Quick Read
SPK GCMS3001:2026 is Speeki’s normative companion standard to SPK GCMS3000:2026, setting out how individual environmental claims are assessed under Speeki GreenDesk®. It covers product-level and organisation-level claims, using a dual-layer assessment against ISO 14021, ISO 14020, applicable regulatory frameworks and advertising law methodology. Every assessment is conducted by Nicole, Speeki’s AI assessment engine, and reviewed and signed by a Speeki Expert before any GreenDesk® Determination Certificate is issued.
SPK GCMS3001:2026(E)
Copyright and Licensing Notice
© Speeki Pte Ltd 2026. All rights reserved.
Copyright
SPK GCMS3001:2026 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, or as permitted under the citation allowance below.
Citation Allowance
Notwithstanding the restrictions in this notice, SPK GCMS3001:2026 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 whose environmental claims are assessed under SPK GCMS3001:2026 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 submission, assessment, or governance of environmental claims under SPK GCMS3001:2026;
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 support claims assessed or to be assessed under this standard.
This licence is granted to the assessed 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 submitting claims for assessment under this standard.
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 environmental claims assessment methodology, determination service, or certification scheme.
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.
Assessment and Determination Rights
The right to assess individual environmental claims against, and to issue GreenDesk Determination Certificates under, SPK GCMS3001:2026 is reserved exclusively to Speeki Pte Ltd and to bodies that Speeki has formally authorised in writing to act as assessment providers under this standard.
An environmental claim assessed and determined under SPK GCMS3001:2026 is awarded a Speeki GreenDesk® Determination Certificate, issued by a Speeki Expert following review of the Nicole AI assessment engine's output under the HIITR (Human-In-The-Loop-To-Review) model. Such a determination attests to the conformity of the specific claim assessed with the applicable requirements of ISO 14021:2016, ISO 14020:2022, the relevant regulatory frameworks, and the advertising law assessment methodology set out in this standard. It does not constitute certification of the organisation's overall Green Claims Management System under SPK GCMS3000:2026.
No organisation, body, or individual may:
issue GreenDesk Determination Certificates, determination letters, compliance statements, or equivalent recognition documents under SPK GCMS3001:2026;
conduct SPK GCMS3001:2026 claim assessments or purport to apply its methodology in a third-party assessment; or
represent to any third party that an environmental claim has been assessed against or found conformant with SPK GCMS3001:2026,
without written authorisation from Speeki. Any certificate, report, or claim purporting to demonstrate a SPK GCMS3001:2026 determination 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 an assessment provider, 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
SPK GCMS3001:2026 is the normative companion to SPK GCMS3000:2026. Where GCMS3000 specifies the requirements for the Green Claims Management System an organisation must operate, GCMS3001 specifies the requirements for how Speeki assesses individual environmental claims and issues GreenDesk Determination Certificates under the Speeki GreenDesk® service.
The need for a published assessment methodology is not administrative. An assessment of an environmental claim carries weight — with regulators, procurement teams, boards, and courts — only if the methodology behind it is transparent, reproducible, and grounded in the applicable standards and frameworks. A signed determination without a published methodology is an opinion. A signed determination under a published, versioned, normative standard is a professional assessment that can be examined, defended, and relied upon.
GCMS3001 draws its technical content from three bodies of doctrine. First, ISO 14021:2016 and ISO 14020:2022 — the international standards that define what environmental claims must demonstrate and on what basis. Second, the applicable regulatory frameworks of the jurisdictions in which claims appear, maintained in the GreenDesk Regulatory Reference Library and incorporated by reference. Third, the advertising law methodology developed across fifty years of pharmaceutical and consumer product claims review — principally the FTC Advertising Substantiation doctrine, the National Advertising Division (NAD) methodology, the UK ASA/CAP framework, and the EFSA health claims evaluation model. These fields are structurally analogous to green claims review: a party makes an objective claim about a product to consumers; that claim must be substantiated before publication; an independent body assesses whether the evidence is adequate.
Every assessment under GCMS3001 is conducted by Nicole — Speeki’s AI assessment engine — and reviewed and signed by a Speeki Expert before any determination is issued. No AI-only determinations are issued under this standard. The HIITR (Human-In-The-Loop-To-Review) model is a non-negotiable structural requirement of this standard.
GCMS3001 is designed in accordance with the principles of ISO 17029:2019.
1. Scope
SPK GCMS3001:2026 specifies the requirements for the assessment of individual environmental claims and the issuance of GreenDesk Determination Certificates by Speeki under the Speeki GreenDesk® service.
This standard governs every assessment conducted by Speeki of an environmental claim about a product, product component, packaging, service, operation, or organisational commitment, regardless of the claim type, jurisdiction, or channel.
This standard applies to both categories of environmental claim:
Product-level claims: self-declared claims about the environmental attributes of a specific product, product component, or packaging, governed principally by ISO 14021:2016 and ISO 14020:2022.
Organisation-level claims: claims about an organisation’s own environmental performance, targets, or commitments — including net zero targets, carbon neutrality commitments, and sustainability claims used in consumer-facing or investor-facing communications — governed by the applicable regulatory frameworks and the advertising law methodology in Annex C.
This standard does not apply to Type I environmental labels (ISO 14024) or Environmental Product Declarations (ISO 14025), which require separate conformity assessment processes.
This standard is designed in accordance with the principles of ISO 17029:2019.
2. Normative References
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 and Amendment 1. |
ISO/TS 14067:2018 | Greenhouse gases — Carbon footprint of products — Requirements and guidelines for quantification. Required methodology for carbon footprint claims. |
ISO 14040:2006 / ISO 14044:2006 | Life cycle assessment — Principles, framework, requirements and guidelines. Referenced for lifecycle-based environmental claims. |
ISO 17029:2019 | Conformity assessment — General principles and requirements for validation and verification bodies. The conformity assessment standard in accordance with which this standard is designed. |
SPK GCMS3000:2026 | Green Claims Management System Standard. The companion management system standard. Organisations operating a GCMS certified under GCMS3000 may submit claims under GCMS3001 through 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
Term | Definition |
|---|---|
Claimant | The organisation that submits an environmental claim for assessment under this standard. |
Environmental claim | Any statement, symbol, or graphic that indicates an environmental aspect of a product, service, operation, or organisational commitment. Includes express, implied, establishment, comparative, and monadic claims. |
Express claim | A direct, explicit statement of a specific environmental attribute, stated in words. |
Implied claim | An environmental claim conveyed indirectly through language, imagery, context, or overall presentation, without being explicitly stated in words. |
Establishment claim | A claim that expressly represents that the claimant has a specific level of independent substantiation or certification for the environmental attribute claimed. |
Comparative claim | A claim asserting that the product’s environmental performance is better than, or different from, a defined comparator. |
Monadic claim | A non-comparative performance claim about the product’s own environmental performance (e.g. ‘up to 40% less’, ‘at least 30%’). |
Net impression | The overall understanding that a reasonable consumer or investor in the relevant target market would form from the claim as a whole, taking into account all elements of the communication including headline text, body copy, imagery, symbols, colour, channel, and context. |
Substantiation | Evidence that is competent and reliable, current, specific to the product or organisation as claimed, and verifiable without access to confidential business information, that supports the claim as a reasonable consumer or investor would understand it. |
Competent and reliable evidence | Evidence that is: based on the expertise of professionals in the relevant field; produced and evaluated objectively by persons qualified to do so and without conflict of interest; and uses procedures generally accepted in the relevant professional field to yield accurate and reliable results. |
Nicole | Speeki’s AI assessment engine. Nicole conducts the initial assessment of every submission and prepares the preliminary determination for Expert review. |
Expert | A person appointed by Speeki who holds the qualifications, experience, and credentials to review Nicole’s assessment and sign a GreenDesk Determination Certificate. |
HIITR | Human-In-The-Loop-To-Review. The operating model under which Nicole conducts assessments and every determination is reviewed and signed by a Speeki Expert before issuance. No AI-only determinations are issued. |
Green determination | A determination that the claim as submitted conforms to all applicable ISO 14021:2016 requirements, complies with all applicable regulatory frameworks, meets the net impression standard, and is supported by adequate evidence. |
Amber determination | A determination that the claim would receive a Green determination if specified modifications are made. Modifications are stated precisely. |
Red determination | A determination that the claim as submitted does not conform to ISO 14021:2016 and/or does not comply with applicable regulatory requirements and/or does not meet this standard. Specific grounds are stated for each finding. |
GreenDesk Determination Certificate | The formal output of a Green or Amber determination: a signed certificate issued by a Speeki Expert under SPK GCMS3001:2026 confirming the determination and its basis. |
Evidence renewal date | The date by which the evidence supporting a Green or Amber determination must be renewed to remain current. The earlier of: the expiry of the most constrained evidence element; or 12 months from the determination date. |
HIITR AUTONOMOUS | The HIITR mode for routine assessments: Nicole prepares the full assessment and preliminary determination; Expert reviews and signs. |
HIITR NOTIFY | The HIITR mode for flagged assessments: Nicole raises a specific concern to the Expert before completing the preliminary determination. Expert judgment is sought before proceeding. |
HIITR ESCALATE | The HIITR mode for high-risk assessments: Nicole stops and requires Expert human judgment before any determination is prepared. Used for matters involving potential fraud risk, fundamental net impression failures, or matters with legal or regulatory implications beyond routine claims review. |
Shall | Mandatory requirement. Departure constitutes a nonconformity. |
Should | Recommendation, not mandatory. Annex A, B, C guidance only. Departure is not a nonconformity. |
4. How to Read This Standard
This standard governs Speeki’s conduct of assessments under Speeki GreenDesk®. Requirements in Sections 5 through 16 use ‘Speeki shall’ rather than ‘The organisation shall’ because these requirements bind Speeki as the assessment body, not the claimant.
