Quick Read
SPK GCMS3000:2026 is Speeki’s proprietary green claims management system standard, created to govern how organisations make, substantiate, review and maintain environmental claims. It requires a structured GCMS covering claims inventories, evidence files, pre-publication review, regulatory monitoring and evidence renewal across products, services, operations and organisational commitments. Certification results in Speeki Verdant™ and confirms the management system, not the accuracy of every individual claim.
SPK GCMS3000:2026(E)
Copyright and Licensing Notice
© Speeki Pte Ltd 2026. All rights reserved.
Copyright
SPK GCMS3000:2026 is the proprietary intellectual property of Speeki Pte Ltd. All rights in this standard — including copyright in its structure, requirements, definitions, guidance, and all other content — are owned by Speeki. No part of this standard may be reproduced, distributed, translated, adapted, or transmitted in any form or by any means, electronic or mechanical, without the prior written permission of Speeki, except as expressly permitted under the licences set out below.
Citation Allowance
Notwithstanding the restrictions in this notice, SPK GCMS3000:2026 may be cited by its reference number in determinations, certificates, regulatory submissions, procurement responses, and client reporting without restriction. This allowance covers citation by reference only and does not permit reproduction of the standard's requirements, methodology, or substantive content.
Licence for Adopting Organisations
Organisations that have adopted SPK GCMS3000:2026 as the basis for their Green Claims Management System (GCMS) are granted a limited, non-exclusive, non-transferable licence to:
reproduce and distribute copies of this standard within the organisation, for the sole purpose of internal use in connection with the adoption, implementation, and operation of SPK GCMS3000:2026;
reference and quote the requirements, definitions, and guidance of this standard in internal documents, policies, procedures, training materials, and governance records, where the purpose is to implement the standard within the organisation.
This licence is granted to the adopting organisation only. It is personal, non-transferable, and does not extend to any related entity, affiliate, or third party unless that entity is itself directly implementing the standard within its own operations.
Restrictions
The licence granted under Licence for Adopting Organisations does not extend to, and the following uses are expressly prohibited without the prior written consent of Speeki:
Service providers, management consultants, advisory firms, legal and professional services firms, and other third-party providers may not incorporate, reproduce, or adapt the requirements, structure, or content of this standard into commercial services, proposals, deliverables, reports, or frameworks provided or sold to clients.
Software vendors, technology companies, and platform or application providers may not incorporate, embed, encode, reproduce, or adapt the requirements, structure, or content of this standard, in whole or in part, into any software product, SaaS platform, application, automated assessment tool, AI model, or other technology product or service.
No person or entity may use this standard, or any material derived from it, to create, develop, publish, or market any competing green claims management standard, certification scheme, or assessment framework.
No person or entity may post, publish, or make available this standard, or any substantial extract of it, on any website, extranet, portal, or platform accessible to persons outside the adopting organisation without the prior written consent of Speeki.
Certification Rights
The right to assess organisations against, and to issue certificates of conformity with, SPK GCMS3000:2026 is reserved exclusively to Speeki Pte Ltd and to bodies that Speeki has formally authorised in writing to act as certification bodies under this standard.
An organisation certified against SPK GCMS3000:2026 may be awarded Speeki Verdant™ certification. Such certification attests to the conformity of the organisation's Green Claims Management System with this standard. It does not constitute a determination that every individual environmental claim made by the organisation is compliant or substantiated.
No organisation, body, or individual may:
issue SPK GCMS3000:2026 certificates, certification letters, compliance statements, or equivalent recognition documents;
conduct SPK GCMS3000:2026 certification assessments or third-party conformity assessments against this standard; or
represent to any third party that an organisation has been assessed against or found conformant with SPK GCMS3000:2026,
without written authorisation from Speeki. Any certificate, report, or claim purporting to demonstrate SPK GCMS3000:2026 certification or conformity that has not been issued by Speeki or a Speeki-authorised body is invalid and may constitute a misrepresentation.
Licence Enquiries and Permissions
Enquiries regarding commercial licences, authorisation to act as a certification body, or any use of this standard not expressly permitted above should be directed to Speeki at speeki.com. Speeki reserves the right to update these licensing terms at each edition review.
Foreword
Organisations across every sector make environmental claims about their products, operations, and commitments. Those claims appear on packaging, websites, advertising, social media, annual reports, procurement submissions, and investor communications. Until now, no single management system standard has existed to govern how an organisation builds, manages, substantiates, and continuously improves the programme through which those claims are made.
SPK GCMS3000:2026 is that standard. It establishes the requirements for a Green Claims Management System (GCMS) — the internal programme an organisation must operate to ensure that its environmental claims are accurate, substantiated, consistent, and maintained over time. An organisation that certifies its management system against this standard demonstrates to regulators, customers, investors, and procurement teams that its environmental claims are governed by a structured, independently audited programme.
The enforcement environment for environmental claims has changed materially. Regulators in Australia, the European Union, the United Kingdom, and the United States have confirmed, through enforcement actions involving penalties of AUD 8–13 million and USD 4–17.5 million, that good intentions do not constitute substantiation. Evidence must exist before a claim is made. The claim must be accurate for every market and channel in which it appears. It must be reviewed when products, supply chains, or markets change. These are not new requirements — they have existed in ISO 14021:2016 and ISO 14020:2022 for years. They are now being enforced.
SPK GCMS3000:2026 translates those requirements into an auditable management system. The standard draws on the ISO Annex SL harmonised structure, making it compatible with other management system standards and straightforward to integrate with existing programmes. It introduces requirements specific to the green claims domain: a claims inventory, evidence management, pre-publication review procedures, regulatory monitoring, and a renewal programme to ensure that evidence stays current as conditions change.
