
Transition Plan Disclosure: What Investors Need to See Beyond Net-Zero Commitments
Learn the most common ESG reporting mistakes made by UAE companies and how to improve materiality, data quality, emissions reporting and assurance readiness.
Sustainability communication is becoming more demanding. Companies can still speak about environmental progress, but the language needs to be accurate, specific, and supported by evidence.
This is why green claims evidence has become a practical business issue. A claim such as “eco-friendly,” “green,” “carbon neutral,” “renewable,” “plastic-free,” or “sustainable” may appear simple, but it can create risk if the company cannot explain what the claim covers, what evidence supports it, and what limitations apply.
From 27 September 2026, the EU’s Empowering Consumers for the Green Transition Directive will apply across Member States. The rules restrict vague environmental claims where excellent environmental performance cannot be demonstrated and limit sustainability labels that are not based on recognised certification schemes or established by public authorities.
Green claims are no longer only marketing statements. They can influence purchasing decisions, procurement evaluations, investor perception, regulatory scrutiny, and brand trust. This means they need to be managed with the same discipline as other business-sensitive communication.
The European Commission has previously stated that many environmental claims are vague or unsupported, and its green-claims work identified that 40% of claims had no supporting evidence. This explains why regulators are moving towards clearer rules on environmental communication.
The issue is not whether companies should communicate sustainability progress. They should. The issue is whether the wording creates an impression that goes beyond the evidence. A company may have a genuine environmental improvement, but if the claim is too broad, it may still be misleading.
A defensible claim is specific enough for the reader to understand and supported enough for the company to evidence. It should not rely on broad language where the actual improvement is narrow.
For example, saying that a product is “sustainable” is usually too broad unless the company can explain the basis of the claim. If the improvement relates only to recycled packaging, the claim should say that. If a company claims “100% renewable electricity,” it should have electricity consumption records, certificate evidence, contractual documentation, and retirement or cancellation records. If a company says “carbon neutral,” it should explain the boundary, emissions calculation method, reporting year, treatment of Scope 1, Scope 2, and relevant Scope 3 emissions, and the role of offsets.
The stronger the claim, the stronger the evidence needs to be.
Claim Type | Better Approach |
“Eco-friendly product” | State the specific environmental attribute, such as recycled content, lower energy use, or reduced packaging. |
“Carbon neutral” | Explain the boundary, year, methodology, emissions covered, and role of offsets. |
“Renewable electricity” | Keep evidence for consumption, certificates, vintage, geography, ownership, and retirement. |
“Sustainable packaging” | Clarify whether the claim relates to material type, recyclability, recycled content, or reduced weight. |
“Plastic-free” | Confirm whether it applies to the product, packaging, component, or full supply chain. |
This approach does not weaken the message. It makes the message more credible.
Companies should maintain an evidence file for each material environmental claim. The file does not need to be complex, but it should allow another person to understand and test the claim.
A good evidence file usually includes the claim wording, scope, relevant product or activity, reporting period, source data, calculation method, certificates, supplier confirmations, assumptions, limitations, and approval record. For emissions-related claims, it should also include emissions factors, organisational boundaries, operational boundaries, offset details where relevant, and reconciliation with reported greenhouse gas data.
This process is particularly important where claims are used in packaging, sales proposals, tenders, product catalogues, ESG reports, or investor-facing documents. These are contexts where claims can directly influence commercial decisions.
The most practical first step is a claims inventory. Companies should identify every place where environmental language is used externally and commercially. This includes websites, LinkedIn posts, brochures, proposals, packaging, labels, sustainability reports, product sheets, tender submissions, and sales decks.
Once the inventory is prepared, each claim should be assessed against four questions: what exactly is being claimed, what the claim applies to, what evidence supports it, and what limitations must be disclosed. If the answer is unclear, the claim should be revised or removed until proper evidence is available.
This review should not sit only with marketing. Sustainability teams understand the technical basis, legal or compliance teams understand risk, and business owners hold the operational evidence. A claim is strongest when all three perspectives are aligned.
The EU rules apply directly within the EU, but their commercial influence is wider. UAE and GCC companies that export products, supply multinational groups, participate in international tenders, or use environmental claims in customer-facing material may be affected through customer expectations and procurement requirements.