Requirement numbering follows the same Clause.Requirement convention as SPK GCMS3000:2026. Req. 7.3.2 refers to Section 7 (The Assessment Sequence), Sub-clause 7.3 (Stage 3), Requirement 2.
‘Shall’ in Sections 5 through 16 is mandatory. ‘Should’ appears in Annexes only. Departure from Annex guidance is not a nonconformity and shall not be treated as such.
Annex C contains the advertising law assessment methodology — the claim type taxonomy, net impression doctrine, evidence quality scoring, and disclaimer adequacy standards drawn from the FTC, NAD, ASA/CAP, and EFSA frameworks. Annex C is normative: its requirements apply to every assessment.
Annex B sets out the applicable regulatory framework requirements. Annex B is normative: the regulatory requirements listed are mandatory inputs to Stage 6 of the assessment sequence.
5. General Principles
5.1 The Pre-Publication Principle
Req. | 5.1.1 — Assessment before publication |
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Speeki shall conduct assessments of environmental claims before those claims are published in any external communication. Evidence assembled after a claim has been published is not substantiation and does not satisfy the requirements of this standard or of ISO 14021:2016 Clause 5.7(b). Speeki shall not issue a Green or Amber determination for a claim that has been published without prior independent review. |
> Cross-references: ISO 14021:2016 Cl.5.7(b); ISO 14021:2016 Cl.6.1; ISO 14020:2022 Cl.6 |
5.2 The Consumer Understanding Principle
Req. | 5.2.1 — Net impression governs |
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Speeki shall assess every claim against the standard of what a reasonable consumer or investor in the stated target market would understand the claim to mean — the net impression — not against the literal meaning of the claim text alone or the claimant’s stated intent. A claim that is technically accurate but creates a misleading net impression is non-compliant regardless of the accuracy of its individual words. |
> Cross-references: ISO 14021:2016 Cl.5.7(a)(g)(k); Annex C Section C.2; ACCC v Clorox Australia Pty Ltd [2025] FCA 357 |
5.3 The Independence Principle
Req. | 5.3.1 — No advisory role |
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Speeki shall not advise claimants on what environmental claims to make. Speeki’s role is assessment of claims as submitted. A determination under this standard reflects independent assessment of the submitted claim. The independence of the assessment body from the commercial interests of the claimant is a structural requirement of this standard and of ISO 17029:2019. |
> Cross-references: ISO 17029:2019; SPK GCMS3000:2026 Cl.6 |
5.4 The Good Faith Principle
Req. | 5.4.1 — Good faith is not a defence |
|---|
Speeki shall apply an objective standard in every assessment. The claimant’s belief in the accuracy of its claim is not determinative. The applicable test — established by ISO 14021:2016 and confirmed in enforcement proceedings in every major jurisdiction — is whether the claim is accurate and adequately substantiated, not whether the claimant believed it to be so. |
> Cross-references: ISO 14021:2016 Cl.5.7; ACCC v Clorox Australia Pty Ltd [2025] FCA 357; ACL s.18 |
5.5 The Dual-Layer Assessment Principle
Req. | 5.5.1 — Both layers required |
|---|
Speeki shall conduct every assessment as a dual-layer assessment: Layer 1 assesses conformity with ISO 14021:2016 (and ISO/TS 14067:2018 where applicable) clause by clause; Layer 2 assesses compliance with the applicable regulatory frameworks in Annex B and the advertising law methodology in Annex C. Both layers are required for every assessment. A claim may fail Layer 2 even if it passes Layer 1. |
> Cross-references: ISO 14021:2016; ISO 14020:2022; Annex B; Annex C |
6. The Claim Submission
Req. | 6.1.1 — Required submission content |
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Speeki shall require every claimant submission to include, as a minimum: the exact claim text or description as it will appear in the market; the format of the claim (text, symbol, imagery, combination); the product, service, or operation to which the claim applies; all channels in which the claim will appear; all markets (jurisdictions) in which the claim will appear; the target audience; the supporting evidence file; and confirmation that the evidence was assembled before the claim was published or, for new claims, before first intended use. |
> Cross-references: ISO 14021:2016 Cl.6.5.3; ISO 14020:2022 Cl.6.1.2 |
Req. | 6.1.2 — Incomplete submissions |
Speeki shall identify and document any gaps in a submission before proceeding with the assessment. Where a gap affects a critical element of the assessment, Speeki shall issue a formal information request to the claimant before proceeding. The assessment clock does not run during the period a submission is incomplete pending the claimant’s response. |
> Cross-references: ISO 14021:2016 Cl.6.1 |
Req. | 6.1.3 — Confidentiality |
Speeki shall treat all claimant submissions and evidence files as confidential. Speeki shall not disclose claimant submission content or determination outcomes to third parties without the claimant’s consent, except as required by applicable law or regulatory authority. |
> Cross-references: ISO 17029:2019; SPK GCMS3000:2026 Cl.12 |
7. The Assessment Sequence
Every assessment under this standard follows a seven-stage sequence. Each stage has defined inputs, a defined process, and a defined output recorded in the assessment log. No stage may be omitted. The stages are completed in sequence; a finding at any stage does not terminate the assessment — all stages are completed to produce a complete assessment record for Expert review.