The certification product is Speeki Verdant™. An organisation certified as conforming to SPK GCMS3000:2026 has had its Green Claims Management System independently audited by Speeki against this standard and found to meet its requirements. That certification does not replace the individual claim determinations issued under SPK GCMS3001:2026 and the Speeki GreenDesk® service — it certifies the system that governs those claims.
1. Scope
SPK GCMS3000:2026 specifies requirements for a Green Claims Management System (GCMS). A GCMS is the set of policies, processes, controls, registers, and review mechanisms through which an organisation manages its environmental claims about products, packaging, services, operations, and organisational commitments.
This standard enables an organisation to demonstrate that it has established and maintains a systematic, auditable programme for making environmental claims that are accurate, substantiated, appropriately qualified, and kept current. Certification against this standard by Speeki results in the award of Speeki Verdant™ certification.
The requirements of this standard apply to all environmental claims made by the organisation about:
Products and product components, including packaging
Services and operations
Organisational commitments and targets, including net zero targets, carbon neutrality commitments, and sustainability strategies used in external communications
This standard applies regardless of the size, sector, or geographic location of the organisation. The depth and complexity of the GCMS may be scaled proportionally to the organisation's size, the number and complexity of its claims, and the markets in which those claims appear — but no requirement may be excluded.
This standard is designed to be compatible with and complementary to other ISO management system standards, including ISO 14001 (Environmental Management), ISO 50001 (Energy Management), and ISO 37001 (Anti-Bribery Management). Integration with existing management systems is encouraged.
This standard does not specify requirements for the technical accuracy of individual claims, which is governed by ISO 14021:2016, ISO 14020:2022, ISO/TS 14067:2018, and the applicable regulatory frameworks. It specifies requirements for the management system within which those claims are made and maintained.
2. Normative References
The following documents are incorporated by reference and are indispensable to the application of this standard. For dated references, only the edition cited applies. For undated references, the latest edition applies.
Reference | Title / Description |
|---|---|
ISO 14020:2022 | Environmental statements and programmes for products — Principles and general requirements. Third edition. |
ISO 14021:2016 (incl. Amd 1:2021) | Environmental labels and declarations — Self-declared environmental claims (Type II environmental labelling). Second edition. |
ISO/TS 14067:2018 | Greenhouse gases — Carbon footprint of products — Requirements and guidelines for quantification. |
ISO 19011:2026 | Guidelines for auditing management systems. |
SPK GCMS3001:2026 | Green Claims Assessment and Certification Guidance. The companion normative standard governing the methodology for individual claim assessment and certification under Speeki GreenDesk®. |
GreenDesk Regulatory Reference Library (current edition) | Maintained by Speeki. Incorporated by reference. Contains current applicable regulatory requirements for each jurisdiction. Updated continuously. Current edition supersedes all prior editions. |
3. Terms and Definitions
For the purposes of this standard, the following terms and definitions apply. ISO 14021:2016 and ISO 14020:2022 definitions apply where terms are not defined here.
Term | Definition |
|---|---|
Green Claims Management System (GCMS) | The set of policies, processes, controls, registers, and review mechanisms through which an organisation manages its environmental claims. The GCMS includes the governance structures, evidence management systems, pre-publication review procedures, and renewal programmes required by this standard. |
Environmental claim | Any statement, symbol, or graphic that indicates an environmental aspect of a product, service, operation, or organisational commitment. Includes product-level and organisation-level claims. (ISO 14021:2016 informed.) |
Claims inventory | A complete register of all environmental claims made by the organisation across all products, services, channels, and markets, maintained in accordance with Section 9 of this standard. |
Evidence file | The documented substantiation for an individual environmental claim, containing all materials required for verification of that claim without access to confidential business information (ISO 14021:2016 Clause 6.5.1). |
Pre-publication review | The review of an environmental claim and its evidence file before the claim is used in any external communication, to ensure conformity with ISO 14021:2016, compliance with applicable regulatory frameworks, and satisfaction of the requirements of this standard. |
Claim owner | The individual or function within the organisation responsible for maintaining the accuracy and currency of a specific environmental claim and its evidence file. |
Material change | Any change to a product, packaging, supply chain, manufacturing process, market, channel, or regulatory requirement that affects the accuracy or currency of an environmental claim. |
Evidence renewal date | The date by which the evidence supporting an environmental claim must be renewed to remain current. Determined as the earlier of: the expiry of the most constrained evidence element; or 12 months from the date of the last assessment. |
Regulatory framework | The applicable consumer protection, environmental, and advertising laws and regulations in each jurisdiction where an environmental claim appears. Current applicable frameworks are maintained in the GreenDesk Regulatory Reference Library. |
Shall | Indicates a mandatory requirement. Departure from a requirement expressed as 'shall' constitutes a nonconformity. |
Should | Indicates a recommendation, not a mandatory requirement. Used in Annex A only. Departure from Annex A guidance is not a nonconformity. |
May | Indicates a permitted option. |
Governing body | The highest decision-making authority of the organisation: board of directors, supervisory board, partnership board, or equivalent. |
Top management | The person or group of people who directs and controls the organisation at the highest level. |
Nonconformity | Failure to satisfy a requirement of this standard. |
Corrective action | Action to eliminate the cause of a nonconformity and to prevent recurrence. |
Speeki Verdant™ | The certification product awarded by Speeki to an organisation whose Green Claims Management System has been independently audited and found to conform to SPK GCMS3000:2026. |
Speeki GreenDesk® | The Speeki service through which individual environmental claims are assessed and certified under SPK GCMS3001:2026. |
4. How to Read This Standard
This section explains the structure of requirements in SPK GCMS3000:2026 and how they are to be interpreted.