A regional supplier may be asked to justify packaging claims, renewable-energy statements, carbon-neutral language, recycled-content claims, or emissions-reduction statements. If evidence is missing, the issue can delay procurement, weaken tender responses, or reduce customer confidence.
This is especially relevant for consumer products, food and beverage, real estate, hospitality, manufacturing, logistics, packaging, construction materials, and energy services. In these sectors, sustainability communication is often used to create differentiation, but differentiation must now be supported by documentation.
The main shift is internal. Environmental claims should pass through a controlled approval process before publication. This does not mean companies should stop communicating sustainability progress. It means they should define what can be claimed, what evidence is required, who approves the wording, and how often the claim is reviewed.
A practical claims-control process should connect marketing, sustainability, compliance, procurement, and operations. It should also ensure that claims remain current. A claim supported in 2024 may become outdated if suppliers, certificates, products, methodologies, or reporting boundaries change.
Strong sustainability communication is not louder communication. It is clearer communication, supported by reliable evidence.
IFRSLAB supports companies in reviewing and strengthening sustainability communication. Our support can include green-claims reviews, ESG marketing claim assessments, carbon-neutral claim reviews, renewable-energy evidence checks, I-REC documentation support, product and packaging claim reviews, supplier evidence reviews, claims inventories, and internal approval frameworks.
Companies that prepare early will be better positioned to communicate progress confidently, respond to customer scrutiny, and reduce greenwashing risk.
Connect with IFRSLAB to assess your green claims evidence and strengthen the credibility of your sustainability communication.
This is why green claims evidence has become a practical business issue. A claim such as “eco-friendly,” “green,” “carbon neutral,” “renewable,” “plastic-free,” or “sustainable” may appear simple, but it can create risk if the company cannot explain what the claim covers, what evidence supports it, and what limitations apply.
From 27 September 2026, the EU’s Empowering Consumers for the Green Transition Directive will apply across Member States. The rules restrict vague environmental claims where excellent environmental performance cannot be demonstrated and limit sustainability labels that are not based on recognised certification schemes or established by public authorities.
Green claims are no longer only marketing statements. They can influence purchasing decisions, procurement evaluations, investor perception, regulatory scrutiny, and brand trust. This means they need to be managed with the same discipline as other business-sensitive communication.
The European Commission has previously stated that many environmental claims are vague or unsupported, and its green-claims work identified that 40% of claims had no supporting evidence. This explains why regulators are moving towards clearer rules on environmental communication.
The issue is not whether companies should communicate sustainability progress. They should. The issue is whether the wording creates an impression that goes beyond the evidence. A company may have a genuine environmental improvement, but if the claim is too broad, it may still be misleading.
A defensible claim is specific enough for the reader to understand and supported enough for the company to evidence. It should not rely on broad language where the actual improvement is narrow.
For example, saying that a product is “sustainable” is usually too broad unless the company can explain the basis of the claim. If the improvement relates only to recycled packaging, the claim should say that. If a company claims “100% renewable electricity,” it should have electricity consumption records, certificate evidence, contractual documentation, and retirement or cancellation records. If a company says “carbon neutral,” it should explain the boundary, emissions calculation method, reporting year, treatment of Scope 1, Scope 2, and relevant Scope 3 emissions, and the role of offsets.
The stronger the claim, the stronger the evidence needs to be.
Claim Type | Better Approach |
“Eco-friendly product” | State the specific environmental attribute, such as recycled content, lower energy use, or reduced packaging. |
“Carbon neutral” | Explain the boundary, year, methodology, emissions covered, and role of offsets. |
“Renewable electricity” | Keep evidence for consumption, certificates, vintage, geography, ownership, and retirement. |
“Sustainable packaging” | Clarify whether the claim relates to material type, recyclability, recycled content, or reduced weight. |
“Plastic-free” | Confirm whether it applies to the product, packaging, component, or full supply chain. |
This approach does not weaken the message. It makes the message more credible.
Companies should maintain an evidence file for each material environmental claim. The file does not need to be complex, but it should allow another person to understand and test the claim.