STAGE 1 — Claim Receipt and Classification
Req. | 7.1.1 — Claim receipt |
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Speeki shall record the exact claim text or description as submitted; assign a unique assessment reference number; record the submission date; and confirm receipt to the claimant within one business day. |
> Cross-references: ISO 17029:2019 |
Req. | 7.1.2 — ISO 14021 category identification |
Speeki shall identify the applicable ISO 14021:2016 Clause 7 category for the claim, or record ‘general claim’ where the claim does not fall within a specific Clause 7 category. The Clause 7 category determines which specific requirements apply in Stage 3. |
> Cross-references: ISO 14021:2016 Cl.7; Annex A |
Req. | 7.1.3 — Advertising law claim type classification |
Speeki shall classify the claim under the advertising law taxonomy in Annex C Section C.1: EXPRESS, IMPLIED, ESTABLISHMENT, COMPARATIVE, MONADIC, or PUFFERY, or a combination. The classification drives the substantiation requirements applied in subsequent stages. |
> Cross-references: Annex C Section C.1 |
Req. | 7.1.4 — Jurisdiction and channel identification |
Speeki shall identify every market and channel in which the claim will appear and load the applicable regulatory framework for each from the GreenDesk Regulatory Reference Library. Where the claim will appear in multiple jurisdictions with different requirements, each jurisdiction is assessed separately in Stage 6. |
> Cross-references: Annex B; GreenDesk Regulatory Reference Library |
STAGE 2 — Net Impression Assessment
Req. | 7.2.1 — Headline-only test |
|---|
Speeki shall assess the claim as if no qualifications, disclaimers, or footnotes were present. The headline claim — the primary text or symbol as a consumer’s eye would first encounter it — shall be assessed independently to determine what it asserts and what it implies. |
> Cross-references: ISO 14021:2016 Cl.5.7(g)(k)(m); Annex C Section C.2 |
Req. | 7.2.2 — Implied claim identification |
Speeki shall identify every implied claim created by the submission, including implied claims arising from: language patterns that reliably signal specific environmental attributes; described or depicted imagery; the channel and audience context; and the organisation’s broader brand positioning where described. Implied claims shall be assessed as fully as express claims. Annex C Section C.3 lists language patterns and imagery types that create implied claims. |
> Cross-references: ISO 14021:2016 Cl.5.7(a)(g)(k); Annex C Section C.3 |
Req. | 7.2.3 — Omitted information assessment |
Speeki shall identify any material information that a reasonable consumer or investor in the target market would expect to be disclosed alongside the claim, and whose omission creates a misleading net impression. ISO 14021:2016 Clause 5.7(k) prohibits claims that are literally true but misleading by omission of relevant facts. |
> Cross-references: ISO 14021:2016 Cl.5.7(k) |
Req. | 7.2.4 — Net impression finding |
Speeki shall record a net impression finding for every assessment: either ‘no net impression issue identified’ or a specific description of the misleading impression, what it implies, and what evidence would be required to substantiate the implied claim. A net impression finding is recorded as a separate finding in the assessment, in addition to any ISO 14021 non-conformity. |
> Cross-references: ISO 14021:2016 Cl.5.7(g); Annex C Section C.2 |
STAGE 3 — ISO 14021:2016 Clause-by-Clause Assessment
Req. | 7.3.1 — General requirements assessment |
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Speeki shall assess the claim against all applicable ISO 14021:2016 general requirements in Clauses 5.3 through 5.10, including the 17 specific requirements of Clause 5.7. Each applicable clause shall be recorded with a finding of PASS, FAIL, WARNING, PENDING, or NOT APPLICABLE, and a specific clause-cited note. |
> Cross-references: ISO 14021:2016 Cl.5; Annex A |
Req. | 7.3.2 — Specific claim type requirements assessment |
Speeki shall assess the claim against the specific requirements of the applicable ISO 14021:2016 Clause 7 category identified in Stage 1. Where the claim does not fall within a Clause 7 category, the general requirements in Clause 5 and the evaluation requirements in Clause 6 apply in full. |
> Cross-references: ISO 14021:2016 Cl.7; Annex A |
Req. | 7.3.3 — Evaluation and verification requirements assessment |
Speeki shall assess the claim against the evaluation and claim verification requirements of ISO 14021:2016 Clause 6, including: the claimant responsibility requirements of Clause 6.1; the comparative claims methodology of Clause 6.3 where applicable; the method selection requirements of Clause 6.4; and the verifiability requirement of Clause 6.5.1. |
> Cross-references: ISO 14021:2016 Cl.6 |
STAGE 4 — Evidence Quality Assessment
Req. | 7.4.1 — Evidence quality scoring |
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Speeki shall score every piece of evidence submitted against the three-part competent and reliable standard in Section 10. The score for each evidence item — STRONG, ADEQUATE, WEAK, or INSUFFICIENT — shall be recorded in the assessment log with the specific basis for the score. |
> Cross-references: Section 10; ISO 14021:2016 Cl.6.4; Annex C Section C.5 |
Req. | 7.4.2 — Currency assessment |
Speeki shall assess whether each piece of evidence reflects the claim as it is currently made, for the product as it is currently formulated and sold, in the markets currently stated. Evidence predating a material change to the product, supply chain, or market is stale and shall be scored INSUFFICIENT regardless of its nominal validity date. |
> Cross-references: ISO 14021:2016 Cl.5.7(q); ISO 14021:2016 Cl.6.2.2 |
Req. | 7.4.3 — Specificity assessment |
Speeki shall assess whether each piece of evidence applies to the specific product in its current specification, or whether it applies at a broader level. Evidence specificity shall be assessed against the hierarchy in Section 10.4. Supplier declarations without independent verification shall be scored INSUFFICIENT as standalone substantiation. |
> Cross-references: ISO 14021:2016 Cl.6.5.3; Annex C Section C.5.4 |
Req. | 7.4.4 — Verifiability assessment |
Speeki shall assess whether the claim can be verified by a third party without access to confidential business information, as required by ISO 14021:2016 Clause 6.5.1. Where evidence is commercially sensitive and cannot be disclosed in verifiable form, this constitutes a nonconformity with Clause 6.5.1 regardless of the strength of the underlying evidence. |
> Cross-references: ISO 14021:2016 Cl.6.5.1 |
Req. | 7.4.5 — Evidence gap identification |
Speeki shall identify every required element of the assessment for which no evidence has been submitted and record it as an evidence gap. Evidence gaps on critical elements shall trigger a formal information request before the preliminary determination is prepared. |
> Cross-references: ISO 14021:2016 Cl.6.5.3 |
STAGE 5 — Disclaimer Adequacy Assessment
Req. | 7.5.1 — Disclaimer adequacy |
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Speeki shall assess the adequacy of every qualifier, disclaimer, or explanatory statement accompanying the claim. The headline-only test shall be applied: if the headline creates a false impression without the disclaimer, the disclaimer is assessed for adequacy but does not automatically cure the non-conformity. The four-part adequacy test in Annex C Section C.6 shall be applied to every disclaimer. |
> Cross-references: ISO 14021:2016 Cl.5.7(m); Annex C Section C.6 |
Req. | 7.5.2 — Prohibited disclaimer formulations |
Speeki shall identify and record as a nonconformity any disclaimer that uses a formulation explicitly prohibited by ISO 14021:2016, including: ‘Recyclable where facilities exist’ (Clause 7.7.2(c)); ‘Compostable where facilities exist’ (Clause 7.2.2.4(c)); ‘Reusable/refillable where facilities exist’ (Clause 7.12.2.3(c)); and ‘Can be disassembled where facilities exist’ (Clause 7.4.2.4(c)). These formulations are non-compliant regardless of other qualifications present. |
> Cross-references: ISO 14021:2016 Cl.7.2.2.4(c); Cl.7.4.2.4(c); Cl.7.7.2(c); Cl.7.12.2.3(c) |
Req. | 7.5.3 — Mandatory disclosures check |
Speeki shall confirm that all mandatory disclosures required to appear on the claim itself are present. For carbon neutral claims, Clause 7.17.3.3 requires that the carbon footprint value, what has been offset, the offset scheme details, and consumer access information all appear on the claim — not only on a linked website. Absence of any mandatory disclosure is a nonconformity. |
> Cross-references: ISO 14021:2016 Cl.7.17.3.3; Annex C Section C.6.3 |
STAGE 6 — Regulatory Compliance Assessment
Req. | 7.6.1 — Jurisdiction-specific assessment |
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Speeki shall assess the claim against the applicable regulatory framework for every jurisdiction identified in Stage 1. The current requirements for each jurisdiction are set out in Annex B and maintained in the GreenDesk Regulatory Reference Library. Where regulatory requirements conflict across jurisdictions, the most stringent requirement governs the overall determination unless the claimant specifies that the claim will appear in different forms in different jurisdictions, in which case each version is assessed separately. |
> Cross-references: Annex B; GreenDesk Regulatory Reference Library |