4.1 Requirement Numbering
Each requirement in this standard is identified by a Clause.Requirement reference. For example, Req. 9.1.3 refers to Section 9 (Operation), Sub-clause 9.1 (Claims Inventory), Requirement 3. Every requirement table row in this standard must be read as a single, complete, mandatory requirement. Each row must be satisfied in full for the organisation's GCMS to conform to this standard.
4.2 The Requirement Table Format
Requirements are presented in the following format throughout this standard:
Req. | X.Y.Z — Example requirement title |
|---|
The organisation shall [descriptive text explaining what the organisation must establish, maintain, document, implement, or ensure]. The requirement is complete and self-contained within this row. |
> Cross-references: ISO reference | Regulatory framework reference | Related GCMS3000 clause |
The table header (dark bar) contains the Req. number and title. The body row contains the requirement, always beginning with 'The organisation shall'. The footer row (shaded) contains cross-references to the ISO standards and regulatory frameworks from which the requirement is drawn. All rows of a requirement table are part of the same requirement.
4.3 Shall, Should, and May
'Shall' — mandatory. Appears in Sections 5 through 12. Departure is a nonconformity.
'Should' — recommended, not mandatory. Appears in Annex A only. Departure from Annex A guidance is not a nonconformity and shall not be treated as such by auditors.
'May' — a permitted option. Does not impose any obligation.
4.4 Scalability
The requirements of this standard apply to all organisations regardless of size or sector. The depth and complexity of documentation, controls, and monitoring may be scaled to the organisation's size, the number of active claims, and the complexity of its claims portfolio. However, no requirement may be excluded. An organisation with two active claims must satisfy every requirement, but may do so with simpler documentation than an organisation with 500 active claims. The auditor assesses conformity relative to the complexity appropriate to the organisation's context.
4.5 Annex A Guidance
Annex A provides non-mandatory guidance on the intent of specific requirements. Annex A guidance is provided to assist organisations in understanding how requirements may be implemented, not to specify additional mandatory obligations. Auditors shall not treat Annex A guidance as normative requirements.
5. Context of the Organisation
5.1 Understanding the Organisation and Its Context
Req. | 5.1.1 — Internal and external issues |
|---|
The organisation shall determine the internal and external issues relevant to its purpose and the management of its environmental claims. Internal issues include the organisation's markets, product portfolio, supply chain structure, marketing practices, and internal governance. External issues include the applicable regulatory frameworks, enforcement environment, consumer expectations, and procurement requirements in the markets where claims appear. |
> Cross-references: ISO 14020:2022 Cl.5; ISO 14021:2016 Cl.1; GreenDesk Regulatory Reference Library |
Req. | 5.1.2 — Claims context mapping |
The organisation shall identify all markets and channels in which environmental claims appear and the applicable regulatory frameworks for each. This mapping shall be documented and reviewed at least annually and following any material change to the organisation's markets, products, or channels. |
> Cross-references: ISO 14021:2016 Cl.5.7(r); SPK GCMS3001:2026 Cl.8; GreenDesk Regulatory Reference Library |
Req. | 5.1.3 — Interested parties |
The organisation shall identify the parties with an interest in its environmental claims, including consumers, procurement teams, investors, regulators, and NGOs, and understand their expectations and requirements relevant to the claims. |
> Cross-references: ISO 14020:2022 Cl.4.9; ISO 14021:2016 Cl.5.7 |
5.2 Scope of the Green Claims Management System
Req. | 5.2.1 — GCMS scope definition |
|---|
The organisation shall define the scope of its Green Claims Management System. The scope shall identify the organisational boundaries covered, the products, services, and operations included, the markets and channels in scope, and the categories of environmental claims within scope. The scope shall be documented and available to interested parties upon request. |
> Cross-references: ISO 14020:2022 Cl.6.1.2; ISO 14021:2016 Cl.1 |
Req. | 5.2.2 — Scope completeness |
The organisation shall ensure that all environmental claims made by the organisation within the defined scope are covered by the GCMS. Environmental claims that fall within the organisation's activities but are excluded from the GCMS scope shall be identified and the reason for exclusion documented. |
> Cross-references: ISO 14021:2016 Cl.5.7(b); ISO 14020:2022 Cl.6 |
5.3 The Green Claims Management System
Req. | 5.3.1 — Establishing the GCMS |
|---|
The organisation shall establish, document, implement, maintain, and continually improve a Green Claims Management System in accordance with the requirements of this standard. |
> Cross-references: ISO 14020:2022 Cl.6; ISO 14021:2016 Cl.6.1 |
6. Leadership
6.1 Governing Body Accountability
Req. | 6.1.1 — Governing body accountability |
|---|
The organisation shall ensure that the governing body is accountable for the organisation's Green Claims Management System and for the accuracy of the organisation's environmental claims. The governing body shall receive a report on the performance of the GCMS at least annually, including the status of active claims, material nonconformities, and corrective actions. |
> Cross-references: ISO 14020:2022 Cl.4.2; ISO 14021:2016 Cl.6.1 |
Req. | 6.1.2 — Governing body approval of GCMS policy |
The organisation shall ensure that the governing body approves the organisation's Green Claims Policy established under Clause 6.2 and receives reports on any material changes to that policy. |
> Cross-references: ISO 14021:2016 Cl.5.7(b); ISO 14020:2022 Cl.4.2 |
6.2 Green Claims Policy
Req. | 6.2.1 — Establishing the Green Claims Policy |
|---|
The organisation shall establish, document, and maintain a Green Claims Policy. The policy shall state the organisation's commitment to making only accurate, substantiated, and current environmental claims; require pre-publication review of all environmental claims before first use; define the organisation's commitment to compliance with ISO 14021:2016, ISO 14020:2022, and the applicable regulatory frameworks; and commit to continual improvement of the GCMS. |
> Cross-references: ISO 14020:2022 Cl.4.2; ISO 14021:2016 Cl.5.7(b) |
Req. | 6.2.2 — Policy availability and communication |
The organisation shall make the Green Claims Policy available to interested parties and communicate it to all persons in the organisation involved in making, approving, or maintaining environmental claims. |
