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April 10, 2026

Climate Claims: What Makes a Substantiated, Verifiable Statement

Why “carbon neutral” is no longer permissible The per-se prohibition under EmpCo applies to all claims that suggest a product or company has no negative climate impact — particularly if this is achieved through carbon offsetting.

What characterises a substantiated statement Substantiated environmental claims are specific, measurable and backed by your own, transparent evidence: concrete figures, a base year, a methodology or an externally awarded certificate with a registration number. Blanket terms without evidence are open to challenge.

15 general examples of substantiated statements The following points are general examples for illustration — not a recommendation for action and not ready-made wordings to adopt. Every statement stands or falls with the evidence behind it: a claim is only permissible if it is backed by your own, verifiable evidence. Empcora reviews statements and maps them to the relevant legal basis — Empcora does not draft wordings.

  1. CO₂ emissions (Scope 1+2) reduced against a base year — with a concrete percentage and base year
  2. Production with green electricity — with a certificate of origin (e.g. TÜV SÜD EE02)
  3. Packaging with a verified share of post-consumer recycled material
  4. Energy consumption per unit of product reduced — with period and measurement methodology
  5. ISO 14001-certified environmental management system
  6. Transport routes shortened through regional sourcing — verifiably documented
  7. Water consumption reduced by a concretely measured amount per year
  8. Waste rate below a verified threshold through a circular economy
  9. EMAS-validated environmental report (updated annually)
  10. EU Ecolabel certified — with licence number
  11. SBTi-validated reduction target — with target value and base year
  12. Cradle to Cradle Certified™ (with level)
  13. Recyclable materials — verified according to ISO 14021
  14. Photovoltaic system covers a verified share of own requirements
  15. Supply chain certified according to SA8000

What matters is not the wording but the evidence behind it. Whether a specific statement is permissible in your case depends on your own records; in case of doubt, seek legal advice.

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