Building a green claims inventory

Scope: where to look

• Owned digital surfaces — corporate sites, e-commerce, country sites, apps, microsites, blog content.
• Marketplace and third-party listings — Amazon, Zalando, retailer dot-coms where product copy may not be fully under marketing's control.
• Packaging and labels — primary, secondary, leaflets, in-pack documentation.
• Paid and earned media — search ads, social ads, TV/OOH, press releases, partner co-marketing.
• Sales and B2C decks reaching end consumers (events, retail HQ, hospitality).
• Brand and product names containing environmental terms — the Commission FAQ confirms these are in scope.
• CSRD/ESG reports the moment any figure is re-used in a consumer-facing channel.

How to capture

Manual audits do not scale. Mature programmes use a hybrid: web crawlers and OCR on packaging artwork to surface candidate claims; NLP pattern matching against EmpCo's banned vocabulary (Recital 9 list, Recital 12 offset terms, Recital 10 social-environmental hybrids); and a human review pass for context and substantiation linkage. Each captured claim records exact wording, medium, URL/asset ID, capture date, market, language, product/brand scope and supporting evidence reference.

Triage — Red / Amber / Green

• Red — clearly prohibited under Annex I. Immediate remediation.
• Amber — potentially defensible but missing substantiation, specification or scope clarity. Close it immediately — enforcement is live.
• Green — specific, substantiated, scoped, tied to recognised evidence. Keep and monitor.

The inventory's real value is what it enables: substantiation file mapping, CMS-level vocabulary blacklists, agency briefs prohibiting specific terms, a sign-off workflow, and a recurring scan to catch drift. The CMA's 2024 undertakings required quarterly progress reports — recurring scans match that cadence.

Citations: Directive (EU) 2024/825 Annex I and Recitals 9–12; UK CMA undertakings with ASOS, Boohoo, Asda (March 2024); European Commission DG JUST FAQ (Nov 2025).