> Cross-references: ISO 14020:2022 Cl.4.4; ISO 14021:2016 Cl.6.1 |
6.3 Roles, Responsibilities, and Authorities
Req. | 6.3.1 — GCMS owner |
|---|
The organisation shall appoint a GCMS owner — an individual or function responsible for maintaining the GCMS, overseeing the claims inventory, coordinating pre-publication reviews, and reporting to top management on GCMS performance. The GCMS owner shall have the authority and resources to fulfil this role. |
> Cross-references: ISO 14021:2016 Cl.6.1; ISO 14020:2022 Cl.6 |
Req. | 6.3.2 — Claim owners |
The organisation shall assign a claim owner for each environmental claim in the claims inventory. The claim owner is responsible for maintaining the accuracy and currency of the claim and its evidence file, notifying the GCMS owner of material changes, and initiating evidence renewal before the evidence renewal date. |
> Cross-references: ISO 14021:2016 Cl.5.7(q); ISO 14021:2016 Cl.6.1 |
Req. | 6.3.3 — Pre-publication review authority |
The organisation shall define and document who has authority to approve environmental claims for publication. No environmental claim shall be published without documented approval from a person or function with this authority. Approval shall confirm that the pre-publication review required under Clause 9.3 has been completed. |
> Cross-references: ISO 14021:2016 Cl.5.7(b); ISO 14020:2022 Cl.6.1.2 |
7. Planning
7.1 Claims Risk Assessment
Req. | 7.1.1 — Claims risk assessment |
|---|
The organisation shall conduct and document a claims risk assessment identifying the risks associated with each category of environmental claims in its portfolio. The risk assessment shall consider the likelihood of a claim being inaccurate or misleading, the regulatory and enforcement exposure if a claim is non-compliant, and the consequence of non-compliance for the organisation. |
> Cross-references: ISO 14021:2016 Cl.5.7; SPK GCMS3001:2026; GreenDesk Regulatory Reference Library |
Req. | 7.1.2 — Risk-based prioritisation |
The organisation shall use the claims risk assessment to prioritise claims for pre-publication review and evidence renewal. Higher-risk claims shall receive more frequent review and more rigorous evidence standards than lower-risk claims. The risk-based prioritisation shall be documented and reviewed at least annually. |
> Cross-references: ISO 14020:2022 Cl.4.3; ISO 19011:2026 |
Req. | 7.1.3 — Regulatory monitoring |
The organisation shall establish and maintain a process for monitoring changes to the applicable regulatory frameworks in the markets where its claims appear. Changes to regulatory frameworks that affect the compliance of active claims shall trigger an immediate review of those claims. |
> Cross-references: ISO 14021:2016 Cl.5.7(q); GreenDesk Regulatory Reference Library |
7.2 Green Claims Objectives
Req. | 7.2.1 — Setting objectives |
|---|
The organisation shall establish measurable objectives for its GCMS consistent with the Green Claims Policy. Objectives shall address, at a minimum: the proportion of active claims that have current evidence files; the proportion of pre-publication reviews completed before first use; and the number of material nonconformities identified and resolved within defined timeframes. |
> Cross-references: ISO 14020:2022 Cl.4.7; ISO 14021:2016 Cl.5.7(q) |
Req. | 7.2.2 — Objectives planning |
The organisation shall determine what will be done, what resources are required, who will be responsible, when it will be completed, and how results will be evaluated for each GCMS objective. Objectives shall be documented and reviewed at each management review. |
> Cross-references: ISO 14020:2022 Cl.4.7 |
8. Support
8.1 Resources
Req. | 8.1.1 — Resource provision |
|---|
The organisation shall provide the resources necessary to establish, implement, maintain, and continually improve the GCMS. Resources include personnel, technology, evidence management systems, and access to legal and technical expertise in environmental claims. |
> Cross-references: ISO 14021:2016 Cl.6.1; ISO 14020:2022 Cl.6 |
8.2 Competence
Req. | 8.2.1 — Competence requirements |
|---|
The organisation shall determine the competence required for persons performing work under the GCMS that affects the accuracy and quality of its environmental claims. Required competence includes: knowledge of ISO 14021:2016 requirements; familiarity with the applicable regulatory frameworks; understanding of the evidence requirements for the claim types used by the organisation; and the ability to assess evidence quality. |
> Cross-references: ISO 14021:2016 Cl.6.1; ISO 14020:2022 Cl.4.3 |
Req. | 8.2.2 — Competence assurance |
The organisation shall ensure that persons performing work under the GCMS are competent on the basis of appropriate education, training, or experience, and retain documented evidence of competence. |
> Cross-references: ISO 14021:2016 Cl.6.1 |
8.3 Awareness
Req. | 8.3.1 — Awareness programme |
|---|
The organisation shall ensure that persons involved in making, approving, or maintaining environmental claims are aware of: the Green Claims Policy; their roles and responsibilities under the GCMS; the requirements of ISO 14021:2016 relevant to their claims; the consequences of making inaccurate or non-compliant environmental claims; and how to report concerns about the accuracy of claims. |
> Cross-references: ISO 14021:2016 Cl.5.7; ISO 14020:2022 Cl.4.2 |
8.4 Documented Information
Req. | 8.4.1 — Required documented information |
|---|
The organisation shall create, maintain, and control the following documented information as a minimum: the Green Claims Policy; the scope of the GCMS; the claims inventory required under Clause 9.1; evidence files for all active claims; pre-publication review records; the claims risk assessment; GCMS objectives and their status; internal audit reports; management review records; and records of corrective actions. |
> Cross-references: ISO 14021:2016 Cl.6.5.3; ISO 14020:2022 Cl.6 |
Req. | 8.4.2 — Document control |
The organisation shall ensure that documented information required by the GCMS is available and suitable for use where and when needed; protected from loss of confidentiality, improper use, or loss of integrity; retained for a period sufficient to demonstrate conformity to this standard and to ISO 14021:2016, and for a period after a claim is discontinued that enables verification of its accuracy during the period it was active. Minimum retention: five years. |
> Cross-references: ISO 14021:2016 Cl.6.2.2; ISO 14021:2016 Cl.6.5.3 |
9. Operation
Section 9 contains the operational requirements of the GCMS. These are the specific controls that the organisation must implement to ensure that its environmental claims are accurate, substantiated, and maintained over time.
