 pts
Offsetting Disclosed Where Used*
- Yes3 pts
- Partly1 pt
- No0 pts
Legal Review Completed*
- Yes3 pts
- Partly1 pt
- No0 pts
Customer Requirements Met*
- Yes3 pts
- Partly1 pt
- No0 pts
Maintenance
6 fieldsEvidence Retained And Retrievable*
- Yes3 pts
- Partly1 pt
- No0 pts
Claim Reviewed On Formulation Change*
- Yes3 pts
- Partly1 pt
- No0 pts
Claim Reviewed On Supplier Change*
- Yes3 pts
- Partly1 pt
- No0 pts
Expiry Or Review Date Set*
- Yes3 pts
- Partly1 pt
- No0 pts
Withdrawal Process Defined*
- Yes3 pts
- Partly1 pt
- No0 pts
Register Of Claims Maintained*
- Yes3 pts
- Partly1 pt
- No0 pts
Outcome
14 fieldsClaim Substantiated*
- Yes3 pts
- Partly1 pt
- No0 pts
Approved For Use*
- Yes3 pts
- With conditions2 pts
- No0 pts
Conditions
Artwork Approval Linked*
- Yes3 pts
- Not applicable3 pts
- No0 pts
Artwork Approval ID
Links to QUA-090 Approval ID
Review Date*
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
Environmental Lead*
Signature*
Technical*
Second Signature*
ENV-056 · record IDs look like ECS-2026-000 · Links Packaging review, GHG inventory
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The record gates one claim. What fails around it is the connection back to the pack, the supplier and the artwork that keep using a claim after its evidence has moved on.
Holds the claims register against every pack and market a claim is used in, flags one whose review date has passed or supplier changed, and routes it back to technical and legal.
Watches formulation, supplier and artwork change records for events that should invalidate a claim, and raises re-substantiation rather than waiting for the review date.
Links the claim's artwork approval to the pack change record, so a claim cannot go to print without the substantiation it was approved against.
This template lives in KnowEnviro — environment and energy. Aspects, permits, waste, emissions, spills and sustainability reporting.
Meet KnowEnviro→Glossary
Environmental Claim Substantiation Record definitions and key terms
- Self-declared environmental claim
- A claim made by the manufacturer or seller without independent certification, governed by ISO 14021, the category most pack or marketing claims fall into.
- Substantiation
- The evidence held to support a claim, obtained before it is made and kept available for as long as it is used.
- Greenwashing
- A claim giving a better impression of environmental benefit than the evidence supports, through vague wording, an unqualified scope, or misleading use of a true statement.
- Comparative claim
- A claim that a product is better than a stated alternative, requiring the comparison basis to be identified and current.
- Offsetting
- Compensating for an impact through an external scheme, most often a carbon credit, disclosed as an offset rather than a direct reduction.
FAQ
Frequently asked questions about environmental claim substantiation record
Does every environmental claim need its own record?+
Yes, in effect. The form is built around one claim, its wording and its market, and reusing one record's substantiation for a different claim or market is the gap that turns a true claim misleading. The auto-sequenced Record ID supports one record per claim, not one per workspace, despite the catalogue setting.
What is the difference between technical and legal sign-off?+
Technical confirms the evidence supports what is claimed. Legal confirms the wording says no more than the evidence supports. A claim can pass technical review and still fail legal, because the failure is in the words chosen, not the facts.
Can a claim be true and still be a problem?+
Yes. A recyclable claim can be true for the material and still misleading if its market has no collection infrastructure for it.
How is a carbon neutral or net zero claim different from other claims here?+
It depends on a calculation this record does not perform. The Greenhouse Gas Inventory produces the figures; this record only confirms the resulting claim and offsetting are stated accurately before publication.
What should trigger a re-check of a claim already in the market?+
A change to formulation, supplier, packaging or the market sold into, any of which can invalidate the evidence without the pack's wording changing. The review date is a backstop, not the primary trigger.
Why does the market where a claim appears matter so much?+
Because substantiation for terms like recyclable depends on facts on the ground, such as local collection infrastructure, not the material's general properties. Wording accurate in one market can mislead in another.
Keep going
Related templates and programmes
Industries this is written for
Programmes this belongs to
Used together in Environmental Management
Legal and Other Requirements Register
Lists every law, regulation, permit and commitment that applies to your operation
Compliance Evaluation Record
Records the periodic evaluation of whether you actually comply with each obligation
Waste Stream Register
Lists every waste stream produced on site, with its classification, container and disposal route
Waste Transfer Record
Records waste leaving site, including type, quantity, carrier and destination
Hazardous Waste Record
Records generation, storage and disposal of hazardous waste
Waste Area Inspection
Checks waste storage areas for correct segregation, labelling, containment and housekeeping
More in Environmental Reporting
Environmental Performance Report
Reports environmental performance over a period against objectives, covering waste, water, energy, emissions and incidents
Customer Sustainability Questionnaire Record
Records a customer or scheme sustainability questionnaire, the answers given and the evidence behind each one
Scope 3 Data Collection Record
Records the collection of value chain emissions data from suppliers and hauliers, with quality and coverage noted
Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- ISO 14021:2016, Self-declared environmental claims (Type II labelling)
- CMA Green Claims Code (UK)
- FTC Green Guides, 16 CFR Part 260 (US)
- Directive 2005/29/EC on unfair commercial practices, as amended by Directive (EU) 2024/825
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.