Req. | 7.6.2 — Absolute prohibitions |
Speeki shall identify whether any absolute regulatory prohibition applies to the claim as submitted. Absolute prohibitions result in a Red determination regardless of the quality of the claimant’s evidence. The current list of absolute prohibitions is maintained in Annex B Section B.2. |
> Cross-references: Annex B Section B.2; EU Directive (EU) 2024/825 Annex I |
Req. | 7.6.3 — Regulatory findings |
Speeki shall record a specific finding for each jurisdiction in scope, stating whether the claim complies with the applicable framework, and citing the specific provision if it does not. |
> Cross-references: Annex B; GreenDesk Regulatory Reference Library |
STAGE 7 — Preliminary Determination and HIITR Assessment
Req. | 7.7.1 — Preliminary determination |
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Speeki shall formulate a preliminary determination — Green, Amber, or Red — drawing together all findings from Stages 1 through 6, with full written rationale meeting the requirements of Section 12. |
> Cross-references: Section 12 |
Req. | 7.7.2 — HIITR mode assessment |
Speeki shall assess the appropriate HIITR mode for the assessment: AUTONOMOUS, NOTIFY, or ESCALATE, based on the criteria in Section 15. The HIITR mode shall be recorded in the assessment log. |
> Cross-references: Section 15 |
Req. | 7.7.3 — Information request |
Speeki shall draft a formal information request for any evidence gap identified in Stage 4 that prevents completion of the preliminary determination. The information request shall cite the specific clause, the specific requirement, and the specific gap, and shall be sent to the claimant before the assessment is finalised. |
> Cross-references: ISO 14021:2016 Cl.6.5.3 |
8. The Claim Type Classification System
At Stage 1 of every assessment, the claim is classified under the advertising law taxonomy. The classification drives the substantiation requirements applied throughout the assessment. Full guidance on each claim type is in Annex C Section C.1.
Claim Type | Definition and Key Substantiation Consequence |
|---|---|
EXPRESS | A direct, explicit statement of a specific environmental attribute. Requires direct, specific, verifiable evidence of the exact stated fact for the product as currently marketed. |
IMPLIED | A claim conveyed indirectly through language, imagery, or context. Requires substantiation just as fully as an express claim. The net impression governs. All implied claims identified in Stage 2 are assessed as if they were express. |
ESTABLISHMENT | A claim that represents the claimant has a specific level of independent certification or verification. Requires evidence that the stated certification actually exists, is current, covers this specific product in its current form, and has the scope the claim implies. |
COMPARATIVE | A claim of relative environmental performance versus a comparator. Requires: current and appropriate comparator; identical functional unit; identical measurement methodology; statistical significance established; absolute and relative figures both available; product and packaging stated separately per ISO 14021:2016 Cl.6.3.5. |
MONADIC | A non-comparative performance claim (‘up to X%’, ‘at least Y%’). Requires evidence that the stated bound is achievable under realistic consumer conditions and that the ‘up to’ formulation is not misleading about the typical case. |
PUFFERY | A subjective statement no reasonable consumer treats as a factual claim. Does not require substantiation. NOTE: ISO 14021:2016 Clause 5.3 is stricter than general puffery doctrine. A statement qualifying as puffery in general advertising law may still be prohibited as a vague or non-specific claim under Clause 5.3. Where both apply, the stricter standard governs. |
9. The Net Impression Assessment
The net impression assessment is Stage 2 of every assessment. Full methodology is in Annex C Section C.2. This section sets out the mandatory protocol.
Req. | 9.1.1 — Six-question protocol |
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Speeki shall answer and record in the assessment log the following six questions for every claim assessed: (1) What does the headline claim assert, stripped of all qualifications and footnotes? (2) What does the headline claim imply, beyond what it literally states? (3) What does any described imagery or visual context imply? (4) What material information relevant to consumer or investor understanding is omitted? (5) Would a reasonable consumer or investor in the target market understand the claim to be making an accurate and specific environmental assertion? (6) Is the understanding a reasonable consumer or investor would form — based on the above — accurate? |
> Cross-references: ISO 14021:2016 Cl.5.7(a)(g)(k); Annex C Section C.2 |
Req. | 9.1.2 — Net impression failure consequences |
Speeki shall treat a negative answer to question 6 of the net impression protocol as a finding of misleading net impression, recorded separately in the assessment and contributing to an Amber or Red determination regardless of whether the literal claim text passes ISO 14021:2016 requirements. Where the misleading impression can be cured by reformulation, the determination is Amber. Where no reformulation of the claim can accurately convey what the claimant intends, the determination is Red. |
> Cross-references: ISO 14021:2016 Cl.5.7(a)(g); Annex C Section C.2 |
10. Evidence Quality Standards
10.1 The Competent and Reliable Standard
Evidence must satisfy all three components of the competent and reliable standard:
Expert basis: produced, evaluated, or validated by professionals with expertise in the relevant discipline.
Objective conduct: produced without conflict of interest in the outcome. Evidence produced by the claimant’s own staff to support a predetermined conclusion does not satisfy this component.
Accepted procedures: methodology is a recognised standard or accepted professional practice in the relevant field.
10.2 Evidence Quality Scoring
Req. | 10.2.1 — Evidence scoring |
|---|
Speeki shall score each piece of submitted evidence and record the score in the assessment log. Scores are STRONG, ADEQUATE, WEAK, or INSUFFICIENT, as defined in the scoring matrix below. A claim cannot receive a Green determination if any critical evidence element is scored WEAK or INSUFFICIENT. |
> Cross-references: ISO 14021:2016 Cl.6.4; Annex C Section C.5 |
Score | Criteria | Typical examples | Determination impact |
|---|---|---|---|
STRONG | All three components of the competent and reliable standard satisfied in full | Accredited lab test; ISO-compliant GHG inventory by qualified practitioner; independent chain of custody certification | Supports Green on elements where this evidence applies |
ADEQUATE | All three components satisfied with minor, non-material limitations | Qualified professional with minor independence question; recognised standard with minor procedural gap | Supports Green with documentation of limitations |
WEAK | Fails one of the three components | Internal staff produced without expert validation; non-independent producer; non-standard methodology | Cannot support Green on any critical element; triggers clarification request |
INSUFFICIENT | Fails two or more components, or absent | Supplier marketing material only; no documentation submitted; commercially confidential evidence | Triggers formal information request; blocks assessment completion until resolved |
10.3 The Currency Requirement
Req. | 10.3.1 — Currency assessment |
|---|
Speeki shall treat as stale any evidence that: predates a material change to the product, supply chain, or manufacturing process; is more than 12 months old without documented confirmation of continuing accuracy; or reflects a market, channel, or regulatory context that has since changed materially. Stale evidence shall be scored INSUFFICIENT regardless of its nominal validity date. |
> Cross-references: ISO 14021:2016 Cl.5.7(q); ISO 14021:2016 Cl.6.2.2 |
10.4 The Specificity Hierarchy
Specificity Level | Adequacy for Substantiation |
|---|---|
PRODUCT-SPECIFIC: Evidence produced for this exact product in its current specification | Meets the specificity requirement. STRONG or ADEQUATE scoring eligible. |
PRODUCT-FAMILY: Evidence covers a defined family of which this product is a confirmed member with identical relevant attributes | Acceptable if membership is documented and relevant attributes are verified identical. ADEQUATE scoring eligible. |
MATERIAL-SPECIFIC: Evidence covers a specific material component only, not the full product | Acceptable only where the claim is expressly and specifically about that component and is scoped accordingly on its face. Cannot support an unqualified product-level claim. |
CATEGORY-GENERIC: Industry average or category data | INSUFFICIENT for product-level claims. May provide contextual support for comparative claims framed at category level only, if framed as such. |
SUPPLIER DECLARATION: Supplier’s own representation without independent verification | INSUFFICIENT as standalone substantiation for any element. May supplement other evidence but shall not substitute for independent verification. |
11. Regulatory Compliance Assessment
Stage 6 of the assessment sequence applies the regulatory framework of each jurisdiction in scope. This section sets out the requirements for that assessment. Current regulatory requirements are in Annex B and the GreenDesk Regulatory Reference Library.