9.1 Claims Inventory
Req. | 9.1.1 — Establishing the claims inventory |
|---|
The organisation shall establish and maintain a claims inventory — a complete register of all environmental claims made by the organisation within the scope of the GCMS. The claims inventory shall include every claim across every product, service, operation, channel, and market where claims appear. It shall not be limited to primary packaging claims. |
> Cross-references: ISO 14021:2016 Cl.5.7; ISO 14020:2022 Cl.6.1.2 |
Req. | 9.1.2 — Claims inventory content |
The organisation shall ensure that the claims inventory records, as a minimum for each active claim: the exact claim text or description; the ISO 14021:2016 category of the claim (or 'general' where no Clause 7 category applies); the product, service, or operation to which the claim applies; all channels and markets where the claim appears; the claim owner; the date the claim was first used; the evidence renewal date; and the status of the claim (active, under review, suspended, or discontinued). |
> Cross-references: ISO 14021:2016 Cl.6.5.3; ISO 14020:2022 Cl.6.1.2 |
Req. | 9.1.3 — Claims inventory maintenance |
The organisation shall review and update the claims inventory at a minimum of every 12 months and immediately upon: the introduction of a new environmental claim; a material change to an existing claim's text, scope, channel, or market; the discontinuation of a claim; or a material change to a product, service, or operation to which an active claim applies. |
> Cross-references: ISO 14021:2016 Cl.5.7(q) |
9.2 Evidence Management
Req. | 9.2.1 — Evidence file requirement |
|---|
The organisation shall establish and maintain an evidence file for every active environmental claim in its claims inventory. The evidence file shall contain all documentation required to demonstrate conformity of the claim with ISO 14021:2016 and compliance with the applicable regulatory frameworks, without access to confidential business information. |
> Cross-references: ISO 14021:2016 Cl.6.5.1; ISO 14021:2016 Cl.6.5.3 |
Req. | 9.2.2 — Evidence file minimum content |
The organisation shall ensure that every evidence file contains, as a minimum: the claim text or description as it appears in the market; the ISO 14021:2016 clause(s) applicable to the claim; the evidence base for each applicable clause, including the methodology used; the source and date of each piece of evidence; the evidence renewal date for each piece of evidence; the identity of the expert or body that produced or validated the evidence; and a confirmation that the evidence enables verification without access to confidential business information. |
> Cross-references: ISO 14021:2016 Cl.6.5.1; ISO 14021:2016 Cl.6.5.3; ISO 14021:2016 Cl.6.4 |
Req. | 9.2.3 — Evidence currency |
The organisation shall ensure that evidence files reflect the claim as it is currently made, for the product as it is currently formulated and sold. Evidence that predates a material change to the product, supply chain, or manufacturing process is stale and shall not be treated as current substantiation. An evidence renewal date shall be assigned to every evidence file, being the earlier of: the expiry of the most constrained evidence element; or 12 months from the date of the most recent evidence assessment. |
> Cross-references: ISO 14021:2016 Cl.5.7(q); ISO 14021:2016 Cl.6.2.2 |
Req. | 9.2.4 — Evidence quality standard |
The organisation shall use only evidence that is competent and reliable: based on the expertise of professionals in the relevant field; produced objectively by persons qualified to do so and without conflict of interest; and using procedures generally accepted in the relevant professional field to yield accurate and reliable results. Supplier declarations without independent verification are not competent and reliable evidence for the purposes of this standard. |
> Cross-references: ISO 14021:2016 Cl.6.4; SPK GCMS3001:2026 Cl.7 |
Req. | 9.2.5 — Verifiability |
The organisation shall ensure that every active environmental claim can be verified without access to confidential business information. Where evidence supporting a claim cannot be disclosed to a third party without revealing confidential business information, the claim shall not be made until the evidence can be presented in a verifiable form. |
> Cross-references: ISO 14021:2016 Cl.6.5.1 |
9.3 Pre-Publication Review
Req. | 9.3.1 — Pre-publication review requirement |
|---|
The organisation shall subject every environmental claim to a pre-publication review before first use in any external communication. The pre-publication review shall assess the claim against ISO 14021:2016, the applicable regulatory frameworks, and the requirements of this standard. Evidence must exist and be documented before the pre-publication review is conducted. Evidence assembled after a claim is published does not satisfy the pre-publication review requirement. |
> Cross-references: ISO 14021:2016 Cl.5.7(b); ISO 14021:2016 Cl.6.1; ISO 14020:2022 Cl.6 |
Req. | 9.3.2 — Pre-publication review scope |
The organisation shall ensure that the pre-publication review of each claim assesses, as a minimum: conformity with all applicable ISO 14021:2016 general requirements (Clauses 5 and 6); conformity with the specific requirements for the relevant Clause 7 category; compliance with the applicable regulatory framework of every market and channel where the claim will appear; the net impression the claim creates for a reasonable consumer or investor in the target market; and the adequacy of any disclaimers or qualifications. |
> Cross-references: ISO 14021:2016 Cl.5 through 7; SPK GCMS3001:2026; GreenDesk Regulatory Reference Library |
Req. | 9.3.3 — Pre-publication review records |
The organisation shall document the outcome of every pre-publication review, including: the claim reviewed; the date of review; the reviewer; the assessment against each applicable standard and regulatory requirement; any modifications required and the basis for those modifications; and the approval decision. Pre-publication review records shall be retained in the evidence file for the relevant claim. |
> Cross-references: ISO 14021:2016 Cl.6.5.3; ISO 14020:2022 Cl.6 |
Req. | 9.3.4 — External pre-publication review |