A good evidence file usually includes the claim wording, scope, relevant product or activity, reporting period, source data, calculation method, certificates, supplier confirmations, assumptions, limitations, and approval record. For emissions-related claims, it should also include emissions factors, organisational boundaries, operational boundaries, offset details where relevant, and reconciliation with reported greenhouse gas data.
This process is particularly important where claims are used in packaging, sales proposals, tenders, product catalogues, ESG reports, or investor-facing documents. These are contexts where claims can directly influence commercial decisions.
The most practical first step is a claims inventory. Companies should identify every place where environmental language is used externally and commercially. This includes websites, LinkedIn posts, brochures, proposals, packaging, labels, sustainability reports, product sheets, tender submissions, and sales decks.
Once the inventory is prepared, each claim should be assessed against four questions: what exactly is being claimed, what the claim applies to, what evidence supports it, and what limitations must be disclosed. If the answer is unclear, the claim should be revised or removed until proper evidence is available.
This review should not sit only with marketing. Sustainability teams understand the technical basis, legal or compliance teams understand risk, and business owners hold the operational evidence. A claim is strongest when all three perspectives are aligned.
The EU rules apply directly within the EU, but their commercial influence is wider. UAE and GCC companies that export products, supply multinational groups, participate in international tenders, or use environmental claims in customer-facing material may be affected through customer expectations and procurement requirements.
A regional supplier may be asked to justify packaging claims, renewable-energy statements, carbon-neutral language, recycled-content claims, or emissions-reduction statements. If evidence is missing, the issue can delay procurement, weaken tender responses, or reduce customer confidence.
This is especially relevant for consumer products, food and beverage, real estate, hospitality, manufacturing, logistics, packaging, construction materials, and energy services. In these sectors, sustainability communication is often used to create differentiation, but differentiation must now be supported by documentation.
The main shift is internal. Environmental claims should pass through a controlled approval process before publication. This does not mean companies should stop communicating sustainability progress. It means they should define what can be claimed, what evidence is required, who approves the wording, and how often the claim is reviewed.
A practical claims-control process should connect marketing, sustainability, compliance, procurement, and operations. It should also ensure that claims remain current. A claim supported in 2024 may become outdated if suppliers, certificates, products, methodologies, or reporting boundaries change.
Strong sustainability communication is not louder communication. It is clearer communication, supported by reliable evidence.
IFRSLAB supports companies in reviewing and strengthening sustainability communication. Our support can include green-claims reviews, ESG marketing claim assessments, carbon-neutral claim reviews, renewable-energy evidence checks, I-REC documentation support, product and packaging claim reviews, supplier evidence reviews, claims inventories, and internal approval frameworks.
Companies that prepare early will be better positioned to communicate progress confidently, respond to customer scrutiny, and reduce greenwashing risk.
Connect with IFRSLAB to assess your green claims evidence and strengthen the credibility of your sustainability communication.

Learn the most common ESG reporting mistakes made by UAE companies and how to improve materiality, data quality, emissions reporting and assurance readiness.

Learn the most common ESG reporting mistakes made by UAE companies and how to improve materiality, data quality, emissions reporting and assurance readiness.

Learn the most common ESG reporting mistakes made by UAE companies and how to improve materiality, data quality, emissions reporting and assurance readiness.
UAE : (+971) 52 710 0320 PAK : (+92) 300 2205746 UK : (+44) 786 501 4445
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S-25, Sea Breeze Plaza Shahrah-e-Faisal, Karachi
Office#1304, 13th Floor, Al Hafeez Heights, Gulberg III
P.O. Box 71, P.C. 100, Muscat
104 Broughton Lane Salford M6 6FL,
UAE : (+971) 52 710 0320 PAK : (+92) 300 2205746 UK : (+44) 786 501 4445
Office 2102 Al Saqr Business Tower 1, Sheikh Zayed Road
S-25, Sea Breeze Plaza Shahrah-e-Faisal, Karachi
Office#1304, 13th Floor, Al Hafeez Heights, Gulberg III
104 Broughton Lane Salford M6 6FL
P.O. Box 71, P.C. 100, Muscat
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