Req. | 11.1.1 — Regulatory framework loading |
|---|
Speeki shall load the current applicable regulatory framework for every jurisdiction identified in Stage 1 from the GreenDesk Regulatory Reference Library before conducting Stage 6. Assessments shall never rely on a prior knowledge of regulatory requirements without confirming currency from the Library. |
> Cross-references: Annex B; GreenDesk Regulatory Reference Library |
Req. | 11.1.2 — Absolute prohibition check |
Speeki shall check whether any absolute regulatory prohibition applies to the claim before assessing other regulatory requirements. An absolute prohibition results in a Red determination for the affected jurisdiction regardless of all other findings. Absolute prohibitions are listed in Annex B Section B.2. |
> Cross-references: Annex B Section B.2 |
Req. | 11.1.3 — Most stringent standard applies |
Speeki shall where a claim appears in multiple jurisdictions with different requirements for the same claim element, apply the most stringent requirement as the governing standard for the determination, unless the claimant has specified separate versions of the claim for different jurisdictions. Separate versions are each assessed separately. |
> Cross-references: Annex B; GreenDesk Regulatory Reference Library |
Req. | 11.1.4 — Regulatory finding documentation |
Speeki shall record a specific regulatory finding for each jurisdiction, stating: the framework applied; whether the claim complies; and if not, the specific provision that is not satisfied and the specific reason. |
> Cross-references: Annex B |
12. The Determination
12.1 Determination Levels
Determination | Criteria — all conditions must be satisfied |
|---|---|
GREEN — Conforming | (a) All applicable ISO 14021:2016 clauses: PASS; (b) All applicable regulatory framework requirements in every jurisdiction in scope: compliant; (c) Net impression: no misleading impression identified; (d) All critical evidence elements scored STRONG or ADEQUATE; (e) All disclaimers and qualifications: adequate; (f) No absolute prohibition applies. A Green determination is a positive finding on all six conditions simultaneously. |
AMBER — Conditionally Conforming | The claim would receive a Green determination if specified modifications are made. Every modification is stated precisely: what must change; which specific clause, provision, or doctrine is satisfied by the change; and by what date the modification is required before the claim may be used. An Amber determination is not a clearance — it is a conditional finding that becomes effective only when the stated modifications are implemented. |
RED — Non-Conforming | The claim as submitted fails one or more of the six Green conditions. Every ground of non-conformity is stated specifically: the ISO 14021 clause, regulatory provision, or advertising law doctrine; the specific finding; and whether the non-conformity can be remedied by reformulation (Amber potential) or represents an absolute prohibition (no reformulation possible). |
12.2 The Determination Rationale
Req. | 12.2.1 — Rationale content |
|---|
Speeki shall ensure that every determination includes a written rationale that records: the claim type classification; the net impression finding; each applicable ISO 14021:2016 clause and the assessment result; the evidence quality score for each critical element; each disclaimer adequacy finding; each regulatory framework finding for each jurisdiction in scope; and the specific basis for the Green, Amber, or Red determination. For Amber: the precise modification required and the specific provision it satisfies. For Red: every ground of non-conformity with the specific clause, provision, or doctrine. |
> Cross-references: ISO 17029:2019; NAD Procedures (BBB National Programs, rev. March 2026) |
13. The GreenDesk Determination Certificate
Req. | 13.1.1 — Certificate issuance |
|---|
Speeki shall issue a GreenDesk Determination Certificate for every Green or Amber determination. Red determinations are accompanied by a GreenDesk Non-Conformity Report, not a certificate. No certificate shall be issued without Expert sign-off under the HIITR model in Section 15. |
> Cross-references: Section 15; ISO 17029:2019 |
Req. | 13.1.2 — Certificate content |
Speeki shall ensure that every GreenDesk Determination Certificate contains: the Speeki GreenDesk® wordmark; the assessment standard reference (SPK GCMS3001:2026, First Edition, 2026); the dual-layer assessment statement in Clause 13.1.3; the claimant organisation name; the exact claim text or description assessed; the ISO 14021:2016 clause applied; the markets and channels in scope; the product or SKU; the determination (GREEN or AMBER); the determination date; the evidence renewal date; the full written determination rationale; the list of evidence reviewed; the issuing Expert’s name and title; the Speeki entity; and the unique assessment reference number. |
> Cross-references: ISO 17029:2019 |
Req. | 13.1.3 — Dual-layer assessment statement |
Speeki shall include the following statement on every GreenDesk Determination Certificate: ‘This determination was conducted by Speeki under SPK GCMS3001:2026 (Green Claims Assessment and Certification Guidance, First Edition, 2026). SPK GCMS3001:2026 is designed in accordance with the principles of ISO 17029:2019 and incorporates the requirements of ISO 14021:2016, ISO 14020:2022, and applicable regulatory frameworks. The claim has been assessed for conformity with ISO 14021:2016 [where applicable] and for compliance with SPK GCMS3001:2026. This determination was reviewed and signed by a Speeki Expert.’ |
> Cross-references: ISO 17029:2019; SPK GCMS3000:2026 Annex B |
Req. | 13.1.4 — Certificate use |
Speeki shall state on every certificate that it may be referenced by the claimant in regulatory submissions, procurement responses, board reporting, investor communications, and internal governance documentation. The certificate may not be displayed in consumer-facing marketing without Speeki’s written consent. The determination relates to the claim as submitted and as evidenced at the date of determination. |
> Cross-references: ISO 17029:2019 |
Req. | 13.1.5 — Evidence renewal date |
Speeki shall state on every Green and Amber certificate the evidence renewal date, being the earlier of: the expiry date of the most constrained piece of evidence in the evidence file; or 12 months from the determination date. Speeki shall send automated renewal alerts to the claimant at 90, 60, and 30 days before the evidence renewal date. |
> Cross-references: ISO 14021:2016 Cl.5.7(q); SPK GCMS3000:2026 Cl.9.5 |
14. Special Categories
The following claim categories carry structural risks requiring additional assessment steps beyond the standard seven-stage sequence. Speeki shall apply the additional requirements below whenever a submission falls into one of these categories.