The organisation shall engage an independent third party accredited for environmental claims assessment to conduct pre-publication review for claims categorised as high-risk under the claims risk assessment, or for any claim that will appear in the European Union on or after 27 September 2026. The organisation should seek to use the Speeki GreenDesk® service for this purpose, or another service operating under a comparable published assessment standard. |
> Cross-references: EU Directive (EU) 2024/825 (EmpCo) Art.10; ISO 17029:2019; SPK GCMS3001:2026 |
9.4 Claims Change and Material Change Controls
Req. | 9.4.1 — Change notification |
|---|
The organisation shall implement a process by which any person aware of a material change to a product, supply chain, market, regulatory requirement, or channel that affects an active environmental claim notifies the claim owner without delay. |
> Cross-references: ISO 14021:2016 Cl.5.7(q) |
Req. | 9.4.2 — Material change response |
The organisation shall immediately assess the impact of a material change on all affected active claims and take one of the following actions: update the evidence file and conduct a new pre-publication review before continuing to use the claim; suspend the claim pending updated evidence and review; or discontinue the claim. The claim shall not continue to be used in its prior form following a material change until a new pre-publication review confirms its continuing accuracy. |
> Cross-references: ISO 14021:2016 Cl.5.7(q); ISO 14021:2016 Cl.6.2.2 |
Req. | 9.4.3 — New claims process |
The organisation shall ensure that no new environmental claim is introduced without completion of the pre-publication review process required under Clause 9.3. Proposed claims shall not be communicated to external parties, including in draft marketing materials shared with external agencies, prior to completion of the pre-publication review. |
> Cross-references: ISO 14021:2016 Cl.5.7(b); ISO 14021:2016 Cl.6.1 |
9.5 Evidence Renewal Programme
Req. | 9.5.1 — Renewal tracking |
|---|
The organisation shall maintain a system for tracking the evidence renewal date of every active claim and generating alerts to the relevant claim owner at a minimum of 90, 60, and 30 days before the evidence renewal date. |
> Cross-references: ISO 14021:2016 Cl.5.7(q); ISO 14021:2016 Cl.6.2.2 |
Req. | 9.5.2 — Renewal completion |
The organisation shall complete the evidence renewal and pre-publication review for every active claim before the evidence renewal date. A claim for which the evidence has not been renewed by the evidence renewal date shall be suspended from use until renewal is complete. |
> Cross-references: ISO 14021:2016 Cl.5.7(q) |
9.6 Supply Chain Claims
Req. | 9.6.1 — Supply chain claim verification |
|---|
The organisation shall take reasonable steps to independently verify any environmental claim that relies on attributes of the supply chain before using that claim. Reliance on a supplier's own declaration without independent verification does not constitute adequate substantiation for a supply chain claim. |
> Cross-references: ISO 14021:2016 Cl.6.5.3; UK CMA Supply Chain Guidance (Jan 2026); ISO 14021:2016 Cl.5.7(b) |
Req. | 9.6.2 — Chain of custody |
The organisation shall obtain chain of custody documentation for any claim involving the specific origin, source, or processing of materials. Chain of custody documentation shall be from an independent certification body and shall cover the specific material in the specific volume being claimed. |
> Cross-references: ISO 14021:2016 Cl.7.8; SPK GCMS3001:2026 Cl.7 |
9.7 Organisation-Level Claims
Req. | 9.7.1 — Net zero and future commitment claims |
|---|
The organisation shall ensure that any organisation-level claim of a net zero target, carbon neutrality commitment, or other future environmental performance commitment: is based on documented reasonable grounds existing at the time the claim is made; includes disclosed assumptions; acknowledges the uncertainty inherent in long-term projections; is supported by a specific, time-bound implementation plan with measurable interim targets; and clearly distinguishes a future commitment from a current achievement. |
> Cross-references: ACCR v Santos, Federal Court of Australia, 17 Feb 2026; EU Directive (EU) 2024/825 Art.6(2)(d); ISO 14021:2016 Cl.5.7 |
Req. | 9.7.2 — Organisation-level claim substantiation |
The organisation shall apply the same pre-publication review process required under Clause 9.3 to organisation-level environmental claims that appear in consumer-facing or investor-facing communications, including claims excerpted from CSRD sustainability reports used in marketing communications. |
> Cross-references: ISO 14020:2022 Cl.6; EU Directive (EU) 2024/825; GreenDesk Regulatory Reference Library |
10. Performance Evaluation
10.1 Monitoring and Measurement
Req. | 10.1.1 — Performance monitoring |
|---|
The organisation shall establish and implement a process for monitoring and measuring the performance of the GCMS. Monitoring shall include, at a minimum: the proportion of active claims with current evidence files; the proportion of pre-publication reviews completed before first use; the number and age of claims with overdue evidence renewal; the number of material nonconformities identified; and the time taken to resolve corrective actions. |
> Cross-references: ISO 14021:2016 Cl.5.7(q); ISO 14020:2022 Cl.4.7 |
Req. | 10.1.2 — Claims health check |
The organisation shall conduct a claims health check across the full claims inventory at least annually. The health check shall assess whether each active claim has a current evidence file, whether the evidence file has been reviewed since any material change, whether the evidence renewal date has passed, and whether the claim is consistent with the organisation's current regulatory obligations in each market where it appears. The results shall be documented and reported to the GCMS owner. |
> Cross-references: ISO 14021:2016 Cl.5.7(q); ISO 14021:2016 Cl.6.2.2 |
10.2 Internal Audit
Req. | 10.2.1 — Internal audit programme |
|---|
The organisation shall plan, establish, implement, and maintain an audit programme for the GCMS. The audit programme shall define the frequency, methods, responsibilities, planning requirements, and reporting for audits. The frequency of internal audits shall reflect the complexity of the GCMS and the risk level of the claims portfolio. The minimum audit frequency is once per year. |
