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.
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.
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.