Special Category | Additional Assessment Requirements |
|---|---|
Health-environment crossover claims (reef-safe, non-toxic to marine life, free of harmful chemicals) | Apply the heightened health claims substantiation standard: the FTC requires randomised, controlled evidence from experts in the relevant field for health-related attributes. Flag as HIITR NOTIFY. Check against current enforcement markers, including ACCC v Edgewell Personal Care (proceedings commenced July 2025, Banana Boat and Hawaiian Tropic reef friendly claims). |
Future-state and forward-looking claims (net zero targets, carbon neutrality commitments, renewable transition plans) | Assess against: EU EmpCo Directive Article 6(2)(d) (clear, objective, publicly available, verifiable commitment; detailed implementation plan; measurable time-bound targets; regular independent third-party verification); and the Santos standard (ACCR v Santos, Federal Court of Australia, 17 February 2026: documented reasonable grounds at time of publication; disclosed assumptions; acknowledged uncertainty). Flag as HIITR NOTIFY. |
Offset-based product-level climate claims in EU B2C (carbon neutral, climate neutral, net zero, carbon positive, carbon compensated) from 27 September 2026 | Apply EU Directive (EU) 2024/825 Annex I point 4c: absolute prohibition regardless of offset quality. Result is Red determination for the EU channel. No evidence, however strong, enables compliance with an absolute prohibition. Flag as HIITR AUTONOMOUS with Red outcome documented. |
Supply chain origin claims (ocean plastic, ocean bound, deforestation-free, sustainably sourced, ethically harvested) | Apply the Clorox net impression test: what does the stated origin imply to a reasonable consumer? Does that implication match reality? Require chain of custody documentation tracing material from the exact claimed origin. Apply UK CMA supply chain guidance (January 2026): reliance on supplier declarations without independent verification is insufficient. Flag as HIITR NOTIFY. |
Claimed-origin recycled content (ocean plastic, post-consumer, pre-consumer) | Apply the specificity hierarchy in Section 10.4. Chain of custody must be product-specific and cover this specific volume. Check the Clorox case pattern: technically accurate origin terminology that creates a misleading net impression about geographic source is non-compliant regardless of definitional accuracy. Flag as HIITR NOTIFY. |
CSRD sustainability report content used in consumer-facing or investor-facing marketing | EU EmpCo Directive applies to content excerpted from sustainability reports and used in marketing communications. Assess as a standard environmental claim under this standard. The CSRD report origin does not exempt the claim from EmpCo requirements. |
15. The HIITR Model and Expert Review
Req. | 15.1.1 — Expert review is mandatory |
|---|
Speeki shall ensure that every GreenDesk determination is reviewed by a Speeki Expert before the determination is issued. No determination of any kind — Green, Amber, or Red — shall be issued without Expert sign-off. This requirement is absolute and applies to every assessment without exception. |
> Cross-references: ISO 17029:2019; SPK GCMS3000:2026 Cl.12 |
Req. | 15.1.2 — Expert authority |
Speeki shall ensure that the Expert reviewing a determination has the authority to: approve the preliminary determination as prepared by Nicole; modify the preliminary determination with documented reasons; return the assessment to Nicole for additional review with specific instructions; or escalate to senior Expert review. No assessment may be finalised without one of these four outcomes being documented. |
> Cross-references: ISO 17029:2019 |
Req. | 15.1.3 — HIITR AUTONOMOUS |
Speeki shall apply HIITR AUTONOMOUS mode to routine assessments where: the claim type is straightforward; the evidence is STRONG or ADEQUATE on all elements; no regulatory escalation trigger applies; and no special category flag has been raised. In AUTONOMOUS mode, Nicole prepares the full assessment and preliminary determination, which the Expert reviews and signs. |
> Cross-references: ISO 17029:2019 |
Req. | 15.1.4 — HIITR NOTIFY |
Speeki shall apply HIITR NOTIFY mode and flag the assessment to the Expert before completing the preliminary determination where: the assessment raises a borderline puffery vs implied claim question; a special category flag has been raised; the comparator in a comparative claim is not specified in the submission; or a non-critical evidence gap exists that should be noted before Expert sign-off. |
> Cross-references: ISO 17029:2019 |
Req. | 15.1.5 — HIITR ESCALATE |
Speeki shall apply HIITR ESCALATE mode and stop — seeking Expert human judgment before any preliminary determination is prepared — where: the claim creates a net impression so fundamentally misleading that withdrawal rather than modification may be required; an establishment claim implies a certification or verification that is found not to exist, creating potential misrepresentation risk; a supply chain origin claim lacks chain of custody documentation consistent with the Clorox case pattern; a future-state climate claim lacks documented reasonable grounds at time of publication; or internal communications described by the claimant suggest the claim was deployed despite known evidence gaps. |
> Cross-references: ISO 17029:2019; Section 5.3 |
16. Independence and Impartiality
Req. | 16.1.1 — No advisory role |
|---|
Speeki shall maintain structural independence from the claimant at all times. Speeki shall not advise claimants on what environmental claims to make, what evidence to assemble, or how to formulate claims to achieve a Green determination. Speeki assesses claims as submitted. Structural independence is the foundation of the value of a GreenDesk determination. |
> Cross-references: ISO 17029:2019; SPK GCMS3000:2026 Cl.6 |
Req. | 16.1.2 — Conflicts of interest |
Speeki shall maintain and apply a conflicts of interest policy. An Expert who has provided advisory services to a claimant on the subject matter of the claim being assessed shall not conduct or sign the determination for that claim. Conflicts shall be identified before assignment and documented. |
> Cross-references: ISO 17029:2019 |
Req. | 16.1.3 — Confidentiality |
Speeki shall treat all claimant submissions, evidence files, and determination records as confidential. Speeki shall not disclose claimant submission content or determination outcomes to third parties without the claimant’s consent, except as required by applicable law or regulatory authority. |
> Cross-references: ISO 17029:2019 |
Req. | 16.1.4 — Record retention |
Speeki shall retain all assessment records — the submission, Nicole’s assessment log, the Expert’s review notes, the issued determination, and all evidence submitted — for a minimum of five years from the determination date. |
> Cross-references: ISO 17029:2019; ISO 14021:2016 Cl.6.2.2 |
ANNEX A — ISO 14021:2016 Clause Reference Matrix (Normative)
This Annex is normative. Every clause listed is assessed in every relevant claim submission. ‘Not applicable’ requires a specific documented basis.