> Cross-references: ISO 19011:2026; ISO 14020:2022 Cl.6 |
Req. | 10.2.2 — Internal audit conduct |
The organisation shall conduct internal audits that assess whether the GCMS conforms to this standard and to ISO 14021:2016, and whether the GCMS is effectively implemented and maintained. Auditors shall be selected to ensure objectivity and impartiality. Persons shall not audit their own work. |
> Cross-references: ISO 19011:2026; ISO 14021:2016 Cl.6 |
Req. | 10.2.3 — Audit results and actions |
The organisation shall document audit results and report them to relevant management. Nonconformities identified in internal audits shall be subject to corrective action under Clause 11.2. Evidence of corrective actions taken shall be retained. |
> Cross-references: ISO 19011:2026 |
10.3 Management Review
Req. | 10.3.1 — Management review |
|---|
The organisation shall conduct a management review of the GCMS at planned intervals, at a minimum annually. The review shall be conducted by top management and shall assess the continuing suitability, adequacy, and effectiveness of the GCMS. Input to the management review shall include: the status of actions from previous reviews; changes in external and internal issues relevant to the GCMS; GCMS performance data; results of internal audits; customer and regulator feedback; material nonconformities and the status of corrective actions; and opportunities for improvement. |
> Cross-references: ISO 14020:2022 Cl.4.7; ISO 14021:2016 Cl.6.2 |
Req. | 10.3.2 — Management review outputs |
The organisation shall document the outputs of management reviews, including decisions and actions relating to GCMS improvement, resource needs, and any changes required to the Green Claims Policy or GCMS scope. Management review records shall be retained. |
> Cross-references: ISO 14020:2022 Cl.4.7 |
11. Improvement
11.1 Continual Improvement
Req. | 11.1.1 — Continual improvement commitment |
|---|
The organisation shall continually improve the suitability, adequacy, and effectiveness of the GCMS. Opportunities for improvement shall be identified through internal audits, management reviews, claims health checks, regulatory monitoring, and the corrective action process. |
> Cross-references: ISO 14020:2022 Cl.4.7; ISO 14021:2016 Cl.5.7(q) |
11.2 Nonconformity and Corrective Action
Req. | 11.2.1 — Responding to nonconformity |
|---|
The organisation shall when a nonconformity occurs — including identification of a claim that does not meet the requirements of ISO 14021:2016 or the applicable regulatory frameworks — take action to control and correct the nonconformity; assess whether the same nonconformity exists in other claims; and suspend or withdraw any non-conforming claim from use until corrective action is complete. |
> Cross-references: ISO 14021:2016 Cl.5.7; ISO 14020:2022 Cl.4.2 |
Req. | 11.2.2 — Root cause and corrective action |
The organisation shall determine the root cause of the nonconformity; evaluate what action is needed to prevent recurrence; implement corrective action; review the effectiveness of the action taken; and update the GCMS as necessary. Documented information on the nonconformity and corrective action shall be retained. |
> Cross-references: ISO 19011:2026 |
12. Leverage — Certification, Reporting and External Assurance
This section addresses how the organisation maximises the value of its GCMS through certification, external assurance, and integration with reporting and procurement programmes. Certification under this section is distinct from, and does not replace, individual claim assessments conducted under SPK GCMS3001:2026.
12.1 Speeki Verdant™ Certification
Req. | 12.1.1 — Certification audit |
|---|
The organisation shall submit the GCMS to an external conformity assessment audit by Speeki against SPK GCMS3000:2026 to obtain Speeki Verdant™ certification. The audit shall be conducted in accordance with Annex B of this standard and with ISO 19011:2026. The organisation shall provide Speeki auditors with access to all documented information, processes, and personnel required to assess conformity. |
> Cross-references: ISO 19011:2026; Annex B |
Req. | 12.1.2 — Certification maintenance |
The organisation shall maintain conformity with this standard between certification audits. Speeki Verdant™ certification is valid for three years from the date of issue, subject to satisfactory surveillance audits at 12 and 24 months. The organisation shall notify Speeki of any material change to the scope or operation of the GCMS between audits. |
> Cross-references: ISO 19011:2026; Annex B |
12.2 External Claims Assurance
Req. | 12.2.1 — External claim review |
|---|
The organisation shall engage the Speeki GreenDesk® service or another service operating under SPK GCMS3001:2026 or a comparable published assessment standard to conduct external pre-publication review and individual claim certification for claims categorised as high-risk under the claims risk assessment, and for all claims appearing in the European Union on or after 27 September 2026. |
> Cross-references: EU Directive (EU) 2024/825; SPK GCMS3001:2026; ISO 17029:2019 |
12.3 Integration with Sustainability Reporting
Req. | 12.3.1 — Consistency with sustainability disclosures |
|---|
The organisation shall ensure that environmental claims made in consumer-facing or investor-facing marketing communications are consistent with the organisation's sustainability disclosures in annual reports, CSRD reports, and ISSB-aligned disclosures. Inconsistency between a marketing claim and a sustainability disclosure is a material nonconformity under this standard. |
> Cross-references: ISO 14020:2022 Cl.4.4; EU Directive (EU) 2024/825; GreenDesk Regulatory Reference Library |
ANNEX A — Guidance on Intent (Normative)
This Annex is normative but contains recommendations, not mandatory requirements. Text in this Annex uses 'should' (not 'shall'). Departure from this guidance is not a nonconformity and auditors shall not treat it as such. The guidance in this Annex is provided to assist organisations in implementing the requirements of Sections 5 through 12 effectively.
