Governance & Policy
Unsubstantiated Claim
An environmental claim made without adequate evidence — the legal category into which most greenwashing enforcement bites.
Definition
An unsubstantiated claim is an environmental or sustainability claim made without possessing adequate evidence to support it at the time it is made. Under the EU Empowering Consumers Directive (2024/825), generic environmental claims ("eco-friendly", "green") without recognised excellent performance are banned outright; sustainability labels not based on certification schemes or established by public authorities are prohibited; and claims of climate neutrality based on offsetting are banned — each a formalised version of the substantiation duty.
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