ISO 14021:2016 Clause | Subject | Stage Applied |
|---|---|---|
Clause 5.3 | Vague or non-specific claims prohibited | Stage 1 (classification), Stage 3 |
Clause 5.4 | ‘Free of’ claims | Stage 3 |
Clause 5.5 | Sustainability claims prohibited | Stage 3 |
Clause 5.7(a) | Accurate and not misleading | Stage 2 (net impression), Stage 3 |
Clause 5.7(b) | Substantiated and verified before publication | Stage 4 (evidence), Stage 5 |
Clause 5.7(c) | Relevant to the product in context | Stage 3 |
Clause 5.7(d) | Scope stated (product/component/packaging) | Stage 3 |
Clause 5.7(e) | Specific as to environmental aspect | Stage 3 |
Clause 5.7(f) | No double-claiming single benefit | Stage 3 |
Clause 5.7(g) | Unlikely to result in misinterpretation | Stage 2, Stage 3 |
Clause 5.7(h) | True for final product; lifecycle considered | Stage 3 |
Clause 5.7(i) | No implied third-party endorsement | Stage 3 |
Clause 5.7(j) | No exaggeration | Stage 3 |
Clause 5.7(k) | Not misleading by omission | Stage 2, Stage 3 |
Clause 5.7(l) | Environmental aspect exists or likely to be realised | Stage 3, Stage 4 |
Clause 5.7(m) | Explanatory statement adequate and proximate | Stage 5 |
Clause 5.7(n) | Comparative basis and timing stated | Stage 3 |
Clause 5.7(o) | Pre-existing attribute not presented as new | Stage 3 |
Clause 5.7(p) | No ‘free of’ for absent-category substance | Stage 3 |
Clause 5.7(q) | Reassessed on change | Stage 4 (currency) |
Clause 5.8 | Symbol use | Stage 3 |
Clause 5.10 | Mobius loop requirements | Stage 3 |
Clause 6.1 | Claimant responsibility; evidence before publication | Stage 4 |
Clause 6.3 | Comparative claims methodology | Stage 3, Stage 4 |
Clause 6.4 | Method selection hierarchy | Stage 4 |
Clause 6.5.1 | Verifiability without CBI | Stage 4 |
Clause 6.5.3 | Minimum documentation | Stage 4 |
Clause 7.2 | Compostable | Stage 3 |
Clause 7.3 | Degradable/Biodegradable | Stage 3 |
Clause 7.4 | Designed for disassembly | Stage 3 |
Clause 7.5 | Extended life product | Stage 3 |
Clause 7.6 | Recovered energy | Stage 3 |
Clause 7.7 | Recyclable | Stage 3 |
Clause 7.8 | Recycled content | Stage 3 |
Clause 7.9 | Reduced energy consumption | Stage 3 |
Clause 7.10 | Reduced resource use | Stage 3 |
Clause 7.11 | Reduced water consumption | Stage 3 |
Clause 7.12 | Reusable and refillable | Stage 3 |
Clause 7.13 | Waste reduction | Stage 3 |
Clause 7.14 | Renewable material | Stage 3 |
Clause 7.15 | Renewable energy | Stage 3 |
Clause 7.16 | Sustainable (prohibited) | Stage 3 |
Clause 7.17 + Amd 1:2021 | Carbon/GHG claims | Stage 3, Stage 5, Stage 6 (EU EmpCo 4c) |
Annex B — Applicable Regulatory Frameworks (Normative)
This Annex is normative. It sets out the current applicable regulatory instruments as at the publication date of this edition. The GreenDesk Regulatory Reference Library is updated continuously between editions and governs where it reflects a more recent position.
Note on the EU Green Claims Directive: The proposed EU Green Claims Directive (COM(2023)0166) was withdrawn by the European Commission in June 2025. It is not operative and shall not be cited as a current legal requirement. Directive (EU) 2024/825 (EmpCo Directive) is the current operative EU instrument and is not affected by the GCD withdrawal.
B.1 Jurisdiction Frameworks
Jurisdiction | Operative Instruments | Key Assessment Points |
|---|---|---|
European Union | Directive (EU) 2024/825 (EmpCo) — applies 27 Sep 2026; UCPD 2005/29/EC (general misleading conduct); European Commission Q&A updated 18 May 2026 | Annex I 4a (generic claims); Annex I 2a (unverified labels); Annex I 4c (offset-based product climate claims, absolute prohibition from 27 Sep 2026); Article 6(2)(d) (future performance claims); B2C scope; CSRD excerpts used in marketing |
United Kingdom | DMCCA 2024 (in force 6 Apr 2025); CMA Green Claims Code (Sep 2021); CMA Supply Chain Guidance (Jan 2026); FCA SDR Anti-Greenwashing Rule (in force 31 May 2024) | Six-point CMA test; up to 10% global turnover fines (no court required); supply chain claim verification; FCA financial product communications |
United States (Federal) | FTC Green Guides 16 CFR Part 260 (2012, under revision); FTC Act Section 5; FTC Advertising Substantiation Policy | Competent and reliable evidence standard; express and implied claim substantiation; carbon neutral and recyclability requirements; certifications and seals |
United States (California) | AB 1305 (in force 1 Jan 2024); SB 343 (CalRecycle qualifying materials, compliance from 4 Oct 2026) | Website disclosure for carbon/offset claims; qualifying materials list for recyclable claims; penalties up to USD 500,000 per violation |
Australia | ACL (Competition and Consumer Act 2010 Sch 2) ss.18, 29; ASIC Act 2001; ACCC Environmental Claims Guidance (Dec 2023) | Misleading or deceptive conduct; strict liability; AUD 50m / 30% turnover maximum penalty; ACCC eight principles; ASIC ESG product claims |
Singapore | Consumer Protection (Fair Trading) Act (CPFTA); MAS ESG fund disclosure guidelines | Misleading representations; ESG fund disclosure requirements |
Canada | Competition Act RSC 1985, c C-34 as amended 2024, s.74.01(1)(b.1) | Environmental claims must be based on adequate and proper testing; penalty up to CAD 10m or 3% annual worldwide gross revenues |
B.2 Absolute Prohibitions
The following result in a Red determination for the stated jurisdiction regardless of evidence quality. No evidence, however strong, enables compliance with an absolute prohibition.
Absolute Prohibition | Jurisdiction and Instrument |
|---|---|
Product-level claims of neutral, reduced, or positive climate impact based on carbon offsetting outside the product’s own value chain from 27 September 2026. Covers: ‘carbon neutral’, ‘climate neutral’, ‘CO₂ neutral’, ‘net zero’, ‘carbon positive’, ‘climate positive’, ‘carbon compensated’ and equivalents at product level. NOTE: Company-level offset claims are not in scope of this prohibition. Genuine lifecycle neutrality within the product’s own value chain is not in scope. | EU — Directive (EU) 2024/825 Annex I point 4c |
Generic environmental claims (‘eco-friendly’, ‘green’, ‘sustainable’, ‘nature-friendly’, ‘ecological’, ‘climate friendly’, ‘environmentally friendly’, ‘biodegradable’, ‘biobased’ and equivalents) where the specific environmental attribute is not provided in clear and prominent terms on the same medium from 27 September 2026. Exception: claims backed by EU Ecolabel, nationally recognised ISO 14024 Type I scheme, or specific Union law. | EU — Directive (EU) 2024/825 Annex I point 4a |
Displaying a sustainability label not based on an approved certification scheme (independent third-party monitoring by legally separate entity; publicly available criteria; non-discriminatory access) from 27 September 2026. | EU — Directive (EU) 2024/825 Annex I point 2a |
Recyclable claims for LDPE flexible film and other materials not on CalRecycle’s qualifying materials list from 4 October 2026. | US (California) — SB 343; CalRecycle final findings 4 April 2025 |
Annex C — The Advertising Law Assessment Methodology (Normative)
This Annex is normative. The methodology set out here applies to every assessment under this standard. It is derived from fifty years of developed practice in the FTC Advertising Substantiation doctrine, the NAD methodology, the UK ASA/CAP framework, and the EFSA health claims evaluation model — all structurally analogous to green claims assessment.
C.1 Claim Type Taxonomy
At Stage 1, every claim is classified under the following taxonomy. The classification drives substantiation requirements. Multiple types may apply to a single claim.
