EmpCo claim requirements
Environmental comparison claims
Make the comparator, metric, boundary, period and calculation method clear enough to understand and reproduce the stated difference.
Illustrative wording
A claim that could start this review
“Now made with 30% less plastic.”
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
- What is the exact comparator or baseline?
- Are the compared products, periods and lifecycle boundaries alike?
- Can the stated difference be reproduced from the retained inputs and method?
Evidence
What to obtain
- The named comparator or baseline and why it is like-for-like.
- The products or activities, geography, lifecycle boundary and time periods compared.
- The calculation method, input data and reproducible result for the stated difference.
Communication
What should be clear
- State the comparator, metric and period.
- Place the essential boundary and qualification beside the comparison.
Unresolved until reviewed
What EmpCo does not assume
- Whether the comparator is like-for-like and representative.
- Whether the calculation and presentation support the exact stated difference.
Next action
Move the record forward.
Write down the comparator, metric, boundary, periods and method; reproduce the calculation; then place the essential qualification beside the comparison.
Legal source
Why this question appears
The Directive reinforces that environmental characteristics and comparison-related information can be material to a transactional decision. This cue does not establish that a separate comparison-service rule applies or that the comparison is misleading.
Article 1(2)(a) and Article 1(3): UCPD Articles 6(1)(b) and 7(4a); recitals 2–3 and 6
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.