EmpCo claim requirements

Chemical and “free from” claims

Define the named substance, threshold, product scope, market and test basis without implying that every exclusion is a special environmental benefit.

Claim level
Product · Ingredient or material · Packaging or component
Source checked
Review state
Guidance available · evidence not checked

Illustrative wording

A claim that could start this review

“PFAS-free materials.”

This example is written by EmpCo for orientation. It is not a quotation, company evidence or a finding that the rule applies.

Clarify

What must be established

  • Which exact substance or group does the wording cover?
  • Does “free” mean absent, below a detection limit or below another threshold?
  • What product version, component, market and date were tested?

Evidence

What to obtain

  • The exact substance or substance group and the meaning of “free”.
  • The product, component, threshold, market and date covered.
  • Current supplier declarations, test method and results for the stated scope.

Communication

What should be clear

  • State the substance, tested threshold and tested scope.
  • Do not present a legal minimum or irrelevant absence as a distinctive benefit.

Unresolved until reviewed

What EmpCo does not assume

  • Whether “free” means absent, below a detection limit or below another threshold.
  • Whether the cited chemical regime applies to the product, substance, market and date.

Next action

Move the record forward.

Define the substance and threshold, confirm the tested product scope and date, and qualify the statement to match the available supplier and test evidence.

Legal source

Why this question appears

The Directive treats product environmental and circularity characteristics as potentially material. It does not make every private exclusion list or candidate-list reference proof of a legal prohibition.

Empowering Consumers for the Green Transition Directive (EU) 2024/825 — enacted text (opens in a new tab)

Article 1(2)(a) and Article 1(4), Annex point (3): UCPD Article 6(1)(b) and Annex I point 10a; recitals 3, 5 and 15

Source checked 2026-10-06. This is an EU-level Directive source. National implementation, sector rules, complete presentation and intended use require separate review.

Use this requirement

Apply it to exact wording and evidence.

A requirement page explains the work. A saved review records the wording, context, evidence state, sources and unresolved questions.