Type | Definition, Examples, and Substantiation Consequence |
|---|---|
EXPRESS | Direct, explicit statement of a specific environmental fact. EXAMPLE: ‘30% post-consumer recycled content’; ‘Carbon footprint of 2.4 kg CO₂e per unit’. SUBSTANTIATION: Direct, specific, verifiable evidence of the exact stated fact. Scope must match the claim exactly — a claim about packaging that appears to cover the product as a whole is non-compliant even if the packaging claim is accurate. |
IMPLIED | Conveyed indirectly through language, imagery, or context without being explicitly stated. EXAMPLE: ‘Ocean plastic’ implies ocean-sourcing; certification-style badge implies independent certification. SUBSTANTIATION: Required just as fully as an express claim. The net impression governs — not the literal text. All implied claims identified in Stage 2 are assessed as express claims. |
ESTABLISHMENT | Represents that the claimant has a specific level of independent substantiation or certification. EXAMPLE: ‘Verified recyclable by [organisation]’; ‘Certified carbon neutral’. SUBSTANTIATION: Two-layer: (1) the underlying attribute must be accurate; AND (2) the stated verification must actually exist, be current, cover this product in its current form, and have the scope the claim implies. |
COMPARATIVE | Asserts relative environmental performance versus a comparator. EXAMPLE: ‘40% less carbon than prior formulation’; ‘22% below market average’. SUBSTANTIATION: Current comparator; identical functional unit; identical methodology; statistical significance established; absolute figure available alongside any relative percentage; product and packaging stated separately (ISO 14021:2016 Cl.6.3.5). |
MONADIC | Non-comparative performance claim. EXAMPLE: ‘Up to 40% less energy’; ‘At least 30% recycled’. SUBSTANTIATION: The stated bound must be achievable under realistic consumer conditions. ‘Up to 40%’ where the realistic range is 2–40% depending on usage mode may be misleading about the typical case. |
PUFFERY | So subjective or exaggerated that no reasonable consumer treats it as factual. EXAMPLE: ‘Nature thanks you’; ‘The green choice’. NOTE: ISO 14021:2016 Clause 5.3 is stricter than puffery doctrine. A statement qualifying as puffery under advertising law may still be prohibited as a vague/non-specific claim. Apply the stricter standard. |
C.2 The Net Impression Doctrine
The net impression is the overall understanding that a reasonable consumer or investor in the target market forms from the claim as a whole — not from the literal text alone. It is the governing standard in every assessment.
The net impression is assessed across four elements:
Headline vs body copy: the majority of consumers read the headline; a minority read body copy. A technically accurate disclaimer in body copy does not cure a misleading headline. The headline claim is assessed independently.
Imagery and visual context: images, icons, colours, and symbols convey claims just as words do. Ocean imagery alongside a recycled plastic claim implies ocean-sourcing. A certification badge implies independent certification. Every environmental implied claim created by described imagery is identified and assessed.
Omitted information: a claim can be literally true but misleading by omission. ISO 14021:2016 Clause 5.7(k) prohibits this. What material fact would a reasonable consumer expect to be disclosed that is not?
Audience calibration: the net impression is formed by a reasonable consumer or investor in the specific target market. B2B technical documentation may include qualifications that would be insufficient in a consumer retail context.
The Clorox Australia case (ACCC v Clorox Australia Pty Ltd [2025] FCA 357) is the definitive net impression case in green claims. The court accepted that the term ‘Ocean Bound Plastic’ was technically defined differently in industry usage. The penalty was AUD 8.25 million — because the net impression created for reasonable consumers was that the plastic came from the ocean. Technical accuracy of a defined term does not override the consumer understanding standard.
C.3 Implied Claim Identification
The following language patterns reliably create implied claims. Every claim submission is scanned for these patterns:
Language Pattern | Implied Claim Created |
|---|---|
Sourcing terms: ‘ocean plastic’, ‘forest-friendly’, ‘sustainably sourced’, ‘ethically harvested’ | Implies specific sourcing conditions that must be substantiated with the specificity the term implies. ‘Ocean plastic’ implies the ocean. ‘Sustainably sourced’ implies a verified sustainability standard. |
Origin claims: ‘natural’, ‘plant-based’, ‘bio-based’, ‘from nature’ | Implies the entire product meets the stated origin. If only a proportion qualifies, an unqualified term implies the whole. Percentage must be stated. |
Process claims: ‘responsibly made’, ‘cleanly produced’, ‘green manufacturing’ | Implies the manufacturing process meets a defined, verifiable environmental standard. |
Certification and endorsement language: ‘certified’, ‘verified’, ‘approved’, ‘recognised’, ‘accredited’ | Implies specific, named, independent certification exists for this product in its current form. |
Outcome claims: ‘reduces ocean plastic’, ‘fights climate change’, ‘protects rainforests’ | Implies a measurable environmental outcome has been or will be achieved. Requires specific evidence of that outcome. |
Comparative superlatives: ‘most sustainable’, ‘lowest carbon’, ‘greenest option’ | Implies superiority over all or most alternatives. Requires evidence of comparative position, not just absolute performance. |
Certification-style visual elements: badges, shields, seals, check marks, logos | Implies independent third-party certification even without text stating this. ISO 14021:2016 Clause 5.7(i) prohibits presenting claims to imply third-party endorsement where none exists. |
C.4 Comparative Claim Methodology
Comparative claims require the following five conditions to be satisfied. Each condition is documented in the assessment:
The comparator is current and appropriate — reflects the current market, covers a product performing the same function for the same consumers.
The functional unit is identical — both products measured on the same basis, producing the same outcome, over the same period.
The measurement methodology is identical — both products measured using the same standard or method.
Statistical significance is established — the difference between the product and comparator exceeds the margin of measurement error.
ISO 14021:2016 Clause 6.3.3 absolute vs relative rule applied: where the relative percentage is significantly larger than the absolute difference, the relative presentation may be misleading. A change from 10% to 15% recycled content is a 50% relative increase but a 5 percentage point absolute increase. The standard disfavours the relative presentation in this context.
C.5 Evidence Quality Standards
The three-part competent and reliable test applied in Stage 4 of the assessment sequence:
Expert basis: the evidence is generated, evaluated, or validated by experts in the specific discipline relevant to the claim.
Objective conduct: produced without conflict of interest in the outcome. Claimant’s own staff or a supplier producing evidence to support a predetermined conclusion fail this test.
Accepted procedures: methodology is a recognised international standard, regional standard with international acceptability, or peer-reviewed industry methodology — in that order of preference (ISO 14021:2016 Clause 6.4).
C.6 Disclaimer Adequacy
A disclaimer does not cure a misleading headline unless it passes all four of the following tests:
Prominence: displayed in a font size, weight, and colour that makes it likely to be noticed by the average consumer in the stated channel.
Presentation: legible against the background, not obscured by design elements.
Placement: within the consumer’s normal visual attention path for the channel.
Proximity: immediately adjacent to the claim it qualifies.
The headline-only test governs: if the headline creates a false impression without the disclaimer, the disclaimer is assessed for adequacy but does not automatically cure the non-conformity.
The following formulations are explicitly prohibited under ISO 14021:2016 and are non-compliant under this standard regardless of other qualifications:
‘Recyclable where facilities exist’ — Clause 7.7.2(c)
‘Compostable where facilities exist’ — Clause 7.2.2.4(c)
‘Reusable/refillable where facilities exist’ — Clause 7.12.2.3(c)
‘Can be disassembled where facilities exist’ — Clause 7.4.2.4(c)
Website references, QR codes, and footnotes referencing external documents do not substitute for mandatory disclosures required to appear on the claim itself. The mandatory disclosures for carbon neutral claims under ISO 14021:2016 Clause 7.17.3.3 must appear on the claim — not on a linked website.
Annex D — Relationship to SPK GCMS3000:2026 (Informative)
This Annex is informative. It describes how GCMS3001 and GCMS3000 relate in practice.
Element | SPK GCMS3000:2026 |
|---|---|
Subject | The organisation’s internal Green Claims Management System |
What is certified | The organisation (its management system) |
The certificate | Speeki Verdant™ — awarded to the organisation |
Requirement language | The organisation shall |
Certification product | Speeki Verdant™ |
Frequency | Triennial certification audit + annual surveillance |
The two standards are independent. An organisation may be certified under GCMS3000 without using GreenDesk for individual claims, and may use GreenDesk without GCMS3000 certification. The combination provides the most complete governance posture: Verdant certification demonstrates the system; GreenDesk certificates demonstrate each claim within it.
Bibliography
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