A.1 Guidance on the Claims Inventory (Clause 9.1)
The claims inventory should be maintained in a centralised system accessible to all claim owners. Organisations should begin with a comprehensive audit of all channels — packaging, websites, social media profiles, advertising archives, procurement response templates, executive communication templates, investor materials, and trade show materials — to ensure the inventory is complete. The most common gap in claims inventories is claims embedded in standard marketing copy that have never been formally identified as environmental claims.
A.2 Guidance on Evidence Quality (Clause 9.2.4)
The competent and reliable evidence standard should be applied using three questions: (1) Was the evidence produced by an expert in the relevant field? (2) Was it produced without a conflict of interest in the outcome? (3) Does it use a methodology recognised in the relevant professional field? Supplier marketing materials, internal management representations, and consultant reports produced for commercial purposes typically fail one or more of these tests and should not be treated as standalone substantiation.
A.3 Guidance on Pre-Publication Review (Clause 9.3)
The pre-publication review should be completed before any draft containing the claim is shared externally, including with advertising agencies and design firms. Sharing a draft claim externally before review creates a risk that the claim will be used in derivative materials before review is complete. The review record should be signed by the reviewer and retained in the evidence file even where the outcome is approval without modification, as the signed record demonstrates that the review was conducted before first use.
A.4 Guidance on Organisation-Level Claims (Clause 9.7)
Net zero and carbon neutrality commitments made in investor-facing communications should be reviewed by the legal and governance function before publication, in addition to the GCMS pre-publication review. The Santos judgment (ACCR v Santos, Federal Court of Australia, 17 February 2026) establishes that the key question is whether the organisation had documented reasonable grounds for the commitment at the time it was made. Documenting the evidence base and assumptions for future-state claims at the time of publication, rather than reconstructing them later, is the most defensible approach.
A.5 Guidance on High-Risk Claims
The following claim categories should be categorised as high-risk in the claims risk assessment, requiring external pre-publication review under Clause 9.3.4: carbon neutral and net zero claims; recyclability claims in markets where infrastructure acceptance has changed recently; origin claims for recycled content (ocean plastic, ocean bound, post-consumer); compostability claims for products with complex material compositions; and all environmental claims in the European Union on or after 27 September 2026.
Annex B — Speeki Verdant™ Certification (Normative)
This Annex specifies the certification process for Speeki Verdant™ certification against SPK GCMS3000:2026. It is normative. Speeki conducts Speeki Verdant™ certification audits in accordance with ISO 19011:2026.
B.1 Certification Scope
Speeki Verdant™ certification confirms that the organisation's Green Claims Management System has been independently audited by Speeki and found to conform to all requirements of SPK GCMS3000:2026. The certification is of the management system — not of individual claims. Individual claim conformity and compliance is established through the Speeki GreenDesk® service under SPK GCMS3001:2026.
B.2 Certification Statement
The Speeki Verdant™ certificate carries the following statement:
[Organisation name] has been awarded Speeki Verdant™ certification by Speeki, following an independent audit of its Green Claims Management System against SPK GCMS3000:2026 (Green Claims Management System Standard, First Edition, 2026). This certification covers the management system operated by [Organisation name] within the scope defined on the reverse. It does not certify the accuracy of individual environmental claims.
B.3 Certification Validity
Speeki Verdant™ certification is valid for three years from the date of issue, subject to: a satisfactory Stage 1 surveillance audit at 12 months from initial certification; a satisfactory Stage 2 surveillance audit at 24 months from initial certification; and continued notification of material changes to the GCMS scope or operation. Certification is withdrawn if a surveillance audit reveals a critical nonconformity that is not remediated within the agreed correction period.
B.4 Relationship to Speeki GreenDesk®
Speeki Verdant™ (GCMS3000 certification) and Speeki GreenDesk® (GCMS3001 individual claim certification) are complementary services. An organisation may hold Speeki Verdant™ certification without using GreenDesk for individual claims, and may use GreenDesk without being Verdant-certified. However, an organisation that is Verdant-certified and uses GreenDesk for high-risk claim review has the most complete and defensible claims governance posture.
Annex C — Relationship to SPK GCMS3001:2026 (Informative)
This Annex is informative. It explains the relationship between SPK GCMS3000:2026 (this standard) and SPK GCMS3001:2026 (Green Claims Assessment and Certification Guidance).
Element | SPK GCMS3000:2026 |
|---|---|
What it governs | The organisation's internal Green Claims Management System — the programme through which claims are managed, substantiated, and maintained |
Who is certified | The organisation (its management system) |
The certificate | Speeki Verdant™ — awarded to the organisation |
Speeki's role | Auditor — assesses the organisation's GCMS against GCMS3000 |
Certification product | Speeki Verdant™ |
Analogy | ISO 14001 environmental management system certification |
An organisation certified under GCMS3000 has demonstrated that it operates a systematic, audited programme for managing its environmental claims. An individual claim assessed under GCMS3001 has been verified as conforming to ISO 14021:2016 and compliant with the applicable regulatory frameworks. Both certifications are independent and both are valuable. The combination provides the most complete governance posture.
Bibliography
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